Environmental
Management System
(EMS) Implementation
Guide for the
Meat Processing Industry
Introduction
-------
Introduction
Welcome to the Environmental Management System (EMS) Implementation Guide for
the Meat Processing Industry. This Guide has been specifically designed to assist meat
processing facilities with a 10 module, step-by-step EMS implementation process. This
Guide should be used in sequence, as each module was designed to be a stepping-stone
towards a fully implemented EMS.
Each module of the Guide is designed to stand alone, having its own attachments and a
workshop presentation. A number of tools, including sample procedures, templates, and
forms, are included in each module in order to facilitate implementation. It is intended
that these tools be utilized and adapted to your specific facility.
This Guide was developed specifically for the meat processing sector with its content
relying heavily on EPA's Design for Environment Program for Integrated Environmental
Management Systems and NSF International's Environmental Management Systems: An
Implementation Guide for Small and Medium-Sized Organizations. The content of the
Guide was created as a collaborative effort by EPA's Sector Strategies Program, ICF
Consulting Inc. and Abt Associates Inc., the Iowa Waste Reduction Center, Iowa
Department of Natural Resources Waste Reduction Assistance Program, the American
Meat Institute, and the American Association of Meat Processors.
Included in Appendix A is a series of workshop/training presentations to be used in
conjunction with the Guide to assist with implementation of the EMS. These
presentations are designed for each of the modules presented in the Guide and include
content related activities. It is suggested that the workshops/training be held in
accordance with the work being completed on each of the modules. The
workshop s/training provide an opportunity to ask direct questions, obtain feedback, and
share experiences related to EMS implementation with other facilities.
Page i of v
-------
Table of Contents
Module 1: Getting Started
Introduction 1-2
Why Have an EMS? 1-2
Key Elements of an EMS 1-5
How Many Parts of an EMS Do We Already Have? 1-7
Implementation Planning 1-8
Who Should Do the Implementation? 1-9
Get Top Management Commitment 1-10
Other Issues to Keep in Mind 1-10
Documentation 1-11
Electronic or Paper Based Documentation 1-11
Homework 1-11
Attachment 1-A: EMS Checklist 1-12
Attachment 1-B: Environmental Requirements Checklist 1-17
Attachment 1-C: Sample Action Plan For EMS Implementation 1-22
Attachment 1-D: Layout Notes for EMS Procedures 1-26
Attachment 1-E: EMS Benefits 1-29
Attachment 1-F: Glossary of Terms 1-34
Module 2: Get Ready
Introduction 2-2
EMS Scope 2-4
Commitment 2-5
Project Champion 2-5
Core Team 2-5
Continual Improvement 2-11
Homework 2-12
Attachment 2-A: Additional Sources of Information and Contacts 2-13
Attachment 2-B: Gantt Chart for EMS Implementation 2-20
Module 3: Identifying Environmental Aspects and Impacts
Introduction 3-2
Terminology 3-2
The Recommended Approach 3-3
Legal and Other Requirements 3-9
Homework 3-11
Attachment 3-A: Identifying Activities, Products, and Services, Environmental Aspects
and Impacts Associated with Meat Processing Operations 3-12
Attachment 3-B: Sample Template For Identifying Activities/Products/Services,
Environmental Aspects and Impacts and Legal/Other Requirements 3-40
Attachment 3-C: Identification of Environmental Aspects Procedure 3-41
Attachment 3-D: Identification of Legal Requirements 3-43
Page ii of v
-------
Table of Contents
(Continued)
Page
Module 4: Determining Significant Environmental Aspects and Setting Objectives
and Targets
Introduction 4-2
Example Significance Procedure 1 4-4
Overall Risk Rating 4-6
Example Significance Procedure 2 4-11
Setting Environmental Objectives and Targets 4-14
Homework 4-18
Attachment 4-A: EMS Procedure: Setting and Tracking of Environmental Objectives
and Targets 4-20
Module 5: Environmental Management Programs (EMPs)
Introduction 5-2
Evaluating Alternatives 5-5
Operational Controls 5-6
Monitoring and Measurement 5-9
Homework 5-11
Attachment 5-A: Conducting an Alternatives Evaluation 5-12
Attachment 5-B: Development of Operational Controls 5-19
Module 6: Supporting EMS Elements
Introduction 6-2
Structure and Responsibility 6-2
Environmental Training Needs 6-5
Training Program 6-7
Communication Programs 6-9
Working with Stakeholders 6-12
Homework 6-15
Attachment 6-A: Example Organizational Chart 6-16
Attachment 6-B: Matrix of Accountabilities 6-17
Attachment 6-C: Procedure for Environmental Training (Awareness and Task-Specific)... 6-20
Attachment 6-D: Procedure for Communication with Stakeholders 6-23
Module 7: EMS Documentation and Records
Introduction 7-2
Document Control 7-5
EMS Records 7-6
Emergency Preparedness and Response 7-11
Homework 7-13
Attachment 7-A: Documentation and Record Keeping 7-14
Attachment 7-B: Emergency Preparedness 7-16
Page iii of v
-------
Table of Contents
(Continued)
Module 8: Monitoring and Measurement and Corrective and Preventive Action
Monitoring and Measurement 8-2
Internal EMS Assessment 8-4
Corrective and Preventive Action 8-7
Homework 8-9
Attachment 8-A: Conducting an Internal Compliance Assessment 8-10
Attachment 8-B: Conducting an Internal EMS Audit 8-12
Attachment 8-C: Taking Corrective Action 8-15
Module 9: Continuous Improvement
Continuous Improvement 9-2
Measurement Criteria 9-2
Management Review 9-4
Homework 9-6
Attachment 9-A: Conducting a Management Review 9-7
Module 10: Lessons Learned
Introduction 10-2
Lessons Learned 10-2
List of Figures
Figure 1-1: The "Plan, Do, Check, Act" Model 1-5
Figure 1-2: Key Elements of an EMS 1-6
Figure 2-1: Initial EMS Planning Steps 2-3
Figure 2-2: Pollution Prevention Hierarchy 2-11
Figure 3-1: Relationship Between Activities, Products, and Services and Aspects and
Impacts 3-3
Figure 3-2: Assessment of Level of Control or Influence 3-7
Figure 3-3: Grouping of Aspects 3-8
Figure 3-4: The Relationship Between Aspects, Legal and Other Requirements, and
Significance 3-10
Figures 3-5 - 3-17: Process Flow Diagrams 3-27
Figure 4-1: Impacts Screening Procedure for Determining Significant
Environmental Aspects 4-3
Figure 4-2: Risk Rating Matrix 4-7
Figure 4-3: Considerations for Setting Objectives and Targets 4-15
Figure 4-4: Significant Aspects and Objectives and Targets 4-17
Figure 5-1: Sample Environmental Management Program Form 5-4
Figure 5-2: Environmental Management Program - Sample Tool 5-5
Figure 5-3: Root Cause Diagram 5-8
Page iv of v
-------
Table of Contents
(Continued)
Figure 6-1: Graphic Representation of EMS Implementation 6-3
Figure 6-2: Internal Versus External Communication 6-10
Figure 6-3: Levels of Statekholder Interest 6-14
Figure 7-1: Hierarchy of EMS Documentation 7-4
Figure 8-1: Linkages Among EMS Audits, Corrective Action, and Management Review 8-5
Figure 8-2: Framework for Corrective Action Process 8-7
Figure 9-1: EMS Program Measurement Criteria Form 9-3
List of Tables
Table 3-1: General Slaughtering Process 3-13
Table 3-2: General Meat Processing 3-16
Table 3-3: Specialized Meat Processing 3-19
Table 3-4: Rendering Process 3-21
Table 3-5: General Facilities Operation 3-22
Table 4-1: Significance Spreadsheet 4-10
Table 4-2: Sample Form for Identification and Significance Determination of
Environmental Aspects 4-13
Table 4-3: Comparing Objectives and Targets - Some Examples 4-14
Table 7-1: Documentation of Records 7-9
Table 7-2: Record Control 7-9
Appendix A - Workshop Materials
Cover Sheet
Workshop Training for Module 1: Getting Started
Workshop Training for Module 2: Get Ready
Workshop Case Studies for Module 2
Workshop Training for Module 3: Identifying Environmental Aspects and Impacts
Workshop Training for Module 4: Determining Significant Environmental Aspects
and Setting Objectives and Targets
Workshop Training for Module 5: Environmental Management Programs (EMPs)
Workshop Training for Module 6: Supporting EMS Elements
Workshop Training for Module 7: EMS Documentation and Records
Workshop Training for Module 8: Monitoring and Measurement and Corrective
and Preventive Action
Workshop Activities for Module 8
Workshop Training for Module 9: Continuous Improvement
Credits: Cover photo by Keith Weller, ARS/USDA
Page v of v
-------
Environmental
Management System
(EMS) Implementation
Guide for the
Meat Processing Industry
Module 1: Getting Started
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
Table of Contents
Introduction 1-2
Why Have an EMS? 1-2
Key Elements of an EMS 1-5
How Many Parts of an EMS Do We Already Have? 1-7
Implementation Planning 1-8
Who Should Do the Implementation? 1-9
Get Top Management Commitment 1-10
Other Issues to Keep in Mind 1-10
Documentation 1-11
Electronic or Paper Based Documentation 1-11
Homework 1-11
Attachment 1-A: EMS Checklist 1-12
Attachment 1-B: Environmental Requirements Checklist 1-17
Attachment 1-C: Sample Action Plan For EMS Implementation 1-22
Attachment 1-D: Layout Notes for EMS Procedures 1-26
Attachment 1-E: EMS Benefits 1-29
Attachment 1-F: Glossary of Terms 1-34
List of Figures
Figure 1-1: The "Plan, Do, Check, Act" Model 1-5
Figure 1-2: Key Elements of an EMS 1-6
Page 1-1 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
Introduction
An EMS is how your plant manages its environmental responsibilities. This Guide provides
overall building blocks for your plant to use in developing the EMS that best fits with your
plant's unique characteristics.
Module 1 of this Guide is about setting the cornerstones for successful EMS implementation.
The titles of the 10 modules of this Guide are:
• Module 1: Getting Started
• Module 2: Get Ready
• Module 3: Identifying Environmental Aspects and Impacts
• Module 4: Determining Significant Environmental Aspects and Setting Objectives
and Targets
• Module 5: Environmental Management Programs (EMPs)
• Module 6: Supporting EMS Elements
• Module 7: EMS Documentation and Records
• Module 8: Monitoring and Measurement and Corrective and Preventive Action
• Module 9: Continuous Improvement
• Module 10: Lessons Learned
Attachment 1-F provides a glossary of terms used in the modules.
Why Have an EMS?
Even if you are convinced that an EMS is good for your plant you may need to convince others.
The following points are designed to give you ammunition to accomplish that purpose.
An EMS is a systematic approach to achieve your environmental and other organizational
goals.
Does your plant need an EMS? Well, ask yourself the following questions:
• Would you like to improve your ability to comply with environmental laws and
regulations ?
• Are you looking for ways to improve your environmental performance?
• Is the state of your plant's environmental affairs a significant liability?
• Does a lack of time or resources prevent your plant from managing its environmental
obligations effectively?
• Is the relationship between your plant's environmental goals and other goals unclear?1
If you answered YES to one or more of the above questions, an EMS can help your plant.
1 NSF International, Environmental Management Systems: An Implementation Guide for Small and Medium-Sized
Organizations (Michigan: NSF International, January 2001) 4. Subsequent references to this document will be given
in parentheses in text.
Page 1-2 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
First, an effective EMS makes good sense. By helping to identify the causes of environmental
problems and then eliminate them, an EMS can help your plant save money.
Think of it this way:
• Is it better to make a product (or provide a service)
right the first time or to fix it later?
• Is it cheaper to prevent a spill in the first place or
to clean it up afterwards?
• Is it more cost-effective to prevent pollution or to
manage it after it has been generated? (4)
Second, an EMS can be an investment in the long-term
viability of your plant. An EMS can help your plant to be
more effective in achieving environmental goals. And, by
helping businesses keep existing customers and attract new
ones, an EMS adds value. (5)
Here's some good news. Much of what your plant needs for an EMS may already be in place!
The management system framework described in this Guide includes many elements that are
common to managing many organizational processes, such as quality, health & safety,
finance, or human resources. (5) Existing management processes such as Hazard Analysis and
Critical Control Point (HACCP) have similar elements as an EMS and therefore provide
opportunities for efficiency. As you review this Guide, you will probably find that your plant has
many EMS processes in place, even though they may have been designed for other purposes.
Integrating environmental management with other key organizational processes can improve
financial, quality, and environmental performance. (5)
The key to effective environmental management is the use of a systematic approach to
planning, controlling, measuring and improving your plant's environmental performance.
Significant environmental improvements (and cost savings) can be achieved by assessing and
improving your plant's management processes. Many environmental "problems" can be solved
without installing expensive pollution control equipment. (5)
Of course, there is some work involved in planning, implementing and maintaining an EMS. But
many organizations have found that the development of an EMS can be a vehicle for positive
change. In addition, many organizations have seen that the benefits of an EMS far outweigh the
potential costs. (5)
In Total Quality Management (TQM) and Quality Management System (QMS) systems thinking,
it is said that "quality is free" — as long as you are willing to make the investments that will let
you reap the rewards. The same holds true for environmental management. (5)
Key EMS Benefits
• improved environmental
performance
• reduced liability
• competitive advantage
• improved compliance
• reduced costs
• fewer accidents
• employee involvement
• improved public image
• enhanced customer trust
• more favorable credit terms
• meet customer requirements (4)
Page 1-3 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
Frequently Asked Questions About EMS
1. We already have a compliance program - why do we need an EMS?
An EMS can help your plant comply with regulations more consistently and effectively. It also
can help your plant identify and capitalize on environmental opportunities that go beyond
compliance.
2. How detailed do we need to be in creating our plant's EMS?
When working your way through the process of creating your plant's EMS, strive for simplicity.
There is no point in creating an overly burdensome management system that your plant cannot
sustain.
Hint: Start simple and if you find over time as a part of your continuous improvement process
that your plant needs to add more detail your plant will be adding value where it makes sense.
In general it is much easier and more cost effective to add detail than to remove it.
3. How big does an organization need to be to successfully implement an EMS?
EMS' have been implemented by organizations ranging in size from a dozen employees to many
thousands of employees. The elements of an EMS (as described in this Guide) are flexible by
design to accommodate a wide range of organizational types and sizes.
4. Will an EMS help us prevent pollution ?
A commitment to preventing pollution is a cornerstone of an effective EMS and should be
reflected in your plant's policy, objectives and other EMS elements.
5. Do we have to start from scratch to implement an EMS?
Much of what your plant has in place now for environmental management and other programs
such as health and safety should be incorporated into the EMS. There is no need to "start over".
6. How will an EMS affect my existing compliance obligations?
An EMS will not result in more or less stringent legal compliance obligations. However an EMS
should improve your plant's ability to comply with legal obligations, and, in some cases, may
lead to more flexible compliance requirements.
7. Do we need to be in 100% compliance in order to have an EMS?
No. The concept of continual improvement assumes that no organization is perfect. While an
EMS should help your plant improve compliance and other measures of performance, this does
not mean that problems will never occur. However, an effective EMS should help your plant
find and fix these problems and prevent their recurrence. (6)
Page 1-4 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
Attachment 1-E is an example slide presentation that reviews benefits of an EMS and why and
EMS may be good for your plant. These are provided as working materials for your use in
preparing internal presentations for your plant staff and management.
If you are charged with "selling" the EMS at your plant focus on the benefits as they relate to the
audience. Typically senior management is concerned with business rationale points, while mid-
level management are concerned with efficiency and making sure that day to day operations run
a smoothly as possible. Be sure to explain why an EMS will improve your plant's operations.
What is an EMS?
An effective EMS is built on TQM and QMS concepts. To improve environmental management,
your plant needs to focus not only on what things happen but also why they happen. Over time,
the systematic identification and correction of system deficiencies leads to better environmental
(and overall organizational) performance. (8)
Most EMS models are built on the "Plan, Do, Check, Act" model introduced by Shewart and
Deming; see Figure 1-1. This model endorses the concept of continual improvement.
In the EMS model described in this Guide, the "Plan, Do, Check, Act" steps have been expanded
into 17 elements that are linked together. (8) These 17 elements are the basis of most EMS
standards, including ISO 14001, the EMS standard created by the International Organization for
Standardization.
Key Elements of an EMS
What does an EMS consist of? How are the elements linked together?
This section describes 17 EMS elements that are common to most EMS models. This section
also notes the key linkages among these elements; see Figure 1-2. (14) While there are several
good EMS models available, they are all based on the general "Plan, Do, Check, Act" cycle.
Figure 1-1: The "Plan, Do, Check, Act" Model
(8)
Page 1-5 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
Figure 1-2: Key Elements of an EMS
Management
Review
Checking I
Corrective Action
Monitoring & Measurement
Nonconformance & Corrective &
Preventive Action
• Records
• EMS Audits
Continual
Improvement!
Environmental
Policy
Planning
Environmental Aspects
Legal & Other Requirements
' Objectives & Targets
Environmental Management,
Program
Implementation
• Structure & Responsibili
Training, Awareness, Competent
• Communication
• EMS Documentation
• Document Control
• Operational Control
' Emergency Preparedness^
Response
Key Elements of an EMS: A Snapshot
Environmental policy — Develop a statement of your plant's commitment to the
environment. Use this policy as a framework for planning and action. The policy is a
direct reflection of the fundamental values of your organization.
Environmental aspects — Identify environmental attributes of your products, activities
and services. Determine those that could have significant impacts on the environment.
Legal and other requirements — Identify and ensure access to relevant laws and
regulations, as well as other requirements to which your plant adheres.
Objectives and targets — Establish environmental goals for your plant, in line with your
policy, environmental impacts, the views of interested parties, and other factors.
Environmental management program — Plan actions necessary to achieve your
objectives and targets.
Page 1-6 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
Structure and responsibility — Establish roles and responsibilities for environmental
management and provide appropriate resources.
Training, awareness and competence — Ensure that your plant's employees are trained
and capable of carrying out their environmental responsibilities.
Communication — Establish processes for internal and external communications on
environmental management issues.
EMS documentation — Maintain information on your plant's EMS and related
documents.
Document control — Ensure effective management of procedures and other system
documents.
Operational control— Identify, plan and manage your plant's operations and activities
in line with your plant's policy, objectives and targets.
Emergency preparedness and response — Identify potential emergencies and develop
procedures for preventing and responding to them.
Monitoring and measurement — Monitor key activities and track performance.
Conduct periodic assessments of compliance with legal requirements.
Nonconformance and corrective and preventive action — Identify and correct
problems and prevent their recurrence.
Records — Maintain and manage records of EMS performance.
EMS audit — Periodically verify that your plant's EMS is operating as intended.
Management review — Periodically review your plant's EMS with an eye to continual
improvement. (15)
How Many Parts of an EMS Do We Already Have?
Knowing what parts of the system your plant already has in place will help you to understand the
building blocks you will need to add.
Your plant may have many parts of an EMS already in place. An EMS implementation program
starts with identifying where the gaps are between your plant's existing approaches to dealing
with environmental issues and a fully functional EMS. This process of assessing the state of your
plant's existing environmental program(s) relative to a set of criteria is called a Gap Assessment.
Once the gaps are identified, a plan and approach for filling in the gaps can be formulated.
At the end of this module a checklist is provided that can be used to gauge the current state of
your plant's approach to environmental affairs. The checklist is based on the series of Key EMS
Page 1-7 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
Implementation Activities described later in this module. Use the checklist not only to identify
gaps now, but also to gauge your plant's progress over time in implementing its EMS (see
Attachment 1-A). Many of the terms in the checklist may be unfamiliar to you now, but you will
understand them better as you go through the EMS implementation process.
One way to answer the questions in the checklist is to answer yes or no. If you want a more
detailed assessment of how well you are doing apply a score to each question.
If scores are used and added up for each EMS element, a more accurate indication of your status
can be developed. To do this you may find using an electronic spreadsheet an easy way to track
how you are doing and to re-calculate the score over time.
After you have conducted a Gap Assessment for your plant, develop an Action Plan to tackle the
Gaps you have identified.
An Action Plan should identify:
• The people and other resources you estimate will be required;
• The time lines for the various steps of the plan; and
• Responsibilities for the various steps.
Hint: Remember, simple is good. The outline in this 10 module Guide is designed to provide you
with detail on how any firm (large or small, and from a simple or singular process to a complex
series of operations) in the meat processing sector can build a robust and sustainable EMS. It is
important to have a practical approach to filling the gaps identified by the checklist. Make sure
to customize the EMS for your plant.
Implementation Planning
Attachment 1-C provides an example of a step-by-step project plan for an EMS implementation.
In this module we introduce EMS planning. Modules 2 to 5 of this Guide provide detail on the
Plan part of EMS within the "Plan, Do, Check, Act" context.
The series of implementation tasks (see Attachment 1-C), once finalized, will have resource
requirements and time lines assigned. This should be a collaborative effort between the EMS
project team, external assistance, (if any is being used) and senior plant management. Consider
using commercial tools to organize your plan. For example, if your plant already uses a project
management tool, then examine if it will work for this project. Once the schedule has been set,
using either project tracking software or in a paper-based format, lay out the various tasks that
should be conducted by the project team(s) with guidance, periodic checking, and input from
senior management.
Focus the implementation plan on improving the ways in which jour plant manages its effects on
the environment. Do this by working within the existing management system(s). Trying to
change your overall management structure should not be the goal of the EMS.
Page 1-8 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
Sample Key Implementation Activities are noted in the table below. In addition, the development
of an EMS can also be described in general by the series of tasks provided in Attachment 1-C.
The exact series of activities depends on your plant. When defining the series of steps for your
plant do not expect to follow the exact series of steps in these examples. Rather it is
recommended that you follow the Plan-Do-Check-Act sequence and customize the details to fit
your situation.
Key EMS Implementation Activities, A Possible Sequence
Action
1. Define and approve implementation plan and schedule
2. Appoint implementation representatives
3. Formally establish and identify members of implementation team(s)
4. Define appropriate scope of EMS
5. Develop matrix of significant aspects and impacts
6. Identify legal and other requirements for all activities
7. Establish environmental objectives and targets and develop management programs
8. Develop documented operational control procedures
9. Develop monitoring and measurement procedures
10. Establish internal and external communications procedures
11. Develop emergency preparedness and response procedures
12. Implement corrective and preventative action program
13. Perform EMS audit and conduct management review
Who Should Do the Implementation?
In order for your plant to implement an EMS you need to be able to "talk-the-talk" and "walk-
the-walk". In other words do more than just read an EMS manual or guidance. The first step is a
get acquainted process. If you or your plant staff have no formal training in EMS then consider:
• Getting some formal training on what an EMS is and is not; or
• Obtaining outside help to guide your plant through the process. The best outside help
would be from a sister firm or your trade association. Of course they should also have
actual experience in implementing an EMS.
Consultants and assistance providers can certainly help you, but implementing an EMS is going
to be something that requires a real commitment from one or more key staff, and a smaller
commitment from many staff in your plant. The amount of help you get with implementing your
EMS is a function of how familiar you are with EMS and how much staff time your plant can
allocate to implementation. A word of caution, an EMS is first and foremost a systematic
approach that involves many parts of your plant. An EMS is not something one staff member can
do, nor can you just hire a consultant to come and build your plant an EMS and then hand it over.
Page 1-9 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
Get Top Management Commitment
It is essential for your plant to have top management support and endorsement of the EMS.
Applying TQM / QMS principles to the environmental area and providing adequate resources are
the job of top management.
To initiate and sustain the EMS effort, top management must communicate to all employees the
importance of:
• Making the environment an organizational priority (think of effective environmental
management as fundamental to the plant's survival);
• Integrating environmental management throughout the organization (think about the
environment as part of product/service and process development and delivery, among
other activities); and
• Looking at problems as opportunities (identify problems, determining root causes, and
preventing problem recurrence).
Note: It is virtually impossible to underestimate the value of an open and "public" display of top
management support for an EMS.
Other Issues to Keep in Mind
Focus on Continual Improvement
No plant is perfect. The concept of continual improvement recognizes that problems will occur.
A committed plant learns from its mistakes and prevents similar problems from recurring. (9)
Flexibility
An effective EMS must be dynamic to allow your plant to adapt to a quickly changing
environment. For this reason, you should keep your plant's EMS flexible and simple. This also
helps make your plant's EMS understandable for the people who must implement it — your
plant's managers and other employees. (9)
Compatibility with Organizational Culture
The EMS approach and an organization's culture should be compatible. For some organizations,
this involves a choice: 1) tailoring the EMS to the culture, or 2) changing the culture to be
compatible with the EMS approach. Bear in mind that changing an organization's culture can be
a long-term process. Keeping this compatibility issue in mind will help you ensure that the EMS
meets your plant's needs. (9)
Employee Awareness and Involvement
As you design and implement an EMS, roadblocks may be encountered. Some people may view
an EMS as bureaucracy or extra expense. There also may be resistance to change or fear of new
responsibilities. To overcome potential roadblocks, make sure that everyone understands why
Page 1-10 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
the plant needs an effective EMS, what their role is and how an EMS will help to control
environmental impacts in a cost-effective manner. Employee involvement helps to demonstrate
the plant's commitment to the environment and helps to ensure that the EMS is realistic,
practical and adds value. (9)
Building an EMS (with the help of this Guide) provides an opportunity to assess how your plant
manages environmental obligations and to find better (and more cost-effective) solutions. While
you will probably identify some areas where you can improve, this does not mean that you
should change things that are working well! By reviewing what your plant does and how well it
works, you can ensure that your EMS will be viable and effective, both now and in the future. (9)
D OCUMENTATION
Module 7 of this guide includes a detailed discussion on effective EMS documentation. One of
the key types of EMS documentation that your plant will need to generate is procedures.
Attachment 1-D provides some general notes about organization of procedural documents for
you to consider. Your plant does not have to make a final format selection for EMS
documentation at this time unless your plant has a specific format it already uses to document
standard practices. However, you should begin to consider what format would work best for
your plant. As you proceed through EMS implementation you will, in some cases, be
formalizing practices already in place or, in other cases, developing methods. Trying to write
down exactly how you will do something before you do it is not always possible or desirable.
Therefore, it is acceptable to do a "back of the envelope" or mental only "first cut" at many of
your plant's new or improved processes and then shortly thereafter write it down. The process of
"writing it down" in plain language will not only help you to remember what worked and what
did not work, but will also guide others in the future.
Electronic or Paper Based Documentation
While a paper-based system for housing your documentation and records is acceptable, some
companies find electronic systems more advantageous. Electronic systems vary from just using
a common file directory for documents to commercial products that provide a framework to
house all EMS documents, records and procedures while providing a structure to organize the
elements of an EMS. The larger or more complex the company or plant the more likely an
electronic documentation management system will prove to be useful.
Homework
Conduct a Gap Assessment using the Checklist in Attachment 1-A and then develop a draft
action plan (it will be a living document) for implementing an EMS at your plant. Confirm that
you have top management endorsement of the EMS and get their buy in to the general
implementation process. Find out if your plant has an Environmental Policy, Guiding Principles
or Mission Statement and if so: who wrote it; when was it last reviewed; and does your plant
actually use it in its business decision making processes.
Page 1-11 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
Attachment 1-A: EMS Checklist
These questions are designed to allow you to identify specific gaps between where your current
system is and a fully implemented EMS. The questions in the checklist include statements that,
if satisfied, meet the requirements for a functional EMS. The checklist also includes questions
that indicate a well developed and sustainable EMS. An EMS that satisfies the requirements of
standards such as ISO 14001 will typically satisfy most if not all of the requirements of this
checklist. However, this checklist is not designed to determine if an EMS meets the requirements
of any one particular standard, but rather provide a comprehensive list of EMS criteria against
which to gauge your plant's EMS as implementation progresses. In order to satisfy all the criteria
in this checklist a plant will need to have a robust, fully developed, implemented and
continuously improved (has gone through at least one full "Plan, Do, Check, Act" cycle) EMS in
place. Think of the content of this checklist as the high bar against which you can gauge your
plant's EMS.
This checklist satisfies the standard EMS requirements of EPA's National Environmental
Performance Track Program (PT). It does not examine performance and other related reporting
requirements of PT. For more information on PT go to: http://www.epa.gov/performancetrack.
There are two suggested evaluation approaches to use with this checklist.
Method A: Simplified
A checkmark S in a box signifies that the evidence of conformance with the associated
requirement has been observed and verified. An X in a box signifies that the associated
requirement does not appear to be satisfied or that evidence of the requirement having been
satisfied was not present or available.
Method B: Scored Level of Completeness
A numerical score is placed in each box to signify the degree to which the EMS is completed.
Suggested scoring is as follows:
• 0 - not initiated
• 1 - under development
• 2 - developed/documented
• 3 - deployed
• 4 - assessed/verified/improved
Only a score of 4 signifies that that requirement of the EMS is complete and that evidence of the
requirement having been satisfied is present or available. You may find that placing these
questions in an electronic spreadsheet program allows for greater ease in adding up scores and
tracking of progress over time.
It is the responsibility of the user of this checklist to utilize due care and good judgement as an
auditor to ensure that each requirement has been met or not met and where prudent retain
evidence.
Page 1-12 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
Environmental Management System (EMS) Requirements
(a) Policy
The plant has a written environmental policy, defined by top management, and committing to:
Compliance with both:
D legal requirements and
D voluntary commitments.
D Pollution prevention (based on a pollution prevention hierarchy where source
reduction is the first choice).
D Continuous improvement in environmental performance, including areas not subject
to regulations.
D Sharing information on performance of the EMS with the community.
(b) Planning
D The plant has a process for identifying its aspects and determining their significance.
D The plant has identified its significant aspects.
D The plant has identified all EPA permits and ID numbers.
D The plant has a process for identifying its legal requirements.
D The plant has identified its legal requirements, i.e., the plant has identified its environmental
requirements in accordance with the attached application checklist (see Attachment 1-B).
D The plant has procedures for integrating anticipated changes to the plant's requirements or
commitments into the EMS.
The plant has established measurable objectives and targets:
To meet:
D policy commitments and
D legal requirements,
D To reduce its impacts associated with its significant environmental aspects, and
D To meet performance commitments made by the plant.
Page 1-13 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
The plant has active, documented programs to achieve the objectives, targets and commitments
in the EMS, including the following to ensure completion:
D The means, and
D The timeframes.
(c) Implementation and Operation
D The plant has identified a top management representative with authority and responsibility
for the EMS.
D The plant has established roles, responsibilities, and dedicated the required resources for
meeting its objectives and targets of the overall EMS.
D The plant has established roles and responsibilities for compliance with legal requirements.
The plant has defined procedures for:
D Achieving and maintaining compliance,
D Meeting performance objectives,
D Communicating relevant information regarding the EMS, including the plant's
environmental performance, throughout the organization,
D Providing appropriate incentives for personnel to meet the EMS requirements, and
D Document control, including where documents related to the EMS will be located
and who will maintain them.
D The plant has established a public outreach program.
D The plant has a designated point of contact with direct access to plant management.
The plant has described its activities / plans / procedures in the following areas:
D Identifying and responding to questions or concerns of local residents.
D Informing community members of important matters that affect them.
The plant is able to:
D List any current or ongoing citizen concerns with the plant.
Page 1-14 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
The plant has defined its training needs and has environmental training programs for:
D All employees,
D Specific training for those whose jobs and responsibilities involve activities directly
related to achieving objectives and targets, and
D Specific training for those whose jobs and responsibilities involve activities directly
related to compliance with legal requirements.
The plant has documented key EMS elements including:
D The environmental policy,
D Significant environmental aspects,
D Objectives and targets,
D Identification of a top management representative,
D An EMS audit program, and
D Overall EMS authority.
D The plant retains EMS documentation.
D The plant has operation and maintenance programs for equipment and for other operations
that are related to legal compliance.
D The plant has operation and maintenance programs for equipment and for other operations
that are related to other significant environmental aspects.
D The plant has an emergency preparedness program.
(d) Checking and Corrective Action
The plant has active program(s) for:
D Assessing performance,
D Detecting non-conformance with legal and other requirements of the EMS,
D Preventing non-conformance with legal and other requirements of the EMS,
D Prompt corrective action of any non-conformance with legal and other requirements
of the EMS, and
D Conducting EMS audits.
Page 1-15 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
(e) Management Review
The plant has a process for, conducts, and documents management reviews covering:
D Performance with regard to the objectives and targets,
D The effectiveness of the EMS in meeting policy commitments.
Page 1-16 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
Attachment 1-B: Environmental Requirements Checklist
The Checklist is given to help facilities identify the major federal, state, tribal, and local
environmental requirements applicable at their facilities. The Checklist is not intended to be an
exhaustive list of all environmental requirements that may be applicable at an individual plant.
Air Pollution Regulations Check All
That Apply
1. National Emission Standards for Hazardous Air Pollutants (40 CFR 61) ~
2. Permits and Registration of Air Pollution Sources ~
3. General Emission Standards, Prohibitions and Restrictions ~
4. Control of Incinerators ~
5. Process Industry Emission Standards ~
6. Control of Fuel Burning Equipment ~
7. Control of VOCs ~
8. Sampling, Testing and Reporting ~
9. Visible Emissions Standards ~
10. Control of Fugitive Dust ~
11. Toxic Air Pollutants Control ~
12. Vehicle Emissions Inspections and Testing ~
Other Federal, State, Tribal or Local Air Pollution Regulations Not Listed Above
(identify)
!3- ~
14- ~
Hazardous Waste Management Regulations
1. Identification and Listing of Hazardous Waste (40 CFR 261)
- Characteristic Waste ~
- Listed Waste ~
2. Standards Applicable to Generators of Hazardous Waste (40 CFR 262)
- Generator status identification ~
- Manifesting
- Pre-transport requirements ~
- Record keeping/reporting ~
3. Standards Applicable to Transporters of Hazardous Waste (40 CFR 263)
- Transfer plant requirements ~
- Manifest system and record-keeping ~
Page 1-17 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
- Hazardous waste discharges ~
4. Standards for Owners and Operators of TSD Facilities (40 CFR 264)
- General facility standards ~
- Preparedness and prevention ~
- Contingency plan and emergency procedures ~
- Manifest system, record keeping and reporting ~
- Groundwater protection ~
- Financial requirements ~
- Use and management of containers ~
- Tanks ~
- Waste piles ~
- Land treatment ~
- Incinerators ~
5. Interim Status Standards for TSD Owners and Operators (40 CFR 265) ~
6. Interim Standards for Owners and Operators of New Hazardous Waste Land ~
Disposal Facilities (40 CFR 267)
7. Administered Permit Program (Part B) (40 CFR 270) ~
Other Federal, State, Tribal or Local Hazardous Waste Management Regulations Not
Listed Above (identify)
8- ~
9- ~
Hazardous Materials Management
1. Control of Pollution by Oil and Hazardous Substances (33 CFR 153) ~
2. Designation of Reportable Quantities and Notification of Hazardous ~
Materials Spill (40 CFR 302)
3. Hazardous Materials Transportation Regulations (49 CFR 172-173) ~
4. Worker Right-to-Know Regulations (29 CFR 1910.1200) ~
5. Community Right-to-Know Regulations (40 CFR 350-372) ~
Other Federal, State, Tribal or Local Hazardous Materials Management Regulations
Not Listed Above (identify)
6- ~
7- ~
Page 1-18 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
Solid Waste Management
1. Criteria for Classification of Solid Waste Disposal Facilities and Practices ~
(40 CFR257)
2. Permit Requirements for Solid Waste Disposal Facilities ~
3. Installation of Systems of Refuse Disposal ~
4. Solid Waste Storage and Removal Requirements ~
5. Disposal Requirements for Special Wastes ~
Other Federal, State, Tribal or Local Solid Waste Management Regulations Not
Listed Above (identify)
6- ~
7- ~
Water Pollution Control Requirements
1. Oil Spill Prevention Control and Countermeasures (SPCC) (40 CFR 112) ~
2. Designation of Hazardous Substances (40 CFR 116) ~
3. Determination of Reportable Quantities for Hazardous Substances (40 CFR ~
117)
4. NPDES Permit Requirements (40 CFR 122) ~
5. Toxic Pollutant Effluent Standards (40 CFR 129) ~
6. General Pretreatment Regulations for Existing and New Sources (40 CFR ~
403)
7. Meat Products Point Source Category Effluent Guidelines and Standards (40 ~
CFR 432)
8. Water Quality Standards ~
9. Effluent Limitations for Direct Dischargers ~
10. Permit Monitoring/Reporting Requirements ~
11. Classifications and Certifications of Operators and Superintendents of ~
Industrial Wastewater Plants
12. Collection, Handling, Processing of Sewage Sludge ~
13. Oil Discharge Containment, Control and Cleanup ~
14. Standards Applicable to Indirect Discharges (Pretreatment) ~
Other Federal, State, Tribal or Local Water Pollution Control Regulations Not Listed
Above (identify)
!5- ~
16- ~
Page 1-19 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
Drinking Water Regulations
1. Underground Injection and Control Regulations, Criteria and Standards (40 ~
CFR 144, 146)
2. National Primary Drinking Water Standards (40 CFR 141) ~
3. Community Water Systems, Monitoring and Reporting Requirements (40 ~
CFR 141)
4. Permit Requirements for Appropriation/Use of Water from Surface or q
Subsurface Sources
5. Underground Injection Control Requirements ~
6. Monitoring, Reporting and Record keeping Requirements for Community q
Water Systems
Other Federal, State, Tribal or Local Drinking Water Regulations Not Listed Above
(identify)
7- ~
8- ~
Toxic Substances
1. Manufacture and Import of Chemicals, Record keeping and Reporting ~
Requirements (40 CFR 704)
2. Import and Export of Chemicals (40 CFR 707) ~
3. Chemical Substances Inventory Reporting Requirements (40 CFR 710) ~
4. Chemical Information Rules (40 CFR 712) ~
5. Health and Safety Data Reporting (40 CFR 716) ~
6. Pre-Manufacture Notifications (40 CFR 720) ~
7. PCB Distribution Use, Storage and Disposal (40 CFR 761) ~
8. Asbestos (40 CFR 61 and 29 CFR 1910) ~
9. Lead (40 CFR 141 and 29 CFR 1910) ~
10. Regulations on Use of Fully Halogenated Chlorofluoroalkanes (40 CFR 762) ~
11. Storage and Disposal of Waste Material Containing TCDD (40 CFR 775) ~
Other Federal, State, Tribal or Local Toxic Substances Regulations Not Listed Above
(identify)
12- ~
!3- ~
Page 1-20 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
Pesticide Regulations
1. FIFRA Pesticide Use Classification (40 CFR 162) ~
2. Procedures for Disposal and Storage of Pesticides and Containers (40 CFR ~
165)
3. Certification of Pesticide Applications (40 CFR 171) ~
4. Pesticide Licensing Requirements ~
5. Labeling of Pesticides (40 CFR 156) ~
6. Pesticide Sales, Permits, Records, Application and Disposal Requirements ~
7. Disposal of Pesticide Containers ~
8. Restricted Use and Prohibited Pesticides ~
Other Federal, State, Tribal or Local Pesticides Regulations Not Listed Above
(identify)
9- ~
10- ~
Environmental Clean-Up, Restoration, Corrective Action
1. Comprehensive Environmental Response, Compensation and Liability Act
(Superfund) (identify section)
~
~
2. RCRA Corrective Action (identify section) ~
~
~
Other Federal, State, Tribal or Local Environmental Clean-Up, Restoration,
Corrective Action Regulations Not Listed Above (identify)
3- ~
4- ~
Page 1-21 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
Attachment 1-C: Sample Action Plan For EMS Implementation
Implementation Tasks
Project Initiation
Review
Page 1-22 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
Implementation Tasks
EMS Planning
EMS
Implementation
Page 1-23 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
Implementation Tasks
EMS Implementation
(Continued)
Task 18
Designate and Formalize Roles &
Responsibilities
Page 1-24 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
Implementation Tasks
Checking and
Corrective Action
Review and Take Corrective Action
Task 26
Compliance Audit
t
Task 27
t
Task 28
Conduct Internal EMS Audit
Management
Review
Task 29
Review and Take Corrective Action
After Internal Audit
Task 30
Perform First Management Review of
EMS
Page 1-25 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
Attachment 1-D: Layout Notes for EMS Procedures
When writing EMS procedures it is often a good idea to have a standardized format. The result
of having a standardized format is that there is a certain level of recognition associated with the
procedures. The suggested layout below should first serve as content guide. When developing
your plant's procedural format, use one that will cause a minimum of disruption in your plant.
Format is entirely at the user's discretion.
Each plant should decide where it needs to have documented and formalized procedures and
where it does not. As a general rule of thumb, if your plant has determined that without a written
procedure there is an unacceptable risk of the activities being conducted incorrectly then a
written procedure is a good idea. The procedure examples provided in the sections and
appendices of this document provide a detailed level of documentation. Some plants may find
that a less in depth level of documentation is sufficient.
This example includes building blocks for an Environmental Aspects Procedure.
Note: Using dates for revision and version numbers helps in the process of document control and
ensuring that users have the correct procedure in hand.
ABC Meat Processing Environmental Policy
Reference to the section (s) of the Policy that are most relevant to this section
Environm en tal A spects
Note: Since ABC Meat Processing is using ISO 14001 as the model for its EMS, it is using the
content of the standard as a reference against which it can cross-reference specific procedures.
The organization shall establish and maintain (a) procedures(s) to identify the environmental
aspects of its activities, products or services that it can control and over which it can be expected
to have an influence, in order to determine those which have or can have significant impacts on
the environment. The organization shall ensure that the aspects relate to these significant
impacts are considered in setting its environmental objectives.
ABC Meat Processing
ENVIRONMENTAL MANAGEMENT SYSTEM MANUAL
Ref.ISO 14001:96 4.3.1
Title: Environmental Aspects
Section: # 0.0
Version 1.1
Issue Date: 00-00-00 Revise by 00-00-00
Page 1-26 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
I. Purpose
Needed here is a short description of the purpose for this section and what is to be included in
this section. This description may serve as a quick reference to describe the contents of the
section.
II. Scope
The scope briefly describes to what areas of the business does this procedure apply. Any
exceptions may be noted here.
III. Definitions
Any terms which require explanation, would be defined here. It is important to define any
necessary terms near the start of the section so that the reader is introduced to these terms and is
made aware of their meaning. A reference is usually provided for any given definition.
IV. Responsibility
This section is needed to identify specific personnel within the organization which have some
responsibility in developing, executing the related procedure and making sure it is kept up-to-
date. Those personnel responsible are normally listed in a "top-down" format beginning with
those positions of "upper management" down to those at an operational level. If certain
environmental programs assume some responsibility for tasks related to the procedure, they
would also be listed and described here. This listing is necessary to clarify any discrepancies
regarding responsibilities but may also serve as a reference for any personnel requiring
additional assistance related to the procedure. Noting responsibilities in procedures is one way
to ensure that responsibility and authority are understood and this serves as a building block for
an overall summary of responsibilities associated with the EMS.
V. Core Content
This section would commonly be broken down into a series of logical steps. Where applicable,
the use of charts and flow diagrams would be used to represent a step of the procedure. A
sequential listing of activities to be completed as part of this procedure can serve to simplify the
process by breaking down a rather complex topic into manageable units.
For the Aspects Procedure the following series of steps might be used
Step 1 - Identify Activities, Products and Services
Step 2 - Identify Environmental Aspects
Step 3 - Identify Associated Environmental Impacts
Step 4 - Grouping of Aspects
Page 1-27 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
VI. Review and Updating
This section sets out the need for periodic review of the procedure. Included in this section will
be a general schedule for the review of certain tasks and will include in some cases the personnel
responsible. Review and updating of procedures is necessary in order to comply with changing
activities, products, and services of the organization.
VII. References
A list of references is needed for the appropriate documentation of information used in the
section. References also serve as a resource that the reader may use if they require any additional
information.
The reference section is also a place to identify other EMS procedures that affect the activities
within this procedure and other areas of the EMS that are linked to this procedure.
Example References for Aspects:
Legal and Other Requirements (needed for determining significance)
Objectives and Targets (uses results of aspect identification and significance process)
Emergency Preparedness and Response (potential emergencies lead to impacts)
Structure and Responsibility (who executes this procedure and provides input)
Page 1-28 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
Attachment 1-E: EMS Benefits
What an EMS Can Do
• Instead of the government setting the environmental
management agenda through compliance, the company
sets the agenda.
• Provides a systematic and logic based approach to
managing environmental issues.
• Provides assurance that policies, objectives, and targets
are being managed.
• Provides a structure to recognize what compliance
requirements are and the process to ensure they are met.
What an EMS Can Do
• Contributes to improved environmental and business
performance. A systematic approach to identifying and
responding to environmental issues allows an
organization to better understand and integrate
environmental issues with existing business practice.
• Lessens the enforcement burden. Demonstrating a
proactive approach to understanding and managing
environmental issues helps to understand what is
needed and to lessen the level of concern.
• Helps to qualify a company for EPA's Performance
Track.
Page 1-29 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
WHY EMS
• Looking at the overall problem can help.
• Some companies have found that it costs more to run a
compliance centered system than an EMS.
• Reduce incidents of pollution and associated expense of
recovery.
- One spill costs more than a lot of prevention.
- Proper design of a lagoon costs less than cleanup of a
less expensive lagoon.
WHY EMS
• Recycling manufacturing waste and unused inputs could
increase revenues.
- Think of everything that leaves the main process. For
example, how to use water more than once?
• Employee health and safety can be improved, thereby
improving productivity, decreasing sick days, and reducing
insurable risk.
• Insurance claims may be reduced, thus reducing the costs
of coverage and settlements.
Page 1-30 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
WHY EMS
• The environmental staff can help employees and
management understand and use environmental systems to
improve organizational performance.
• A management system can lead to a more reliable and
predictable outcome for environmental performance,
which can reduce or limit the severity of incidents.
WHY EMS
• An EMS provides feedback on the operations of the
organization that can be used for daily action and to
determine the appropriateness of pollution prevention
strategies.
• Problems that could be expensive to resolve and damaging
to the environment can be identified earlier. Management
awareness of problems would offer the best opportunity for
efficient resolution.
Page 1-31 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
WHY EMS
• A unified approach to environmental management
provides the opportunity for sharing ideas among facilities
and a potential increase in efficiency and benefits.
• Spreading environmental responsibility throughout the
organization places responsibility with those directly
associated with environmental impacts and pollution
prevention. This improves the effectiveness and efficiency
of environmental programs.
• Community support for a facility could be increased by
demonstrating concern for the local environment through
an EMS.
WHY EMS
• Workers may be attracted to a company with a plan to
protect the work environment and the surrounding
community.
• When environmental issues are prioritized based on a
rational process, the organization can focus where "the best
bang for the buck" exists.
• Energy efficiency and other process gains can go hand in
hand with environmental improvement when planned and
executed in a systematic way.
Page 1-32 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
Summary
• An EMS is an extension of general good proactive
business management to the environmental arena.
• An EMS assists your organization in understanding how it
influences the environment.
• Having an EMS makes good business sense.
- Drive performance and set your priorities rather than
react.
- Finding savings opportunities and avoiding costs.
Page 1-33 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
Attachment 1-F: Glossary of Terms
alternatives evaluation - A systematic evaluation of alternative ways to accomplish a task that
reviews the cost, performance, and environmental impact of each alternative under consideration.
Ideally, the range of evaluation would include alternative chemicals, products, processes,
technology, work procedures, and disposal methods.
aspect, environmental - Element of an organization's activities, products, and services that can
interact with the environment.
assessment - An estimate or determination of the significance, importance, or value of
something.
certification - Procedure by which a third party gives written assurance that a product, process,
or service conforms to specified requirements.
compliance - An affirmative indication or judgment that the supplier of a product or service has
met the requirements of the relevant specifications, contract, or regulation; also the state of
meeting the requirements.
continual improvement - Process of enhancing the environmental management system to
achieve improvements in overall environmental performance, in line with the organization's
environmental policy. Note - The process need not take place in all areas of activity
simultaneously.
corrective action - An action taken to eliminate the causes of an existing nonconformity, defect,
or other undesirable situation in order to prevent recurrence.
critical control point (CCP)- A point, step or procedure in a food process at which control can
be applied and, as a result, a food safety hazard can be prevented, eliminated, or reduced to
acceptable levels.
critical limit - The maximum or minimum value to which a physical, biological, or chemical
hazard must be controlled at a critical point to prevent, eliminate, or reduce to an acceptable level
the occurrence of the identified food safety hazard.
effects - Refers to changes, actual or potential, caused by a chemical, activity, or process as it
comes into contact with humans or the environment.
environment - Surroundings in which an organization operates, including air, water, land,
natural resources, flora, fauna, humans, and their interrelation.
environmental assessment - A systematic, documented, periodic and objective review by
company management of plant operations and practices related to meeting environmental
requirements. The assessment is a systematic, documented verification process of objectively
obtaining and evaluating evidence to determine whether specified environmental activities,
Page 1-34 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
events, conditions, management systems, or information about these matters conform with
selected criteria, and communicating the results of this process to management.
environmental management system (EMS) - The part of the overall management system that
includes organizational structure, planning activities, responsibilities, practices, procedures,
processes and resources for developing, implementing, achieving, reviewing and maintaining the
environmental policy.
environmental objective - Overall environmental goal, arising from the environmental policy,
that an organization sets itself to achieve, and that is quantified where practicable.
environmental performance - The measurable results of the environmental management
system, related to an organization's control of its environmental aspects, based on its
environmental policy, objectives, and targets.
environmental performance evaluation - Process to measure, analyze, assess, report, and
communicate an organization's environmental performance against criteria set by management.
environmental performance indicator - A specific datum selected, such as volume of a
chemical used, which will provide measurable information regarding progress toward meeting a
specific environmental goal.
environmental policy - Statement by the organization of its intentions and principles in relation
to its overall environmental performance, which provides a framework for action and for the
setting of its environmental objectives and targets.
environmental target - Detailed performance requirement, quantified wherever 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.
function - Performance characteristic.
HACCP (Hazard Analysis and Critical Control Point) System - Is a scientific system for
process control that has long been used in food production to prevent problems by applying
controls at points in a food production process where hazards could be controlled, reduced or
eliminated.
hazard - The ability to cause damage.
impact, environmental - Any change to the environment, whether adverse or beneficial, wholly
or partially resulting from an organization's activities, products, or services.
inputs and outputs - Material or energy that crosses a unit process boundary. Example —
Materials may include raw materials, products, emissions, and waste.
Page 1-35 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
interested party - Individual or group concerned with or affected by the environmental
performance of an organization.
life cycle - Consecutive and inter-linked stages of a product system, from raw material
acquisition or generation of natural resources to the final disposal.
life-cycle assessment (LCA) - Compilation and evaluation, according to a systematic set of
procedures, of the inputs and outputs of materials and energy and the potential environmental
impacts of a product system throughout its life cycle.
life-cycle characterization - Element of the life-cycle impact assessment phase in which the
potential impacts associated with the inventory data in each of the selected categories are
analyzed.
media - The means or substance through which something is transmitted, e.g., air, water, or soil.
objective, environmental - Overall environmental goal, arising from the environmental policy,
that an organization sets itself to achieve, and that is quantified where practicable.
prevention of pollution - Use of processes, practices, materials, or products that avoid, reduce,
or control pollution, which may include recycling, treatment, process changes, control
mechanisms, efficient use of resources, and materials substitutions.
procedure - A specified way to perform an activity.
process - A set of interrelated resources and activities that transform inputs into outputs,
product - Any good or service.
risk - This is the probability that something undesirable will happen from exposure to a hazard.
risk assessment - Risk assessment is the process of gathering data and making assumptions to
estimate short- and long-term harmful effects on human health or the environment from exposure
to hazards associated with the use of a particular product or technology.
root cause - A fundamental deficiency that results in a nonconformance and must be corrected to
prevent recurrence of the same or similar nonconformance.
stakeholders - Those groups and organizations having an interest or stake in a plant's EMS
program (e.g., regulators, shareholders, customers, suppliers, special interest groups, residents,
competitors, investors, bankers, media, lawyers, insurance companies, trade groups, unions,
ecosystems, cultural heritage, and geology).
substitutes - A chemical, product, process, or technology, which may be substituted for another
to perform the same function or achieve the same end result.
Page 1-36 of 37
-------
EMS Implementation Guide for the Meat Processing Industry
Module 1: Getting Started
target, environmental - Detailed performance requirement, quantified wherever 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.
total quality management (TQM) - A structured system of organizational change that aims to
satisfy internal customers, external customers, and suppliers by integrating business,
environment, maintenance, and continuous improvement considerations.
volatile - Ability to evaporate easily.
waste - Any output from the product system that is disposed of.
Page 1-37 of 37
-------
Environmental
Management System
(EMS) Implementation
Guide for the
Meat Processing Industry
Module 2: Get Ready
-------
EMS Implementation Guide for the Meat Processing Industry
Module 2: Get Ready
Table of Contents
Introduction 2-2
EMS Scope 2-4
Commitment 2-5
Project Champion 2-5
Core Team 2-5
Continual Improvement 2-11
Homework 2-12
Attachment 2-A: Additional Sources of Information and Contacts 2-13
Attachment 2-B: Gantt Chart for EMS Implementation 2-20
List of Figures
Figure 2-1: Initial EMS Planning Steps 2-3
Figure 2-2: Pollution Prevention Hierarchy 2-11
Page 2-1 of 22
-------
EMS Implementation Guide for the Meat Processing Industry
Module 2: Get Ready
Introduction
Building an EMS might sound like an overwhelming task for an organization, but it need not be.
Since time and other resources are limited in any organization, it is important that your plant use
its resources wisely. One way to do this is by preparing and following a simple, effective plan.
Fortunately, your plant can build on the experiences of other organizations that have
already implemented an EMS. Another thing to keep in mind is to strive for simplicity. This
means keep plans at a level that your plant is capable of executing during your initial
implementation and build an EMS that your plant has the resources to sustain over the long term.
It is easier to add more detail to your plant's EMS as a part of continuous improvement
than is to remove detail once it is in place.
Figure 2-1 illustrates the initial steps in the EMS planning process. The importance of careful
planning cannot be overemphasized. Taking the time to figure out what you need to do, how
you will do it, and who must be involved will pay big dividends down the road.
Experience shows that using a team approach to planning and building an EMS is an excellent
way to promote commitment and ensure that your objectives, procedures, and other system
elements are realistic, achievable, and cost-effective. Ideas for using a team and involving
employees are discussed in this section.1
Hints: Keep these points in mind as you build your plant's EMS:
• Help is available — don't hesitate to use it. (See Attachment 2-A for information on
resources).
• Pace yourself. Move quickly enough that employees stay interested and engaged, but not so
fast that those involved are overloaded, or that the effort becomes superficial.
• Don't re-invent the wheel -- existing management practices should help your plant to meet
EMS requirements. (10) In the Meat Processing Sector use and adapt parts you feel work for
your plant from existing Hazardous Analysis and Critical Control Point (HACCP) systems.
• Consultants and assistance providers can help you evaluate your plant's existing EMS
components and suggest approaches used successfully elsewhere. Explore ways to hold
consulting costs down. You may be able to join forces with other plants to hire a consultant
or sponsor a training course. (10)
1 NSF International, Environmental Management Systems: An Implementation Guide for Small and Medium-Sized
Organizations (Michigan: NSF International, January 2001) 10. Subsequent references to this document will be
given in parentheses in text.
Page 2-2 of 22
-------
EMS Implementation Guide for the Meat Processing Industry
Module 2: Get Ready
Figure 2-1: Initial EMS Planning Steps
Note: While displayed as a linear set of events, often many of these events affect each other and
happen simultaneously.
1
Define Organization's Goals
Secure
Management
Commitment
Select
EMS
Champion
Build
Core
Team
Define
EMS
Scope
Evaluate
Gap
Assessment
Detailed
Project
Plan,
Schedule
Secure I
Initiate
Monitor &
Resources, —~
Employee —~
Communicate
Assistance
Involvement
Progress
(ii)
Page 2-3 of 22
-------
EMS Implementation Guide for the Meat Processing Industry
Module 2: Get Ready
A first step in EMS planning is to decide why you are pursuing the development of an EMS.
Are you trying to improve your environmental performance (for example, compliance with
regulations or prevent pollution)? Are you trying to promote involvement throughout the plant?
Write your goals down and refer back to them frequently as you move forward. As you design
and implement the EMS, ask: "How is this task going to help us achieve our goals?" This also is
a good time to define the scope of the EMS. (12)
EMS Scope
You will need to define the scope of the EMS.
The scope should be defined by:
• Identifying what it is that your plant actually does (does it operate offices, a waste water
treatment facility, are there trucks, shipping and receiving, how many buildings, and how
much property is there to operate and maintain?);
• Drawing boundaries around the plant and its components; and
• Considering practical constraints and timing.
Defining the scope helps to set the tone for the entire EMS. When defining the scope include
those areas that the management can control and over which it can be expected to have an
influence. This is often called management control.
Management control includes:
• Authority to determine how the environmental policy is implemented;
• Authority to allocate appropriate resources;
• Clearly defined boundaries for inputs to and outputs of the plant's activities;
• Interfaces with services not completely within the scope of the EMS (e.g., a common
effluent treatment plant); and
• The scope of environmental licenses, permits or approvals.
As part of defining the scope of the EMS, the plant should draw boundary conditions defining
what i controls. The boundary conditions can be simple and include the plant and associated
activities, products and services or they can be more complex and include such things as:
• Transportation to and from the site;
• Post consumer disposal;
• Purchasing of resources; and
• The life cycle of the product.
Temporary sites such as construction sites should be covered if the EMS of the plant has
management control over them. A plant should not omit from its scope activities that it has
management control over.
Page 2-4 of 22
-------
EMS Implementation Guide for the Meat Processing Industry
Module 2: Get Ready
Hint: Some organizations find that for the initial development of their EMS it is most effective to
limit the scope to any activities that occur within their physical property limits or that occur as a
direct result of those operations on adjacent sites. In subsequent EMS cycles they can consider
expanding their scope to include their supply chain (e.g., contract farmers), product lifecycle, and
other key associated organizations such as rendering facilities and the local POTW.
Commitment
As shown in Figure 2-1, one of the most critical steps in the planning process is gaining top
management's commitment to support EMS development and implementation. As discussed
in Module 1, management must first understand the benefits of an EMS and what it will take to
put an EMS in place. Explain to top management the strengths and limitations of your plant's
current approach and how those limitations can affect the plant's financial and other
performance. Management also has a role in ensuring that the goals for the EMS are clear and
consistent with other organizational goals. Management's commitment should be communicated
across the organization. (12)
Project Champion
Not all organizations have the luxury of choosing among multiple candidates, but your choice of
project champion is critical. The champion should have the necessary authority, an
understanding of the plant, and project management skills. The champion should be a "systems
thinker" (ISO 9000 or HACCP experience can be a plus, but is not necessary), should have the
time to commit to the EMS-building process, and must have top management support. (12) The
project champion serves as a leader for the EMS within your plant. Often in smaller
organizations, this champion, among their many duties, is also the EMS representative.
Core Team
Consider developing an EMS Core Team to provide guidance for the implementation project.
Your Core Team should include representatives from key management functions, such as
engineering, finance, human resources, production and/or service. Consider including
contractors, suppliers or other external parties as part of the core team, where appropriate. Also
consider those employees who have shown an interest in environmental performance and/or
those employees who have time to learn and act. A cross-functional team can help to ensure that
procedures are practical and effective, and can build commitment to and "ownership" of the
EMS. (12)
The team's purpose is to define the scope of the EMS and ensure that all major internal interests
are considered in the EMS development process. The Core Team should also provide greater
access to management in each functional area as the project progresses and act as a sounding
board for ideas as the project progresses.
Once the team has been selected, hold a kick-off meeting to discuss the plant's objectives in
implementing an EMS, the steps that need to be taken initially, and the roles of team members
among other topics. If possible, get top management to describe its commitment to the EMS at
this meeting. The kick-off meeting also is a good opportunity to provide some EMS training for
Page 2-5 of 22
-------
EMS Implementation Guide for the Meat Processing Industry
Module 2: Get Ready
team members. The team will need to meet regularly, especially in the early stages of the project.
Communicate progress of meetings to all employees. (12-13)
Continue to Define and Refine Your Project Plan and Schedule
Based on a review of the results of the gap assessment and using the initial draft action plan
conducted in Module 1, prepare a detailed project plan and budget. The team should develop
this detailed plan based on their understanding of the different business units of your plant. The
plan should describe in detail what key actions are needed, who will be responsible, what
resources are needed, and when the work will be completed. Keep the plan flexible, but set
some stretch goals. Think about how to maintain project focus and momentum over time. Look
for potential "early successes" that can help to build momentum and reinforce the benefits of the
EMS. (13)
The plan and budget should be reviewed and approved by top management. In some cases,
there may be outside funding or other types of assistance that you can use (trade association, a
state technical assistance office, etc.). (13) Attachment 1-C provides a simplified example of a
project plan and Attachment 2-B provides a graphic illustration of the sequence of events
involved in implementation. A detailed plan should include timelines, anticipated staffing and
funding requirements for each task. Expect the plan to evolve as the project proceeds.
Employee Involvement
An EMS is all about people and personal involvement in managing how an organization effects
the environment. Look for ways at all levels and throughout all stages of the EMS
implementation process to involve your staff. Employees are a great source of knowledge on
environmental, health and safety issues related to their work areas as well as on the effectiveness
of current processes and procedures. They can help the core team in drafting procedures.
Ownership of the EMS will be greatly enhanced by meaningful employee involvement in the
EMS development process. (13)
As you build the EMS, be sure to regularly monitor your progress against the project plan and
communicate this progress within the plant. Be sure to communicate the accomplishments that
have been made and describe what happens next. Build on small successes. Be sure to keep top
management informed and engaged, especially if additional resources might be required. (13)
Environmental Policy
An environmental policy is your declaration of commitment to the environment. This policy
provides a unifying vision of environmental principles that will guide the actions of employees
and management. Through it, top management should communicate goals such as preventing
pollution and minimizing risk to workers and the environment. This policy statement serves as
the framework for setting environmental objectives and targets, and will be brought to life in
your plans and business activities. Major environmental concerns can be addressed in your
plant's environmental policy statement.
Page 2-6 of 22
-------
EMS Implementation Guide for the Meat Processing Industry
Module 2: Get Ready
The policy statement should:
• Be a written statement of intent and values;
• Identify the main environmental issues and indicate how they will be managed;
• Present strategic objectives to attain the company's long-term environmental position;
• Highlight how your facility will monitor and improve environmental performance; and
• Reflect the scope.
Consider the Scope of Your EMS
A policy should be appropriate for the nature and scale of pur plant and should reflect your
plant's core values both on ethical level as well as a business performance level.
Draft Your Environmental Policy Statement In General Terms
Address your list of specific issues in general terms in your policy statement. For example, if
chemicals in your water or air are a concern because they potentially impact the community, you
could express a commitment to review and, where feasible, make changes in the chemicals used
by your plant, or make sure you are managing them appropriately. Or, if solid waste in landfills
is a concern in your area or to your plant, you could express a commitment to reduce the solid
waste your plant produces.
Next, think about how to put commitments into action. For example, your commitment to reduce
solid waste may be achieved through a pollution prevention program and/or a program to design
products or services that result in minimal waste generated by the consumer. Also, these
programs may be implemented one at a time over a several-year period, as part of your
commitment to continual improvement.
Going From Policy to Procedures
Written procedures are necessary when an unacceptable risk of the activity being done
incorrectly exists. When developing procedures, it is important to use a procedural format that
your facility is familiar with. Attachment 1-D provides layout notes for EMS procedures.
Procedures should:
• Reference the section of the policy that is most relevant;
• Use dates and/or version numbers to help with document control and ensure all have most
current versions;
• Clearly and concisely communicate who, what, when, where, and how;
• Provide continuity;
• Help identify areas for improvement; and
• Make transition easier.
Page 2-7 of 22
-------
EMS Implementation Guide for the Meat Processing Industry
Module 2: Get Ready
Hint: Your plant probably has some type of environmental policy now, even if it's not written
down. For example, your plant probably is committed to complying with the law and avoiding
major environmental problems, at a minimum. Document existing commitments and goals as a
starting point.
The policy should relate to your products and services, as well as supporting activities. Consider
the results of your EMS checklist (see Module 1) and your analysis of the environmental
aspects (Modules 3 and 4) of your products, services and activities before finalizing the policy.
These two steps can provide insight as to how your plant interacts with the environment and how
well it is meeting its challenges. For example, information obtained from completing the
checklist might help you define specific policy commitments.
Keep your policy simple and understandable. Ask yourself: What are we trying to achieve?
How can we best communicate this to the rest of the organization? One test to use: Could our
employees describe the intent of our policy in twenty words or less?
The environmental policy should be explicit enough to be audited If you choose to use
phrases such as "We are committed to excellence and leadership in protecting the environment",
consider how to demonstrate that such a commitment is being met.
The environmental policy can be a stand-alone document or it can be integrated with your
health & safety, quality, or other organizational policies.
Consider who should be involved in developing the policy and the best process for writing it.
Input from a range of people within your plant should increase commitment and ownership.
Make sure that your plant's employees understand the policy. Options for communicating your
policy internally include posting it around work sites (e.g., in lunchrooms), using paycheck
staffers, incorporating the policy into training classes and materials, and referring to the policy at
staff meetings. Test awareness and understanding from time to time by asking employees what
the policy means to them and how it affects their work.
The policy can also be communicated externally. Some options for external communications
include placing the policy on business cards, in newspaper advertisements and in annual reports,
among other options. You might choose to communicate the policy proactively, in response to
external requests (or both). This decision should be factored into your overall strategy for
external communication (see later discussion under "Communications").
Consider how you would demonstrate that you are living by the commitments laid out in the
policy. This is a good test of whether or not the policy is a "living document". (16-17)
It is important to think through which commitments your plant
will be capable of addressing. Do not include commitments in
your policy that the plant will not be able to carry out. The
following is a checklist of commitments or principles that you
may wish to consider including in your plant's policy statement:
Key Policy Commitments:
• Continual improvement
• Pollution prevention
• Compliance with
relevant laws and
regulations (16)
Page 2-8 of 22
-------
EMS Implementation Guide for the Meat Processing Industry
Module 2: Get Ready
• Comply with applicable environmental laws and regulations;
• Work to achieve pollution prevention;
• Prevent accidents;
• Identify opportunities for risk reduction associated with the processes and chemicals used
in your plant, the supplies procured, the products produced, and the disposal of waste
products;
• Consider the life cycle (from raw materials extraction and processing to use and eventual
disposal) of products produced, including packaging, so as to affect how suppliers and
end users impact the environment through your products;
• Continue improvement in your use of cleaner technologies and processes, and in the safer
use of chemicals;
• Practice wise resource management, including conservation of limited resources and
reuse and recycling of materials; and
• Consider which goals of industry or your trade association could be adopted for your
environmental policy statement.
Make sure top management commits to the environmental policy statement. If possible, the
company president or plant manager should sign and date it. The final environmental policy
statement should be posted or distributed to employees and other interested parties.
For EPA's Performance Track program, an organization's policy must include:
• Compliance with legal requirements and voluntary commitments;
• Pollution prevention;
• Continuous improvement in environmental performance, including areas not subject to
regulation; and
• Sharing information on environmental performance and their operation of the EMS with
the community. (17)
Sample Policy Commitments
ConAgra's Sustainable Development Commitment includes a commitment to pollution
prevention.
Our Environmental Commitment
At ConAgra Foods, sustainable development requires reductions in the generation of wastes and
pollutants, protection of clean air and water, sustainable protection of the land and the wise use
of energy....
Kraft Foods International's environmental principles include commitments to compliance and
continual improvement.
Page 2-9 of 22
-------
EMS Implementation Guide for the Meat Processing Industry
Module 2: Get Ready
Kraft Foods International is committed to these Environmental Principles.
To conduct operations in accordance with all applicable laws and regulations...
.. .To continually reevaluate these principles to ensure that they remain consistent with our policy
of minimizing the environmental impact of our activities and promoting the sustainability of the
natural resources upon which we depend.
Every plant will find its own way to express its values. The key points are that the policy /
principles / commitments are stated clearly and that management provides direction on how it
envisions these statements being put into practice. Deeds, not words, are what speak.
Compliance
Compliance with legal requirements is a critical consideration in EMS development and
implementation. EMS implementation requires a plant, among other things, to:
• Develop and communicate an environmental policy that includes a commitment to
compliance;
• Develop and implement a procedure to identify, analyze and have access to
environmental laws and regulations;
• Set objectives and targets in line with its environmental policy, which includes a
commitment to compliance;
• Establish management programs to achieve its objectives;
• Train employees and communicate relevant EMS requirements to them;
• Establish and implement operational control procedures;
• Establish and implement a procedure for periodically evaluating compliance; and
• Establish and implement a procedure to carry out corrective and preventive actions.
(18)
While the requirements noted above relate directly to a plant's management of legal
requirements, each of the EMS elements described in this Guide can contribute to enhanced
compliance (including communication, documentation and document control, records
management, EMS audits, and management review). An EMS that includes the elements
described in this Guide will help your plant improve or maintain its compliance performance and
facilitate the establishment of objectives and targets that go "beyond compliance." (18)
Pollution Prevention
EMS design and implementation also should take into account the Pollution Prevention (P2)
hierarchy (see Figure 2-2). In evaluating P2 opportunities, organizations should start at the top
of the pyramid (i.e., source reduction) and work their way down as needed to define the most
appropriate methods for preventing pollution. (18)
Page 2-10 of 22
-------
EMS Implementation Guide for the Meat Processing Industry
Module 2: Get Ready
Figure 2-2: Pollution Prevention Hierarchy
(18)
Continual Improvement
Continual improvement is the process of enhancing the environmental management system to
achieve improvements in overall environmental performance in line with the organization's
environmental policy. An EMS by design looks for ways and means to prioritize and improve.
While this does not mean that you must improve in all areas at once, the policy should drive your
plant's efforts to continually improve environmental management (and the improved
performance that results from these efforts). (16)
The following is a sample environmental policy statement that in some way incorporates most of
the principles listed above.
[YOUR COMPANY] (ABC Meat Processing)
ENVIRONMENTAL POLICY
[This is an example policy. Adapt portions if they are useful and applicable for your plant.]
ABC Meat Processing Company is committed to managing environmental matters as an integral part of
our business. In particular, it is our policy to assure the environmental 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 applicable laws and regulations and will implement programs and procedures to
assure compliance. Compliance with environmental regulations will be a key ingredient in the training,
performance reviews, and incentives of all employees.
RISK REDUCTION, PREVENTION, and RESOURCE MANAGEMENT
We will seek opportunities, beyond regulatory compliance requirements, for reducing risk to human
health and the environment, and we will establish and meet our own environmental quality standards
where appropriate.
Page 2-11 of 22
-------
EMS Implementation Guide for the Meat Processing Industry
Module 2: Get Ready
We will employ management systems and procedures specifically designed to prevent activities and / or
conditions that pose a threat to human health and the environment. We will look for ways to minimize
risk and protect our employees and the communities in which we operate by employing clean technology
and operating procedures, as well as being prepared for emergencies.
We will strive to minimize releases to the air, land, or water through use of cleaner technologies and the
safer use of chemicals. We will minimize the amount and toxicity of waste generated and will ensure the
safe treatment and disposal of waste.
We will manage scarce resources, such as water, energy, land, forests, in an environmentally sensitive
manner.
COMMUNICATION
We will communicate our commitment to environmental performance to our employees, vendors, and
customers. We will solicit their input in meeting our environmental goals and in turn will offer assistance
to meet their goals.
CONTINUOUS IMPROVEMENT
We will measure our progress as best we can. We will review our progress at least on an annual basis.
We will continuously seek opportunities to improve our adherence to these principles and to improving
our environmental performance, and we will periodically report progress to our stakeholders. (90)
{Signature} President Date
Homework
Who is your EMS representative and Core Team? Have the Core Team look at what the scope
of the EMS should be, justify it, and get senior management buy in to your approach. If your
plant has a policy or guiding principles, determine if it meets the recommended components. If
no policy exists create one and provide it to top management for their consideration.
Page 2-12 of 22
-------
EMS Implementation Guide for the Meat Processing Industry
Module 2: Get Ready
Attachment 2-A: Additional Sources of Information and Contacts
(189)
There are many resources available to help your plant develop and implement an EMS that are free of charge or relatively
inexpensive. The following is a description of some of these resources.
Note: As ISO 14001 is a popular EMS standard there are a number of resources, which have based their assistance offerings on this
standard. Also, this list is not intended to be comprehensive. Appearance on this list should not be construed as an endorsement of
any products/service.
i i di rai. \<;i:\( u s
Organization Resource
US Environmental
Protection Agency US EPA EMS Home Page
Small Business Compliance
Assistance Centers
Design for the Environment (DfE)
Guide, Fact Sheets and EMS
Template
Telephone Number / Internet Address
www.epa.gov/ems
http://www.epa.gov/compliance/assistance/cent
ers/index.html
http://www.epa.gov/opptintr/dfe/tools/iems.ht
m
Description
Information about EPA's efforts to develop
policies and related materials about
environmental management systems (EMS).
This site lists state programs for EMS and
nonprofit TAPS.
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.
Small Business Compliance Policy http://www.epa.gov/compliance/resources/poli Effective May 11, 2000, this policy
cies/incentives/smallbusiness/sbcomppolicv.pd supercedes the June 1996 version. Published
f in the Federal Register on April 11, 2000 (65
FR 19630).
Page 2-13 of 22
-------
EMS Implementation Guide for the Meat Processing Industry
Module 2: Get Ready
i i di uai. \<;i:\( u s
Compliance-Focused EMS -
Enforcement Agreement Guidance
http://www.epa.gov/compliance/resources/publ
ications/incentives/ems/ems 12elemr.pdf
Presents the key elements of a compliance
focused EMS model.
Environmental Compliance
Auditing Protocols
EPA National Service Center
1-800-490-9198 (for environmental
publications)
http://www.epa.gov/compliance/resources/poli
cies/incentives/auditing/
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.
Pollution Prevention Information
Clearinghouse (PPIC)
1-202-566-0799
http://www.epa.gov/opptintr/librarv/ppicindex.
htm
Technical Information on materials and
processes, including publications related to
waste minimization and pollution prevention.
Office of Wastewater Management http://www.epa.gov/QWM/
Public Information Center
http://www.epa.gov/epahome/pic.htm
Provides information on various
sponsored EMS projects.
EPA-
General information about EPA programs.
RCRA, Superfund & EPCRA
Hotline
1-800-424-9346
Provides information about hazardous waste
regulations and handles requests for federal
documents and laws.
Small Business and Asbestos
Ombudsman
http://www.epa.gov/sbo/whois.htm
1-800-368-5888
Information and advice on compliance issues
for small quantity generators of hazardous
waste.
Technology Transfer & Support
Division of EPA's Office of
Research and Development's
(ORD) National Risk Management
Research Laboratory (NRMRL)
http://www.epa.gov/ttbnrmrl/
1-513-569-7562
Access to the ORD research information and
publications.
TSCA Assistance Information
Service (TAIS)
1-202-554-1404
Assistance and guidance on TSCA
regulations.
Page 2-14 of 22
-------
EMS Implementation Guide for the Meat Processing Industry
Module 2: Get Ready
i i di uai. \<;i:\( u s
EnviroSenSe
http://es.epa.eov
Solvent alternatives, international, federal and
state programs, other research and
development. Also, environmental profiles of
various industrial categories.
US EPA Home Page
http://www.epa.gov
Information about EPA regulations,
initiatives, and links to the home pages of
other agencies and EPA regional offices.
U.S. Small Business SBA Answer Desk
Administration
1-800-8-ASK-SBA
Information about SBA programs, and
telephone numbers for local offices.
SBA Home Page
http://www.sbaonline.sba.gov
Information about business services available
to your organization, with links to other
related sites.
Government Printing GPO Superintendent of Documents 1-202-512-1800
Office
US Department of Pollution Prevention Information http://epic,er.doe.gov/epic/
Energy Clearinghouse
Information about available documents and
instructions on ordering GPO publications.
Pollution prevention and environmental
design information.
Page 2-15 of 22
-------
EMS Implementation Guide for the Meat Processing Industry
Module 2: Get Ready
STvri: \<;i:\( u s
Organization
State Environmental
Protection Agencies
Resource
Environmental Assistance
Programs
Small Business Assistance
Programs (Mandated under Title V
of the Federal Clean Air Act)
Telephone Number / Internet Address
Contact your state's Environmental Protection
Agency
Call the EPA Small Business Ombudsman (1-
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. Several states,
including Texas and Virginia have
established "EnviroMentor" programs
with their Small Business Assistance
offices, to help small companies comply
with regulations.
State and Local Pollution
Prevention Programs
Contact the National Pollution Prevention
Roundtable (1-202-299-9701;
http://www.p2.org/') for the phone number and
address of the pollution prevention program
in your state.
http ://www.epa.eov/opptintr/p2home/resource
sZstatep2.htm
Provides information and technical
assistance on pollution prevention.
Provides state-by-state information on
agencies and organizations offering
pollution prevention assistance.
Iowa Waste
Assistance
(WRAP)
Reduction
Program
Iowa Department of Natural
Resources
502 E. 9th Street
Des Moines, IA
50319-0034
Phone: 1-515-281-4367; Fax: 1-515-281-8895
http://www.state.ia.us/dnr/organiza/wmad/wm
abureau/pollution/wrap .html
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.
The WRAP is a non-regulatory,
voluntary initiative designed to assist in
source reduction and recycling for Iowa
businesses and public institutions.
Page 2-16 of 22
-------
EMS Implementation Guide for the Meat Processing Industry
Module 2: Get Ready
NOVPUOI IT OKCAM/.A I IONS
Organization
Address
Industrial Technology Institute (ITI) (also 2901 Hubbard Road
known as the Michigan Manufacturing P.O. Box 1485
Technology Center) Ann Arbor, Michigan
48106-1485
Manufacturing Extension Partnership (MEP)
Building 301, Room C121
National Institute of Standards and
Technology
Gaithersburg, Maryland 20899-0001
Iowa Waste Reduction Center
University of Northern Iowa
1005 Technology Parkway
Cedar Falls, IA
50613-6951
Page 2-17 of 22
Phone Number
Description
1-800-292-4484 Technical assistance to small and mid-
Fax: 1-734-451-4201 sized manufacturers. Energy,
environment, and manufacturing
assessments, as well as performance
benchmarking, and QS 9000 and ISO
14000 implementation assistance.
1-301-975-5020 Assists manufacturers with assessing
1-800-MEP-4MFG technological needs, and works to help
Fax: 1-301-963-6556 small manufacturers solve environmental
problems with cost-effective solutions.
1-319-273-8905 Helps small businesses comply with
1-800-422-3109 federal and state environmental
regulations, by incorporating on site
reviews, applied research, and hands-on
training into is free, confidential
assistance program.
-------
EMS Implementation Guide for the Meat Processing Industry
Module 2: Get Ready
IVU KM i KISOI K( I S
Resource
Internet Address
Description
American National Standards Institute (ANSI) Online
http://www.ansi.org
Contains information related to the
American National Standards
Institute, including meetings,
events, and standards information
databases.
Canadian Standards Association
Consortium on Green Design and Manufacturing (UC-Berkeley)
http://www.csa.ca/language/default.asp7thisUrl
=%2FDefault%2Easp
http://cgdm.berkelev.edu/
Industrial Technology Institute (ITI) (also known as the Michigan http://www.iti.org
Manufacturing Technology Center) Home Page
International Network for Environmental Management (INEM)
ISO 14000 Information Center
http: / / www. inem. or g/
http://www.isol4000.com
A center for information and
services related to ISO 9000 and
ISO 14000, maintained by the
Canadian Standards Association.
Environmental design
sustainable development.
and
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 standards.
ISO 14000 Integrated Solutions (ANSI/GETF)
http: / / www. gnet. or g
Will provide training,
conferencing, on-line information
services and publications on a fee
basis.
Page 2-18 of 22
-------
EMS Implementation Guide for the Meat Processing Industry
Module 2: Get Ready
IVU KM i KISOI K( I S
Resource Internet Address Description
Multi-State Working Group on Environmental Performance http://www.mswe.ore/ Describes the activities of this
group regarding EMS and ISO
14001.
Page 2-19 of 22
-------
EMS Implementation Guide for the Meat Processing Industry
Module 2: Get Ready
Attachment 2-B: Gantt Chart for EMS Implementation
Task Name
Jul
Aug
Sep
Oct
Nov
Dec
Jan
Feb
Mar
Apr
May
June
Designate EMS
Representative '
IHI 2 w
eeks
Develop an Initial Work ,
Plan
8 weeks
Establish Core EMS Team (
3 weeks
Provide Top Management
Briefing
m
weeks
Gain Management
Approval and Define
Scope of EMS
g 3 w<
;eks
Conduct Gap Analysis |
8 weeks
Identify Environmental
Aspects and Impacts
Review Environmental
Legislation and other
requirements
<
8 weeks
1
Define Significant Aspects
1
) 5 weeks
Get Approval for
Implementation
1
' 2 weeks
Provide Management and
Leadership Training
1
10 weeks
Establish Procedures
Format
^ 8 w
eeks
Intermittent
task
Page 2-20 of 22
-------
EMS Implementation Guide for the Meat Processing Industry
Module 2: Get Ready
Task Name
Jul
Aug
Sep
Oct
Nov
Dec
Jan
Feb
Mar
Apr
May
June
Develop Environmental
Objectives and Targets
4 weeks
Develop Environmental
Management Programs
4 weeks
Identify and Develop
Operational Controls /
Emergency Plans
4 weeks
Identify and Develop
Measuring and Monitoring
Programs
4 weeks
Develop Community
Outreach
44 weeks
Designate and Formalize
Roles and Responsibilities
24 weeks
Provide Internal Auditor
Training
5 weeks
Identify Communication
Requirements
44 weeks
36 weeks
Identify and Develop
Documents and Records
Required
Conduct Training Needs
Assessment
18 weeks
Provide Documentation
and Record Keeping
Training
2 weeks
Provide Employee
Implementation Training
22 weeks
Page 2-21 of 22
-------
EMS Implementation Guide for the Meat Processing Industry
Module 2: Get Ready
Task Name
Jul
Aug
Sep
Oct
Nov
Dec
Jan
Feb
Mar
Apr
May
June
Verification Test of
Emergency Response
Plans
H 5 wee
ks
Compliance Audit
mm 4
weeks
Review and Take
Corrective Action
Conduct Internal EMS
Audit
—
2 weeks
Review and Take
Corrective Action after
Internal Audit
___3 \
'eeks
Perform First Management
Review of EMS
20 weeks
6 weeks
Page 2-22 of 22
-------
This page intentionally left blank.
-------
Environmental
Management System
(EMS) Implementation
Guide for the
Meat Processing Industry
Module 3: Identifying Environmental
Aspects and Impacts
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Table of Contents
Introduction 3-2
Terminology 3-2
The Recommended Approach 3-3
Legal and Other Requirements 3-9
Homework 3-11
Attachment 3-A: Identifying Activities, Products, and Services, Environmental Aspects
and Impacts Associated with Meat Processing Operations 3-12
Attachment 3-B: Sample Template For Identifying Activities/Products/Services,
Environmental Aspects and Impacts and Legal/Other Requirements 3-40
Attachment 3-C: Identification of Environmental Aspects Procedure 3-41
Attachment 3-D: Identification of Legal Requirements 3-43
List of Figures
Figure 3-1: Relationship Between Activities, Products, and Services and Aspects and
Impacts 3-3
Figure 3-2: Assessment of Level of Control or Influence 3-7
Figure 3-3: Grouping of Aspects 3-8
Figure 3-4: The Relationship Between Aspects, Legal and Other Requirements, and
Significance 3-10
Figures 3-5 - 3-17: Process Flow Diagrams 3-27
List of Tables
Table 3-1: General Slaughtering Process 3-13
Table 3-2: General Meat Processing 3-16
Table 3-3: Specialized Meat Processing 3-19
Table 3-4: Rendering Process 3-21
Table 3-5: General Facilities Operation 3-22
Page 3-1 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Introduction
In order to control your plants environmental impacts, you must know what these impacts are
where these impacts come from. Stated another way, how does your plant (i.e., your plant's
products, services and activities) interact with the environment?1
Terminology
As an initial matter, it is important to understand the definition of aspect and impact.
An environmental aspect:
Refers to an element of a plant's activities, products or services that can have an impact or that
can with the environment. Interaction is often described as having a beneficial or adverse effect.
These interactions and the resulting effects may be continuous in nature, or periodic or only be
associated with special events such as emergencies.
An environmental impact:
Refers to any change in the environment whether adverse or beneficial, wholly or partially
resulting from a plant's activities, products or services.
Therefore, the aspect is the cause and the impact is the effect.
These definitions can be difficult to understand. A simple example will help.
A curing operation at a plant is an activity. The air emissions that result from the burning of
wood to cure or smoke the meat are the environmental aspect, since the air emissions interact
with the environment. One of the environmental impacts associated with (or caused by) that
operation is air pollution, e.g., the air pollution from emission of particulates (dust). In a sense,
an environmental aspect lies between an activity, product, or service and an impact. A plant's
"operations" drive the environmental aspects, which in turn drive the environmental impacts (see
Figure 3-1).
1 NSF International, Environmental Management Systems: An Implementation Guide for Small and Medium-Sized
Organizations (Michigan: NSF International, January 2001) 20. Subsequent references to this document will be
given in parentheses in text.
Page 3-2 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Figure 3-1: Relationship Between Activities, Products, and Services and Aspects and
Impacts
The Recommended Approach
A generalized approach to environmental aspect identification and evaluation involves the
following tasks:
• Define the scope within which the environmental aspects and impacts will be identified
i.e., the scope of your EMS (Module 2);
• Identify all activities, products, and services within the scope;
• Identify the environmental aspects associated with the activities, products, and services;
• Affirm that your plant's management has control and influence over aspects and
determine the significance of the aspects (Module 4), and prioritize them accordingly;
and
• Group the aspects according to some criteria to ensure that the number of aspects is
manageable.
Hint: It is important to not get overly detailed in the process of identifying your aspects and
impacts. Do this to a level appropriate for your business. Periodically step back as you
proceed through the aspect and impact identification process and ask yourself if you are thinking
about aspects at the level of detail that you would need if you were going to make a change now
or in the future on how you manage that aspect. For example, it is good to know that your
various cooling systems based on ammonia can result in emissions but there may be no need to
think of each system separately especially if they are all maintained by the same maintenance
team.
Activities, products, and services may have one or more environmental aspects associated with
them. Each aspect, in turn, may result in one or more environmental impacts (actual changes in
the environment). Tables 3-1 through 3-5 in Attachment 3-A present examples of activities,
products, and services that are commonly associated with meat processing operations and their
corresponding environmental aspects and impacts.
Note: The process tables are based on both core processes typically associated with the meat
processing sector and on general plant operations.
Page 3-3 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
In understanding environmental aspects and impacts, it helps to think about the processes in
which your plant generates products and services. Figures 3-5 through 3-17 in Attachment 3-A
present a number of process flow diagrams detailing the steps involved in production and
manufacturing of different meat products.
Note: Figures 3-5 to 3-17 were developed using figures from United States Department of
Agriculture (USDA) Guidebooks for the Preparation of Hazard Analysis and Critical Control
Point (HACCP) Plans. The use of process flow diagrams that have been developed
specifically for your plant is encouraged.
The tables and figures presented in Attachment 3-A can be used as a starting point in
determining actual environmental aspects and impacts for your plant according to the
recommended approach described below. Attachments 3-B and 3-C provide sample templates or
procedures, which may be used for the identification of environmental aspects and impacts.
The general steps involved in this procedure include the following:
Establish the boundaries within which the environmental aspects and impacts will be
identified.
This task should have been completed when you defined the scope of your EMS in Module 2.
The boundaries of your environmental aspect procedure must include all of the operations that
are included within the EMS scope. This may be an important first step, especially for plants
which are engaged in multiple activities, like slaughtering, specialized meat processing,
rendering or have their own water treatment and wastewater disposal operations.
Identify the activities, products and services specific to your plant. The tables and figures
given in Attachment 3-A identify general related activities, products and services for particular
areas of meat manufacturing and processing. Additional detail is provided below to help you
understand how these tables and figures relate to each other and how to use them.
In each of the tables, activities/products/services, and associated aspects and impacts have been
identified for particular areas of meat processing and manufacturing. Keep in mind however the
information presented in these tables is not a comprehensive listing of all
activities/products/services and aspects and impacts associated with meat processing and
manufacturing. These tables are for you to use as a starting point in beginning to think about
your own plant.
You will in fact use the lists in the tables and amend them to reflect the actual environmental
aspects and impacts identified for your plant. Be sure to bok at all activities, products and
services within the scope of your plant's EMS.
The process flow diagrams provided in Attachment 3-A are to assist you in identifying your
plant's environmental aspects and impacts. The following list is a "cross-walk" of the process
flow diagrams and topics covered in the tables.
Page 3-4 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Table
Table 3-1: General Slaughtering Process
Table 3-2: General Meat Processing
Table 3-3: Specialized Meat Processing
Table 3-4: Rendering Process
Table 3-5: General Facilities Operation
Process Flow Diagram
Figure 3-7, Figure 3-8, Figure 3-12
Figure 3-5, Figure 3-6, Figure 3-7, Figure 3-8,
Figure 3-9, Figure 3-10, Figure 3-11, Figure 3-12,
Figure 3-13, Figure 3-14, Figure 3-15, Figure 3-16,
Figure 3-17
Figure 3-14, Figure 3-15, Figure 3-16, Figure 3-17
Figure 3-7, Figure 3-8, Figure 3-12
No process flow diagrams
As a good starting point for this exercise, a general definition of what is meant by the term
"activities, products, services" is needed. This is given below.
"Activities, Products and Services" is a catchall phrase that was developed to capture all of the
"things" done at a facility or plant. When trying to identify activities, products or services you
may (and probably will) find issues that do not obviously fall into any of these three categories
(for the sake of simplicity just call these activities if you are not sure which label is the right
one). It is fairly common for an organization to identify aspects that are not activities it carries
out, nor products it manufactures, nor services that it conducts. The important thing is that you
have identified the aspect so that you can determine if there are any associated known or
potential environmental impacts that require consideration.
Identify aspects and associated impacts for each of the activities, products or services.
Examples of common aspects relating to specific activities/products/services have already been
given in the process tables in Attachment 3-A. Knowing these common environmental aspects,
you can determine which activities, products or services at your plant, have a specific aspect
associated with them.
For example, the aspect of generation of wastewater, you should identify all
activities/products/services that result in wastewater being generated and those which also
contribute to contaminant levels in the wastewater stream.
For each aspect identify all impacts and potential impacts. This means whether the impacts
happen continuously, once in a while or only on special occasions (Example: there is a process
upset).
Sources in which to identify aspects for your plant may include some of the following:
• Employees;
. HACCP;
• Process flow chart;
Page 3-5 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
• Process hazard analysis;
• Emission inventory / risk assessment;
• Safety and hazard reviews; and
• Compliance and pollution prevention audits.
Hint: At the end of this section you should have identified and developed a list of all activities,
products and services related to your plant and their associated aspects and impacts. A sample
template is given in Attachment 3-B to help you organize these. Keep in mind that if your plant
has not previously identified these, your list will not likely be 100%-complete or correct. Don't
be discouraged, rather think about applying a "90 / 10 rule". Get about 90 % of the way there
and realize that as you work on subsequent parts of your EMS you will identify other aspects and
impacts you had not originally thought of and add them into your EMS. As others in your plant
become more aware of the environment they may also identify additional aspects and impacts.
The following listing identifies a number of possible sources of useful information for
identifying and evaluating environmental impacts.
Data Sources for Identifying Environmental Aspects and Impacts
HACCP Hazard Analysis: The Hazard Analysis and Critical Control Point process for
identification of hazards requires detailed understanding of the process through the generation of
flow diagrams and the development of a detailed understanding of all associated materials flows.
Also the process of identification of hazards can be adapted and expanded for the purpose of
considering environmental aspects and impacts.
Process Hazard Analyses: Used to identify and assess potential impacts associated with
unplanned releases of hazardous materials. This methodology is commonly used in OSHA Process
Safety Management regulations. It 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 Figures 3-5 to 3-17): A process of identification of the various processes
that are the core functions of an organization. By mapping the processes in detail and in inflows
and outflows of materials, products and byproducts and noted. Your HACCP process maps will
provide you with an excellent starting point from which to identify related aspects and impacts.
Life Cycle Assessments: Used to assess full range of impacts from products, from raw material
procurement through product disposal. These methodologies are somewhat subjective and can
be resource intensive.
Risk Assessments: Used to assess potential health and/or environment risks typically associated
with chemical exposure. Varieties of qualitative and quantitative methodologies are commonly
used.
Page 3-6 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Project Safety / Hazard Reviews: Used to assess and mitigate potential safety hazards
associated with new or modified projects. This methodology typically does not focus on
environmental issues.
Emission Inventories: Used to quantify emissions of pollutants to the air. Some data may
already be available to the organization, based on EPCRA requirements and CAA Title V
permitting program.
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 plant operations. Does not usually examine off-site impacts.
Environmental Property Assessments: Used to assess potential environmental liabilities
associated with plant or business acquisitions or divestitures. Scope and level of detail is
variable. This does not assess impacts associated with products or services. (97)
Identify and assess environmental aspects that the organization can control and over which it
can have an influence (see Figure 3-2). An organization is not expected to manage issues
outside its sphere of influence or control. (20)
To identify and assess aspects that the plant can control, first determine if it is within the
"scope " of your EMS implementation. Then determine if your plant has "management control"
over it. If your plant does not have management control over it, determine the level of
"influence" you have over it. Determinations of "control" and 'Influence" will affect the
objectives you set in relation to a given aspect.
Figure 3-2: Assessment of Level of Control or Influence
The process of identifying and setting priorities among environmental aspects is one of the key
drivers of an EMS. Most organizations find the process of identifying aspects and impacts time
consuming if they have not previously developed the methodologies and expertise needed to
understand all of the environmental impacts associated with all facets of their operations.
Page 3-7 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Ensure that the number of aspects carried forward for further analysis is manageable. A
grouping scheme is commonly used to accomplish this. Grouping of aspects is conducted
before the determination of significance.
Hint: In keeping with the less complexity is better approach, use the figures in this guide and
your own detailed process diagrams as tools to ensure that you don't miss aspects and impacts
you were not previously considering in your existing environmental programs. At the same time
remember that you do not need to create a list that itemizes every impact associated with every
process step in those figures. The level of detail provided in this portion of this guide is in
case you need it, and is not designed to suggest that all plants should have this much detail.
The first level of organization of aspects should be the categories defined on a practical level for
your plant. Use categories that fit with the way your plant works. All aspects should be placed
in one of these categories, which can accommodate any number of individual aspects. Match the
categories with the way your plant is operated, and where possible, use terminology the majority
of staff are familiar with.
Examples (see Figure 3-3):
A plant that has different operating areas (killing floor, processing, and storage) might wish to
first categorize aspects along these lines so that when it comes time for programs they are
aligned with the operating areas. Or, where various trades perform work or job skill categories
aspects categorized by cleanup crew activities versus production may be appropriate.
Similar aspects arising from several distinct activities, products, or services should be grouped
into one aspect. In cases in which one existing system is used to manage impacts arising from a
number of aspects or functional areas yielding similar aspects, the aspects should be combined
into one group.
Figure 3-3: Grouping of Aspects
Page 3-8 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Be sure that when you group aspects, that you don't loose track of the areas where impacts
occur and the sources of the impacts.
If, for example, all hazardous wastes at the plant are collected and disposed of the same way then
these aspects should be combined into one group. Note: In this example, it is important to first
identify all of the sources of hazardous waste generation, so that when it comes time to manage
them, they are not missed. It is not advisable (or acceptable from an EMS perspective) to
assume that a just because such a program exists that it was designed to include all of the
hazardous waste streams.
Energy use is a good candidate for aspect grouping. It might be effective in some circumstances
to combine all the process steps having energy aspects, and develop a plant-wide strategy and
program for achieving improvement. Understand, however, that the energy aspect should be
ranked in each process step to determine its relative importance in that step. For example,
energy use in office work might be a different priority than energy use in a manufacturing step.
In addition, standards and procedures developed to reduce energy use would possibly be
different for each process step. Consequently, although you might achieve certain efficiencies
through a plant-wide effort, your actual environmental improvement will be attained through
objectives set for each process step.
General rule of thumb: A manageable list might include anywhere between 20 - 50 aspects. If
your list includes < 20 or > 50 aspects, you should re-evaluate your grouping scheme. More than
50 aspects are possible if you have a larger fully integrated plant with your own water treatment
and rendering operations.
Remember to keep it simple!
Legal and Other Requirements
Once you have identified your activities, products, and services and associated environmental
aspects and impacts, consider legal and other requirements related to these aspects and impacts.
By the end of this module you will have built onto the aspect and impact list you previously
created, by stating explicitly the legal and other requirements of each aspect and impact. It is
recommended that you first develop a listing of activities, products, services and environmental
aspects and impacts and then examine legal and other requirements related to these, rather than
first assessing your legal/other requirements and then coming up with a listing of environmental
aspects and impacts.
Legal requirements:
Do environmental rules of the legal jurisdiction(s) in which you operate apply to your plant's
activities, products and services, aspects and impacts?
Legal requirements include:
• Federal statues and regulations;
• State and local regulations;
• Standards in locations where your company sells products/services; and
Page 3-9 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
• Permit conditions.
Other requirements might include, for example:
• Company-specific codes, and
• Other industry codes or programs to which your plant voluntarily subscribes (e.g., AMI
or AAMP policies).
Your plant's EMS should include a procedure for identifying, having access to, and analyzing
applicable legal and other requirements. (25) Attachment 1-B in Module 1 of this guide provides
a good starting list of Federal requirements to consider. Attachment 3-D provides a sample
procedure for the identification of legal and other requirements. Figure 3-4 illustrates the
relationship between aspects, legal and other requirements, and significance.
Figure 3-4: The Relationship Between Aspects, Legal and Other Requirements, and
Significance
Your first step will be to obtain information about applicable laws and regulations, their
interpretation, and how they impact your operations. These tasks however can be very time-
consuming. Fortunately, there are many methods to obtain information, including:
• Information from corporate headquarters;
• 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 USE PA web site at http://www.epa.gov);
• Public libraries;
• Seminars and courses;
• Newsletters / magazines;
• Consultants and attorneys; and
• Customers, vendors and other companies. (25)
Page 3-10 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
In order to consult and analyze these requirements on a regular basis, you must either obtain a
physical copy of the requirements or have an alternative method to access them. Alternative
methods of access could include a subscription to an electronic service that sends you updated
regulatory information on a regular basis, Internet access, or any other method that allows such
consultation.
Once you have established the requirements that apply to your plant, your environmental
programs should identify what tasks need to be performed to ensure compliance with those
requirements.
There is a practical reason for such programs—the knowledge that a requirement exists is of
little use unless it is translated into a specific action that can be assigned to an individual to
accomplish.
Such Environmental Management Programs (EMPs) will be discussed further in Module 5.
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 plant) is an important but often overlooked step. (26). Communications
programs will be discussed at length in Module 6.
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. (26)
Homework
Your homework for this module will be to complete the aspects, impacts and legal and other
requirements analysis.
Once you have created your list of aspects and impacts and have identified associated legal and
other requirements, move on to Module 4.
Page 3-11 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Attachment 3-A: Identifying Activities, Products, and Services, Environmental
Aspects and Impacts Associated with Meat Processing Operations
Process flow diagrams and tables of aspects and impacts are provided in this Attachment to assist
you in identifying your plant's environmental aspects and impacts. The following list is a
"cross-walk" of the process flow diagrams and topics covered in the tables.
Table Process Flow Diagram
Table 3-1: General Slaughtering Process Figure 3-7, Figure 3-8, Figure 3-12
Table 3-2: General Meat Processing
Figure 3-5, Figure 3-6, Figure 3-7,
Figure 3-8, Figure 3-9, Figure 3-10,
Figure 3-11, Figure 3-12, Figure 3-13,
Figure 3-14, Figure 3-15, Figure 3-16, Figure 3-17
Table 3-3: Specialized Meat Processing Figure 3-14, Figure 3-15, Figure 3-16, Figure 3-17
Table 3-4: Rendering Process Figure 3-7, Figure 3-8, Figure 3-12
Table 3-5: General Facilities Operation No process flow diagrams
Page 3-12 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Table 3-1: General Slaughtering Process
(Related Process Flow Diagrams: See Figure 3-7, Figure 3-8, Figure 3-12)
Activity/Product/
Service
1 - Housing live animals
Aspect
Animal waste (manure)
generated
Odors generated
Water effluent generated
from daily washing of barn
facilities
Impact
If untreated and not properly handled, wastes from animals emitted into the
environment can cause widespread contamination of the air, surface water,
groundwater and land
For example, if mishandled, manure may contaminate water supplies with nitrogen,
phosphorus, inorganic salts, organic solids and microorganisms. If present in sufficient
quantities, Ihose contaminants can cause considerable problems. Phosphorus is one of
the most common and serious surface water contaminants causing eutrophication
Offensive odors can be emitted into the environment
Such odors can negatively impact human health and quality of life
Environmental hazards associated with water effluent high in BOD and
suspended solids
Excess water use could lead to depletion of a finite resource
Use of and disposal of water for washing can cause pollution and disruption of natural
systems
2 - Stunning/killing
Use of fuel/energy
Air pollutants generated
Energy used in the case of mechanical or electrical stunning
Carbon dioxide stunning operations may be sources of CO2 emissions
Carbon dioxide is the primary global warming gas
Global warming has multiple effects including not only extending the range of tropical
pests and diseases but increasing the likelihood of fires and severe weather events such
as storms, floods and drought
Page 3-13 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Animal waste (blood) produced The blood recovered is sent for edible or inedible rendering
The disposal of blood as sewage can drive up the Biological Oxygen Demand
In wastewater streams
Generation of animal-by product Three categories of animal waste materials are distinguished:
waste (a) High risk category, includes animal by-products presenting a risk related to
the presence of residues of prohibited substances used illegally or residues of
environmental contaminants. These materials must be completely disposed of as waste
by incineration or landfill
Impacts associated may include increased disposal to landfill sites
Landfill sites can pollute the air, surface, and groundwater, spoil the scenery and
represent an imminent risk to public health
Disposal from incineration can release toxins into the air and create ash that
requires disposal in hazardous waste landfills
(b) This category includes animal by-products presenting a risk related to
animal diseases or a risk or residues of veterinary drugs. These materials may
only be recycled (through rendering) for uses other than animal nutrition (ie: biogas,
composting, oleo chemical products, etc.)
(c) This category includes by-products derived from healthy animals (i.e animals
slaughtered for human consumption which passed the health inspection). Only by-
products belonging to this category can be used as feed materials following appropriate
rendering treatment.
Impacts associated with rendering plants may include harmful odors and air pollution
Airborne emissions from rendering plants may cause a variety of health issues
Harmful viruses and bacteria may not be fully eliminated in rendering and may be
transmitted into the environment
Waste generated from rendering plants if released into the environment can result in
negative environmental impacts
Page 3-14 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
3 - Carcass washing and Water effluent generated
rinsing
Environmental hazards associated with water effluent high in BOD, suspended
solids, fats and grease
Excess water use could lead to depletion of a finite resource
Use of and disposal of water for washing/rinsing can cause pollution and disruption of
natural systems
Page 3-15 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Table 3-2: General Meat Processing
(Related Process Flow Diagrams: See Figure 3-5, Figure 3-6, Figure 3-7, Figure 3-8, Figure 3-9,
Figure 3-10, Figure 3-11, Figure 3-12, Figure 3-13, Figure 3-14, Figure 3-15, Figure 3-16, Figure 3-17)
Activity/Product/ Aspect Impact
Service
1 - Packaging material use Use of resources in the
manufacture of products for
storage
Excess water use could lead to depletion of a finite supply of natural resources
Extraction and manufacturing of resources utilizing energy and generating flows
of waste at each stage of processing
Hidden impacts associated with the process of extraction, including soil erosion
and degradation
Generation of waste Increased disposal to landfill sites
from packaging
Landfill sites can pollute the air, surface, and groundwater, spoil the scenery and
represent an imminent risk to public health
Disposal from incineration can release toxins into the air and create ash that
requires disposal in hazardous waste landfills
2 - Preparing/processing
meat
Air exhaust and particulate
generated from processing
Generation of noise/
vibration
Pollutants emitted may include sulfur dioxide, nitrogen dioxide, carbon
monoxide
Harmful effects depend on their concentration and the duration of exposure to
the pollutant
Physical and chemical processes in an ecosystem may also suffer impacts
Impacts depend upon the magnitude and frequency of the noise and vibration
High levels/intensities can be detrimental to quality, reliability, safety and
performance in plant operations
Page 3-16 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Some associated health effects may range from noise-induced hearing loss to
high blood pressure
Generation of animal waste Animal by-products presenting a risk related to the presence of residues of
from processing toxic substances or environmental contaminants used in processing, can be
disposed of as waste by incineration or landfill
Landfill sites can pollute the air, surface, and groundwater, spoil the scenery
and represent an imminent risk to public health
Airborne emissions from landfills are known to contain ammonia, hydrogen
sulfide, VOCs, dust and endotoxins. These emissions cause health problems
including headaches, sore throats, diarrhea and burning eyes
Disposal from incineration can release toxins into the air and create ash that
requires disposal in hazardous waste landfills
Certain wastes are recycled at a rendering plant for production of tallow, grease
and high-protein meat and bone meal
Impacts associated with rendering plants may include harmful odors and air
pollution
Airborne emissions from rendering plants may cause a variety of health issues
Harmful viruses and bacteria may not be fully eliminated in rendering and may
be transmitted into the environment
Waste generated from rendering plants if released into the environment can result in
negative environmental impacts
3 - Storage meat (cold) Use of CFCs and HFCs as Emission of ozone-depleting substances (ODSs) such as CFCs into the
refrigerants atmosphere
Depletion of ozone will increase UVb radiation reaching the earth's surface with
adverse effects for humans, plants and animals
Page 3-17 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
ODSs will also have a global warming effect
Global warming can have multiple effects, not only extending the range of
tropical pests and diseases but increasing the likelihood of fires and severe
weather events such as storms, floods and droughts
HFCs contribute to global warming but have no ozone depleting potential
Use of (anhydrous) ammonia
as a refrigerant
Ammonia is a dangerous refrigerant if not properly handled.
Ammonia is primarily a respiratory toxicant that can cause lung irritation, and in
higher concentrations, death.
4 - Receiving and shipping Emissions of CO, NOx, VOCs and
meat particulates from vehicles
These pollutants collectively impact urban air quality
Air pollution from vehicles causes cancer and premature death in addition to
aggravating chronic respiratory illnesses such as asthma
Vehicles are a major source of carbon monoxide, the primary global-warming gas.
This pollution has multiple effects, not only extending the range of tropical pests
and diseases but increasing the likelihood of fires and severe weather events
such as storms, floods and drought
Pollutants may chemically react in the atmosphere to produce secondary
pollutants such as acid rain and ozone
Noise generation from vehicles Impacts depend upon the magnitude of the noise
Noise caused by traffic can endanger health and quality of life
The growth and spread of traffic have exacerbated the noise problem
Waste generated from road and These wastes may impact the environment by causing pollution of surface
traffic sources waters, groundwater and land
Consumption of huge quantities of gasoline leads to offshore oil spills,
expansion of offshore oil drilling, toxic leaks from underground storage tanks,
fallout from acid rain, and runoff from roads and highways
Page 3-18 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Activity/Product/
Service
Table 3-3: Specialized Meat Processing
(Related Process Flow Diagrams: See Figure 3-14, Figure 3-15, Figure 3-16, Figure 3-17)
Aspect
Impact
1 - Meat cooking
Air pollutants generated
Possible odor, and products of combustion.
2 - Meat smoking
Air pollutants generated
Odors generated
Use of resources (wood) to produce
Particulate matter (PM), carbon monoxide (CO), volatile organic compounds
(VOCs), polycyclic aromatic hydrocarbons (PAH), organic acids, acrolein,
acetaldehyde, formaldehyde, and nitrogen oxides are identified pollutants
Acetic acid has been identified as the most prevalent organic acid present in
smoke, followed by formic, propionic, butyric, and other acids
The emission is also dependent on the quantity of wood (or liquid smoke) used,
rather than the quantity of meat processed
Emissions can impact air quality and pose a risk to human health
Heating zones in smokehouses are a source of odor that includes VOCs
VOCs are considered an odor nuisance in residential areas in close proximity to
rendering plants
In the presence of sunlight, VOCs can react with nitrogen oxides to create ground level
ozone and photochemical smogs, which can in turn contribute to pollution of the
atmosphere
Some individual VOCs are believed to be a threat to human health. For example,
benzene is classified as carcinogenic (cancer-causing) to humans and hexane as a cause
of nervous system disorders
Excess use could lead to depletion of a finite supply of natural resources
Page 3-19 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
smoke
Extraction and manufacturing of resources utilizing energy and generating flows
of wastes at each stage of processing
Hidden impacts associated with the process of extraction, including soil erosion
and degradation
Residual additives used in curing processes in water generated during cleaning
steps and processing area wash downs resulting increased loading in wastewater
Salts are not removed by normal secondary treatment systems and therefore ability of
treatment works to meet surface water discharge criteria is limited
4 - Ingredient application Water effluent generated Residual additives contributing to wastewater treatment requirements
(spices, preservatives,
extenders, etc)
3 - Meat curing (using salt, Water effluent generated
sugar, sodium nitrite and
sodium nitrate)
Page 3-20 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Table 3-4: Rendering Process
(Related Process Flow Diagrams: See Figure 3-7, Figure 3-8, Figure 3-12)
Activity/Product/ Aspect Impact
Service
1 - Washing of receiving Water effluent generated Environmental hazards associated with water effluent high in BOD, suspended
area solids, fat and grease
Excess water use could lead to depletion of a finite natural resource
Untreated wastewater can cause pollution and disruption of natural systems
2 - Rendering processing Air pollutants generated Volatile organic compounds (VOCs) are the primary airpollutants emitted from
rendering operations
VOCs are considered an odor nuisance in residential areas in close proximity to
rendering plants
In the presence of sunlight, VOCs can react with nitrogen oxides to create ground level
ozone and photochemical smog, which can in turn contribute to pollution of the
atmosphere
Some individual VOCs are believed to be a threat to human health. For example,
benzene is classified as carcinogenic (cancer-causing) to humans and hexane as a cause
of nervous s ystem disorders
In addition, particulate matter is emitted from grinding and screening of the solids in
the rendering process
Odors emitted Offensive odors may be emitted into the environment
Such odors can negatively impact human health and quality of life
Page 3-21 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Table 3-5: General Facilities Operation
(No Related Process Flow Diagrams)
Activity/Product/ Aspect Impact
Service
1 - Fuel use/energy use Fuel/energy used in operations Increased consumption will deplete a finite supply of natural resources
Extraction and manufacturing of resources utilizes energy and generates
flows of waste at each stage of processing
Hidden impacts associated with the process of extraction of resources may include soil
erosion and degradation
Carbon dioxide, most of which results from fossil fuel combustion, causes about half of
global warming. The greenhouse effect of fossil-fuel-derived methane, nitrous oxide,
carbon monoxide, and the nitrogen oxides must also be considered
Global warming has multiple effects including not only extending the range of tropical
pests and diseases but increasing the likelihood of fires and severe weather events such
as storms, floods and drought
2 - Refrigeration/ Use of CFCs and HFCs as Emission of ozone depleting substances (ODSs) such as CFCs into the
air conditioning systems refrigerants atmosphere
Depletion of ozone will increase UVb radiation reaching the earth's surface with
adverse effects for humans, plants and animals
ODSs will also have a global warming effect
Global warming can have multiple effects, not only extending the range of
tropical pests and diseases but increasing the likelihood of fires and severe
weather events such as storms, floods and droughts
HFCs contribute to global warming but have no ozone depleting potential
Page 3-22 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Use of (anhydrous) ammonia
as a refrigerant
Ammonia is a dangerous refrigerant if not properly handled.
Ammonia is primarily a respiratory toxicant that can cause lung irritation, and in
higher concentrations, death
These pollutants collectively impact urban air quality
Air pollution from vehicles causes cancer and premature death in addition to
aggravating chronic respiratory illnesses such as asthma
Vehicles are a major source of carbon monoxide, the primary global-warming gasses
This pollution has multiple effects, not only extending the range of tropical pests
and diseases but increasing the likelihood of fires and severe weather events
such as storms, floods and drought
Pollutants may chemically react in the atmosphere to produce secondary
pollutants such as acid rain and ozone
Noise generation from vehicles Impacts depend upon the magnitude of the noise
Noise caused by traffic can endanger health and quality of life
The growth and spread of traffic have exacerbated the noise problem
Waste generated from road and These wastes may impact the environment by causing pollution of surface
traffic sources waters, groundwater and land
Consumption of huge quantities of gasoline leads to offshore oil spills,
expansion of offshore oil drilling, toxic leaks from underground storage tanks,
fallout from acid rain, and runoff from roads and highways
Road salt used in parking lots and access roads can cause localized elevation of Sodium
and Chloride concentration in soil and ground water an contribute to stressed vegetation
Road salt can also contribute to Chloride concentrations in waste water or storm water
runoff depending on sewer routing from parking areas.
3 - Shipping and receiving Emissions of CO, NOx, VOCs and
operations particulates from vehicles
Page 3-23 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
4 - Vehicle Maintenance Generation of Wastes Oils, lubricants and hazardous wastes generated vehicle fleet maintenance
See above list associated with shipping and receiving and apply to on-site
vehicles
5 - General lighting Use of fluorescent light bulbs There are environmental issues associated with the use and disposal of
fluorescent light bulbs
Spent light bulbs may contain hazardous waste. Most older fluorescent light
ballasts have small capacitors that contain high concentrations of PCBs. PCBs
are toxic chemicals which have a history of persistent and potential ecological
damage.
The mercury used in the light bulbs represents a small part of the total mercury
potentially entering the environment. While high amounts of mercury are obviously
toxic, there is debate over the health effects at lower levels.
6 - General trash Generation of solid waste Increased disposal to landfill sites
Landfill sites can pollute the air, surface, and groundwater, spoil the scenery and
represent an imminent risk to public health
Disposal from incineration can release toxins into the air and create ash that
requires disposal in hazardous waste landfills
7 - Maintenance of plant
grounds
Use and discharge of water for
ground maintenance
Use of fertilizers, pesticides and
herbicides in maintenance
operations
Impact may include excess water use and depletion of a finite resource
Modern use of water resources can cause pollution and disruption of natural
systems
Water effluent generated can be treated at a waste water treatment plant
There is a wealth of toxicological and environmental impact data for these
products
Page 3-24 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
The main chemicals contained in fertilizers are nitrogen and phosphorus.
These two chemicals can cause accelerated growth of aquatic plants leading to
oxygen depletion and large fish kills
Pesticides and herbicides contain toxic materials that pose environmental and
Human health risks. Humans, animals, aquatic organisms, and plants can be
severely threatened by these chemicals
Use of toxic substances for cleaning Hazardous wastes generated from cleaning agents may pollute soil, air,
surface water or groundwater
Pollution of soil may affect people who live on it, plants that put roots into it and
animals that move over it
Air may become contaminated by direct emission of hazardous wastes
Evaporation of toxic solvents from cleaning agents is a common problem
River and lake pollution, if it is toxic enough, may kill animal and plant life
Immediately, or it may injure slowly
Underground pollutants can be carried by underground water flow to
contaminate water supplies
Water effluent generated from washing can be treated at a wastewater treatment
plant
8 - Washing and maintenance Use of toxic substance for cleaning
of machinery and plant
Hazardous wastes generated from cleaning agents may pollute soil, air,
surface water or groundwater
Pollution of soil may affect people who live on it, plants that put roots into it and
animals that move over it
Air may become contaminated by direct emission of hazardous wastes
Evaporation of toxic solvents from cleaning agents is a common problem
River and lake pollution, if it is toxic enough, may kill animal and plant life
Immediately, or it may injure slowly
Page 3-25 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Underground pollutants can be carried by underground water flow to
contaminate water supplies
Water effluent generated from washing can be treated at a wastewater treatment
plant
9 - General operations Use of salt for safety measures on floors Wastes generated from the use of salt may pollute the surrounding soils, air, and
waterways
Sodium and calcium chlorides can severely impact vegetation through soil
contamination, direct foliar contact, and water pollution
Aquatic life may also be impacted due to changes in water chemistry and habitat
loss
Pollutants can be seen to negatively impact human health and quality of life
Page 3-26 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Figures 3-5 - 3-17: Process Flow Diagrams
Figure 3-5
PROCESS FLOW DIAGRAM
PROCESS CATEGORY: RAW PRODUCT, GROUND
PRODUCT: FRESH PORK SAUSAGE
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Figure 3-6
PROCESS FLOW DIAGRAM
PROCESS CATEGORY: MECHANICALLY SEPARATED (SPECIES)
PRODUCT: MECHANICALLY SEPARATED PORK
RECEIVING
PACKAGING
MATERIALS
SHIPPING
Page 3-28 of 44
RECEIVING
CARCASS
PARTS
Aspect
Impact
Packing Materials Use
Use of natural resources
Depletion of natural
resources
Solid waste
Landfill or incineration
Contamination of
land/water
Meat Storage (cold)
CFCs and HFCs
Depletion of ozone
Ammonia
Global warming
Human health impacts
Shipping/receiving meat
CO, NOx, VOCs
Air quality
Human health impacts
Global warming
Noise
Human health impacts
Road/traffic waste
Contamination of land/
water
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Figure 3-7
PROCESS FLOW DIAGRAM
PROCESS CATEGORY: SLAUGHTER
PRODUCT: PORK (CARCASSES)
RECEIVING
PACKAGING
MATERIALS
RECEIVING LIVE SWINE
STUNNING/BLEEDING/SCALDING
DEHAIRING
GAMBRELLIN G/SIN GEIN G/POLISHIN G/SHA VIN G
PRE-EVISCERATION WASH (ANTIMICROBIAL)
EVISCERATION
PLUCK/VISCERA
DISASSEMBLE &
PROCESS
FINAL TRIM/FINAL WASH (ANTIMICROBIAL)
Aspect
Impact
Housing live animals
Animal waste
Contamination of land/water
Odors
Air pollution
Water effluent
Human health impact
Sunning/killing
Fuel/energy usage
Depletion of natural resource
Air emissions
Air pollution
Animal waste
Landfill or incineration
Human health impacts
Carcass washing and rinsing
Water effluent
Depletion of natural resource
Contamination of water supply
Human health impacts
SHIPPING
WASH
(ANTIMICROBIAL)
Page 3-29 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Figure 3-8
PROCESS FLOW DIAGRAM
PROCESS CATEGORY: SLAUGHTER
PRODUCT: BEEF
RECEIVING
PACKAGING
MATERIALS
STORAGE
PACKAGING
MATERIALS
FINISHED PRODUCT
STORAGE (COLD)
VARIETY
MEATS
PRODUCTION
SHIPPING
Page 3-30 of 44
Aspect
Impact
Housing live animals
Animal waste
Contamination of land/water
Odors
Air pollution
Water effluent
Human health impact
Sunning/killing
Fuel/energy usage
Depletion of natural resource
Air emissions
Air pollution
Animal waste
Landfill or incineration
Human health impacts
Carcass washing and rinsing
Water effluent
Depletion of natural resource
Contamination of water supply
Human health impacts
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Figure 3-9
PROCESS FLOW DIAGRAM
PROCESS CATEGORY: THERMALLY PROCESSED, COMMERCIALLY STERILE
PRODUCT: BEEF STEW
RECEIVING
CANS/PACKAGING
MATERIALS
RECEIVING
NON-MEAT
FOOD
INGREDIENTS
RECEIVING
FROZEN COOKED
DICED BEEF
STORAGE
CANS/PACKAGING
MATERIALS
CLEANING
CANS
STORAGE
NON-MEAT FOOD
INGREDIENTS
ASSEMBLE / PRE-WEIGH
CUT-UP/PRE-MIX
NON-MEAT FOOD
INGREDIENTS
FORMULATION
FILLING
SEALING
THERMAL
PROCESSING
& COOLING
LABELING
AND
CASING
STORAGE
SHIPPING
STORAGE
FROZEN COOKED
DICED BEEF
ASSEMBLE/WEIGH
PRE-GRIND / RE-WORK
FINAL GRIND
COOKED DICED BEEF
Aspect
Impact
Packing Materials Use
Use of natural resources
Depletion of natural resources
Solid waste
Landfill or incineration
Contamination of land/water
Preparing/processing meat
Air exhaust
Air pollution
Human health impacts
Noise/vibrations
Human health impacts
Animal waste
Landfill or incineration
Meat Storage (cold)
CFCs and HFCs
Depletion of ozone
Ammonia
Global warming
Human health impacts
Shipping/receiving meat
CO, NOx, VOCs
Air quality
Human health impacts
Global warming
Noise
Human health impacts
Road/traffic waste
Contamination of land/water
Page 3-31 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Figure 3-10
PROCESS FLOW DIAGRAM
PROCESS CATEGORY: PRODUCTS WITH SECONDARY INHIBITORS,
NOT SHELF STABLE
PRODUCT: CORNED BEEF
RECEIVING
PACKAGING
MATERIALS
RECEIVING
RAW REEF ROUNDS
STORAGE
(COLD - FROZEN/REFRIGERATED)
RAW REEF
TEMPERING
FROZEN REEF
CURE APPLICATION
STORAGE
PACKAGING
MATERIALS
VACUUM
PACKAGIN G/LARELIN G
RECEIVING
RESTRICTED
NONMEAT
FOOD
INGREDIENTS
STORAGE
RESTRICTED
NONMEAT
FOOD
INGREDIENTS
WEIGHING
RESTRICTED
NONMEAT
FOOD
INGREDIENTS
RECEIVING
UNRESTRICTED
NONMEAT
FOOD
INGREDIENTS
STORAGE
UNRESTRICTED
NONMEAT
FOOD
INGREDIENTS
WEIGHING
UNRESTRICTED
NONMEAT
FOOD
INGREDIENTS
FINISHED PRODUCT STORAGE
(COLD)
Aspect
Impact
Packing Materials Use
Use of natural resources
Depletion of natural resources
Solid waste
Landfill or incineration
Contamination of land/water
Preparing/processing meat
Air exhaust
Air pollution
Human health impacts
Noise/ vibrations
Human health impacts
Animal waste
Landfill or incineration
Meat Storage (cold)
CFCs and HFCs
Depletion of ozone
Ammonia
Global warming
Human health impacts
Shipping/receiving meat
CO, NOx, VOCs
Air quality
Human health impacts
Global warming
Noise
Human health impacts
Road/traffic waste
Contamination of land/water
Page 3-32 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Figure 3-11
PROCESS FLOW DIAGRAM
PROCESS CATEGORY: RAW PRODUCT, NOT GROUND
PRODUCT: BEEF TRIMMINGS, TENDERIZED (MECHANICALLY) BEEF CUTS
RECEIVING
PACKAGING
MATERIALS
RECEIVING
CARCASSES
STORAGE
(COLD)
CARCASSES
STORAGE
PACKAGING
MATERIALS
REEF CUTS
FABRICATION OF
BEEF
TRIMMINGS
AND/OR
BEEF CUTS
Aspect
Impact
Packing Materials Use
Use of natural resources
Depletion of natural resources
Solid waste
Landfill or incineration
Contamination of land/water
Preparing/processing meat
Air exhaust
Air pollution
Human health impacts
Noise/vibrations
Human health impacts
Animal waste
Landfill or incineration
Meat Storage (cold)
CFCs and HFCs
Depletion of ozone
Ammonia
Global warming
Human health impacts
Shipping/receiving meat
CO, NOx, VOCs
Air quality
Human health impacts
Global warming
Noise
Human health impacts
Road/traffic waste
Contamination of land/water
BEEF TRIMMINGS
FINISHED
PRODUCT
STORAGE (COLD)
SHIPPING
Page 3-33 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Figure 3-12
PROCESS FLOW DIAGRAM
PROCESS CATEGORY: SLAUGHTER
PRODUCT: YOUNG CHICKEN
Page 3-34 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Figure 3-13
PROCESS FLOW DIAGRAM
PROCESS CATEGORY: MECHANICALLY DEBONED POULTRY
PRODUCT: MECHANICALLY DEBONED CHICKEN
Aspect
Impact
Housing live animals
Animal waste
Contamination of land/water
Odors
Air pollution
Water effluent
Human health impact
Sunning/killing
Fuel/energy usage
Depletion of natural resource
Air emissions
Air pollution
Animal waste
Landfill or incineration
Human health impacts
Carcass washing and rinsing
Water effluent
Depletion of natural resource
Contamination of water supply
Human health impacts
Page 3-35 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Figure 3-14
PROCESS FLOW DIAGRAM
PROCESS CATEGORY: HEAT TREATED, SHELF STABLE
PRODUCT: SNACK STICKS, JERKY
RECEIVING
PACKAGING
MATERIALS
RECEIVING
RESTRICTED
NONMEAT/
NONPOULTRY
FOOD
INGREDIENTS
STORAGE
RESTRICTED
NONMEAT/
NONPOULTRY
FOOD
INGREDIENTS
WEIGHING
RESTRICTED
NONMEAT/
NONPOULTRY
FOOD
INGREDIENTS
FERMENTING (SOME
SNACK STICKS
ONLY)
HEAT TREATMENT
RECEIVING
UNRESTRICTED
NONMEAT/
NONPOULTRY
FOOD
INGREDIENTS
STORAGE
UNRESTRICTED
NONMEAT/
NONPOULTRY
FOOD
INGREDIENTS
WEIGHING
UNRESTRICTED
NONMEAT/
NONPOULTRY
FOOD
INGREDIENTS
Aspect
Impact
Packing Materials Use
Use of natural resources
Solid waste
Depletion of natural resources
Landfill or incineration
Contamination of land/water
Preparing/processing meat
Air exhaust
Noise/vibrations
Animal waste
Air pollution
Human health impacts
Human health impacts
Landfill or incineration
Meat Storage (cold)
CFCs and HFCs
Ammonia
Depletion of ozone
Global warming
Human health impacts
Shipping/receiving meat
CO, NOx, VOCs
Noise
Road/traffic waste
Air quality
Human health impacts
Global warming
Human health impacts
Contamination of land/water
Page 3-36 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Figure 3-15
PROCESS FLOW DIAGRAM
PROCESS CATEGORY: HEAT TREATED BUT NOT FULLY COOKED, NOT SHELF STABLE
PRODUCT: SMOKED SAUSAGE, PARTIALLY COOKED CHICKEN PATTIES
Page 3-37 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Figure 3-16
PROCESS FLOW DIAGRAM
PROCESS CATEGORY: FULLY COOKED, NOT SHELF STABLE
PRODUCT: HAM/ROAST BEEF
Page 3-38 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Figure 3-17
PROCESS FLOW DIAGRAM
PROCESS CATEGORY: NOT HEAT TREATED, SHELF STABLE
PRODUCT: PEPPERONI AND SALAMI
RECEIVING
PACKAGING
MATERIALS
RECEIVING
RAW MEAT
STORAGE
(COLD - FROZEN/REFRIGERATED)
RAW MEAT
RECEIVING
RESTRICTED
NONMEAT
FOOD
INGREDIENTS
RECEIVING
UNRESTRICTED
NONMEAT
FOOD
INGREDIENTS
TEMPERING
FROZEN MEAT
STORAGE
RESTRICTED
NONMEAT
FOOD
INGREDIENTS
WEIGHING
RAW MEAT
COMBINE INGREDIENTS/
PROCESSING (LIST ALL) *
STORAGE
PACKAGING
MATERIALS
WEIGHING
RESTRICTED
NONMEAT
FOOD
INGREDIENTS
STORAGE
UNRESTRICTED
NONMEAT
FOOD
INGREDIENTS
PREPARING
STARTER
CULTURES/
CASINGS
FERMENTING
STORAGE
STARTER
CULTURES/
CASINGS
WEIGHING
UNRESTRICTED
NONMEAT
FOOD
INGREDIENTS
RECEIVING
STARTER
CULTURES/
CASINGS
Aspect
Impact
Packing Materials Use
Use of natural resources
Solid waste
Depletion of natural resources
Landfill or incineration
Contamination of land/water
Preparing/processing meat
Air exhaust
N oi se/vibrations
Animal waste
Air pollution
Human health impacts
Human health impacts
Landfill or incineration
Meat Storage (cold)
CFCs and HFCs
Ammonia
Depletion of ozone
Global warming
Human health impacts
Shipping/receiving meat
CO, NOx, VOCs
Noise
Road/traffic waste
Air quality
Human health impacts
Global warming
Human health impacts
Contamination of land/water
DRYING
SLICING/PEELING
PACKAGING/LABELING
FINISHED PRODUCT
STORAGE (COLD)
Stuffing
Chopping
Mixing
Grinding
Forming
SHIPPING
Page 3-39 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Attachment 3-B: Sample Template For Identifying Activities /Products/Services, Environmental Aspects and Impacts
and Legal/Other Requirements
Activities/Products/Services
* Things at your plant that cai
interact with the environment
Environmental AsDects
* Interaction of these things with the
environment - beneficial or adverse
Environmental ImDacts
* Any change in the environment -
beneficial or adverse
Legal/Other Reauirements
* What rules relate to the
environmental aspect
Boiler operation
Air emissions that result from the
burning of fuel to heat the boiler
Air pollution (from the emission of
nitrogen oxides (NOx))
Clean Air Act (CAA)
Cleanup
Floor washing and cleanup
BOD loading of the POTW
Local POTW sewer ordinance and the
POTW's NPDES discharge criteria
Page 3-40 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Attachment 3-C: Identification of Environmental Aspects Procedure
I. Purpose
In order to understand and manage its actual and potential environmental impacts, ABC Meat
Processing identifies the environmental aspects of its activities, products, and services as they
fall within the scope of the EMS.
II. Procedure
1. Using processing mapping (or input/output flow charts), the EMS committee
identifies the basic manufacturing and supporting operations that fall within the scope
of the EMS. These are recorded, with supporting material flow diagrams and tables.
2. The EMS coordinator arranges for the environmental aspects of these operations to be
identified by a team of several employees from the operation in question, using the
process mapping approach where feasible and under the oversight of the EMS
coordinator or a committee member where appropriate.
3. Environmental aspects are grouped where appropriate and their actual or potential
impacts (quantified to the extent possible) are listed by activity, product, or service in
a format similar to EA-02.
III. Frequency
This procedure is repeated annually to ensure that any new environmental aspects are identified.
Page 3-41 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
EA-02: Sample Aspect Identification Form
Activity, Product
or Service
Input / Output
Environmental
Aspect
Grouped Aspect
Environmental
Impact
Contact Person: Date Completed:
Page 3-42 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
Attachment 3-D: Identification of Legal Requirements
I. Purpose
ABC Meat Processing is committed to complying with all applicable environmental regulations.
This procedure describes how ABC Meat Processing identifies applicable regulations.
II. Procedure
1. The EMS management representative is responsible for tracking applicable
environmental laws and regulations and evaluating their potential impact on the
company's operations. He or she employs several techniques to track, identify, and
evaluate applicable laws and regulations. These techniques include commercial
databases, information from the trade association, direct communication with national
and state regulatory agencies, and periodic refresher training on environmental laws.
2. As necessary, the management representative may call upon off-site resources such as
consultants or attorneys.
3. The management representative compiles and maintains updated copies of applicable
environmental laws and regulations.
4. The management representative, working with the EMS coordinator and committee,
correlate these regulations to the business activities and environmental aspects
associated with them using format similar to LR-01, given below.
III. Frequency
Periodic: depends on information source.
IV. Records
The EMS coordinator maintains the format (LR-01: Applicable Legal Requirements). The EMS
management representative maintains copies of the applicable regulations.
Page 3-43 of 44
-------
EMS Implementation Guide for the Meat Processing Industry
Module 3: Identifying Environmental Aspects and Impacts
LR-01: Applicable Legal Requirements
The following table provides a list of environmental regulations that apply to ABC Meat Processing's activities. The specific operation(s) to
which each regulation applies are also shown.
Regulatory Agency
Regulation and Specific Provision
Operation(s) to which Provision Applies
Contact Person: Date Completed:
Page 3-44 of 44
-------
This page intentionally left blank.
-------
Environmental
Management System
(EMS) Implementation
Guide for the
Meat Processing Industry
Module 4: Determining Significant
Environmental Aspects and
Setting Objectives and Targets
-------
EMS Implementation Guide for the Meat Processing Industry
Module 4: Determining Significant Environmental Aspects and Setting Objectives and
Targets
Table of Contents
Introduction 4-2
Example Significance Procedure 1 4-4
Overall Risk Rating 4-6
Example Significance Procedure 2 4-11
Setting Environmental Objectives and Targets 4-14
Homework 4-18
Attachment 4-A: EMS Procedure: Setting and Tracking of Environmental Objectives
and Targets 4-20
List of Figures
Figure 4-1: Impacts Screening Procedure for Determining Significant Environmental
Aspects 4-3
Figure 4-2: Risk Rating Matrix 4-7
Figure 4-3: Considerations for Setting Objectives and Targets 4-15
Figure 4-4: Significant Aspects and Objectives and Targets 4-17
List of Tables
Table 4-1: Significance Spreadsheet 4-10
Table 4-2: Sample Form for Identification and Significance Determination of
Environmental Aspects 4-13
Table 4-3: Comparing Objectives and Targets - Some Examples 4-14
Page 4-1 of 23
-------
EMS Implementation Guide for the Meat Processing Industry
Module 4: Determining Significant Environmental Aspects and Setting Objectives and
Targets
Introduction
Once your plant's environmental aspects are fully identified and placed into manageable
categories, the next step is to identify those that are significant and which therefore need to be
managed. This module will help you prioritize these aspects and to determine which one(s) to
work on first.
An aspect is considered significant if it has or may have a significant impact on the environment.
Since the aspect is the cause and the impact is the effect (see Module 3) you need to be
concerned with reducing the effects by ranking them and prioritizing which causes to focus
your efforts on. For example: If you identified five separate processes around your plant
(aspects) with air pollution impacts and ten that have water pollution impacts, your plant needs a
process to decide on which of the aspects that result in these impacts, will be focus of your
efforts at prevention of pollution Your management will want to spend its limited resources in
the most effective way and get the "best bang for the buck". This module provides guidance
how to decide on which aspects to focus your management efforts.
Managing your environmental aspects consists of the ways you plan to achieve prevention of
pollution, compliance and continual improvement, which will often be as unique as your
operation. Do not expect to work on all of the aspects you have identified in Module 3. Expect
to work on some now and others in the future.
The ranking and prioritization process, which is called determination of significance, is intended
to identify significant environmental aspects associated with activities, products, or services, and
is not intended to require a detailed life-cycle assessment. You do not have to evaluate each
product, component, or raw material input. You may instead select categories of activities,
products or services to identify those aspects most likely to have a significant impact.
Every plant is unique and therefore the rationale behind where to put the greatest emphasis in
environmental management programs is also unique. Depending on how your plant has defined
its process for identification of Hazard Analysis and Critical Control Point (HACCP) critical
control points, it may provide you with building blocks and ideas on approaches for determining
your plant's significant aspects.
The following is an example of a procedure that can be used to identify significant
environmental aspects. It is recommended that you and your Core Team consider this procedure
as a starting point to develop your own customized procedure. Figure 4-1 graphically represents
this procedure.
Page 4-2 of 23
-------
EMS Implementation Guide for the Meat Processing Industry
Module 4: Determining Significant Environmental Aspects and Setting Objectives and
Targets
Figure 4-1: Impacts Screening Procedure for Determining Significant Environmental
Aspects
Specific Aspect
~
Page 4-3 of 23
-------
EMS Implementation Guide for the Meat Processing Industry
Module 4: Determining Significant Environmental Aspects and Setting Objectives and
Targets
Example Significance Procedure 1
The significance of environmental aspects is determined by subjecting each grouped aspect to a
screening process (yes/no filters) in the sequence given below.
Hint: When determining significance consider whether the impacts of concern happen
continuously, once in a while or only on special occasions (Example: there is a process upset).
Screen 1: Regulatory Requirements
This screen identifies those environmental aspects that are subject to legislation and regulation
(including permit requirements and regulatory agreements), but are not being met. [Not being
met being defined in this case as the existence of a known non-compliance (continuous or
intermittent) or the organization is currently unable to confirm if it is or is not in compliance].
These aspects are considered significant. If the environmental aspect is not subject to any
regulatory requirements, it may still be considered significant at Screen 2.
Note: Many of your existing environmental programs keep you in compliance with regulatory
requirements. This first screen is based on the state of your plant at the time of the assessment of
significance. When determining significant aspects you are looking for where a new program
might be needed or additions to an existing one to ensure compliance.
Screen 2: Unique Value System of the Company
This screen identifies those environmental aspects deemed a priority based upon the value
system of the company. The value system is unique to your plant and may include:
• Corporate commitments and requirements,
• Financial operational and business requirements,
• Aspirations and initiatives that are designed to move your organization towards a "triple
bottom line" approach (economic prosperity + social well being + healthy environment);
and
• Views of interested parties such as stockholders, community groups, regulatory agencies
and environmental groups, etc.
Environmental aspects, which are considered a priority based upon your plant's value system,
would be considered significant. If the aspect is not considered to be significant at this stage, it
may still be at Screen 3.
Note: This type of screen allows you to decide that regardless of other factors that the aspect is
significant. For example, if you decide that recycling wooden pallets is important to your plant
and you would like to have an environmental management program for it, you can make it
significant although the other screens (regulatory and risk) would not make it significant.
However, it does not allow you to override a finding of significance indicated by the other
screens.
Page 4-4 of 23
-------
EMS Implementation Guide for the Meat Processing Industry
Module 4: Determining Significant Environmental Aspects and Setting Objectives and
Targets
Screen 3: Risk Ranking
Aspects that have not been identified as significant by Screens 1 or 2 undergo risk ranking to
determine if they pose a risk unaccounted for in previous screens, and are significant aspects on
this basis. In the risk ranking process, a angle, numerical risk rating (between 1 and 25) is
calculated for each aspect at this stage.
Based on this rating, an aspect is classified as either significant (equal to or more than N points)
or non-significant (less than N points). Again, the value of N must be selected by your plant in
advance of applying the risk ranking. For this ranking scheme consider a minimum value of 9
and a maximum value of 15. For your first analysis of significance it is recommended that you
start with a value 12 for N and evaluate all of your aspects with this level of screening.
Note: Over time a plant can drive continual improvement into its EMS by decreasing the risk
ranking score (the value of N) at which it defines an aspect as significant.
The risk rating for the aspect is the product of two variables:
Consequence * Relative Probability, where
• Consequence (assigned a value of 1 to 5) refers to the consequence of the aspect in terms
of the magnitude of the associated impact; and
• Relative Probability (assigned a value of 1 to 5) refers to the likelihood of occurrence of
the impact associated with the aspect.
Note: To add consistency into your risk ranking process, use a committee and keep records of the
reasoning behind the consequence and probability rankings you assign.
Consequence Rating
Two impact attributes are considered for the assignment of Consequence values:
• Impact intensity; and
• Geographic extent and duration.
Impact intensity is considered the more important of these two and is assigned values of:
1 - Low 3 - High; or
2 - Moderate 4 - Very High
Note: The intensity of the impact is a measure of the severity of the damage. Using air pollution
as an example, a low intensity impact would be visible emissions with perceived public nuisance,
moderate intensity would be some reduced visibility with air pollution, and high intensity would
be excessive reduced visibility and/or public nuisance and very high intensity would be
exceedance of regulatory and/or other standards.
Page 4-5 of 23
-------
EMS Implementation Guide for the Meat Processing Industry
Module 4: Determining Significant Environmental Aspects and Setting Objectives and
Targets
Geographic extent and duration are considered together and are assigned values of:
0 - Low; or
1 - High
Note: Low geographic extent and duration would be an impact in the immediate vicinity or
neighborhood of the plant or one that does not have a lasting effect. For example: noise. A high
extent might be water contamination that travels downstream in river (e.g., an oil spill will leave
the soil contaminated for years).
The intensity and geographic extent and duration values are added to obtain the overall
Consequence rating as shown below:
1 - Negligible impact
2 - Minor impact
3 - Moderate impact
4 - Major impact
5 - Massive impact
(Low intensity, Low extent and duration: 1+0=1)
(Low intensity, High extent and/or duration: 1 + 1 = 2); or
(Moderate intensity, Low extent and duration: 2 + 0 = 2)
(Moderate intensity, High extent and/or duration: 2 + 1 = 3); or
(High intensity, Low extent and duration: 3 + 0 = 3)
(High intensity, High extent and/or duration: 3 + 1 = 4); or
(Very high intensity, Low extent and duration: 4 + 0 = 4)
(Very high intensity, High extent and/or duration: 4+1=5)
Relative Probability Rating
The Relative Probability rating of a specific aspect is based on the frequency of occurrence
rather than on the duration of the associated impact. The rating is assigned using the scale shown
below:
1 - Unheard of in the meat processing sector
2 - Suspected or known to occur in the sector
3 - Incident has occurred at your plant
4 - Occurs several times per year at your plant (For example: up to 3 times a year
historically)
5 - Occurs regularly at your plant (For example: once a month or more)
Overall RiskRating
The overall risk rating of an aspect is determined by multiplying the Consequence rating by the
Relative Probability rating. Figure 4-2 illustrates all possible risk ratings and, for illustrative
purposes, highlights those that are greater than or equal to 12. In this example, aspects with a
rating of 12 or more are considered significant, and aspects that have a rating of less than 12 are
considered to be non-significant.
Page 4-6 of 23
-------
EMS Implementation Guide for the Meat Processing Industry
Module 4: Determining Significant Environmental Aspects and Setting Objectives and
Targets
Figure 4-2: Risk Rating Matrix
Relative Probability
Unheard of in
Suspected or
Has
Occurs
several
Occurs regularly
sector
known to occur
happened
times/
year at
at plant
in sector
at plant
plant
Consequence
Negligible
1
2
3
4
5
Minor
2
4
6
8
10
Moderate
3
6
9
111—
Major
4
8
lllilMilllil
ilillBlM
Massive
5
10
15
20
25
Note: Some organizations might decide to have additional screens before an aspect is considered
to be non-significant. Organizations may have as many as 6 or 7 "triggers" where if any of the
present conditions are met with respect to a particular aspect then it is automatically considered
significant. Adding more screens has the effect of potentially a greater number of aspects being
considered as significant.
Hint: The consequence rating is derived based on subjective assessments of intensity and extent
or duration of the impact (High, Moderate, etc., are terms that mean different things to different
people). As a result, it is wise to consider a team approach to determining scores in risk ranking.
In addition, retain records of how the analysis was conducted. If the scores determined for the
aspects were recorded along with rationale/comments for choosing these scores, this process may
be duplicated in the future with a greater degree of consistency.
The following examples illustrate the procedure involved in risk ranking to determine if an
aspect is significant. For both of these examples, it is assumed that the aspect was not significant
at Screens 1 and 2.
Page 4-7 of 23
-------
EMS Implementation Guide for the Meat Processing Industry
Module 4: Determining Significant Environmental Aspects and Setting Objectives and
Targets
EXAMPLE 1
Activity/Product/Service Aspect Impact
Packaging material use Generation waste Increased disposal to landfill
from packaging Air, surface, groundwater
contamination from landfill
Consequence Rating
• Impact intensity - 2 (moderate)
• Geographic extent and duration - 0 (low)
Overall score 2 + 0 = 2
2 - Minor impact (Moderate intensity, Low extent and duration: 2 + 0 = 2)
Relative Probability Rating
The probability ranking is 5 (occurs regularly at your site(s)).
Risk Rating
Consequence * Relative Probability
2*5 = 10
Based upon an arbitrary rating system, which considers that those aspects with a rating of more
than 11 are significant, this aspect with an overall rating of 10 would be labeled non-significant.
EXAMPLE 2
Activity/Product/Service Aspect Impact
Meat smoking Air pollutants generated Affects air quality and poses
a risk to human health
Consequence Rating
• Impact intensity - 3 (high)
• Geographic extent and duration - 1 (high)
Overall score 3 + 1=4
4 - Major impact (High intensity, High extent and duration: 3 + 1=4)
Page 4-8 of 23
-------
EMS Implementation Guide for the Meat Processing Industry
Module 4: Determining Significant Environmental Aspects and Setting Objectives and
Targets
Relative Probability Rating
The probability ranking is 5 (occurs regularly at your site(s)).
Risk Rating
Consequence * Relative Probability
4 * 5 = 20
Given the same rating system as in Example 1, this aspect with an overall rating of 20 would be
considered significant.
Note: At some point in the future the factors that resulted in aspect being deemed significant may
change. Before you can consider an aspect no longer significant, be sure to reapply the entire
significance procedure to ensure that no other factors exist that would result in it being
significant.
The information gathered in the process of identifying significant environmental aspects is useful
for setting objectives and targets for your plant.
Page 4-9 of 23
-------
EMS Implementation Guide for the Meat Processing Industry
Module 4: Determining Significant Environmental Aspects and Setting Objectives and Targets
Table 4-1: Significance Spreadsheet
Environmental Aspect
Intensity
Duration and
Extent
Sum
Probability
Overall
Rating
Significant?
Rationale / Comments
Pick 1 to 4
Pick 0 or 1
Pick 1 to 5
Generation of waste from
packaging
2
0
2
5
10
Not Significant
Landfill impacts for packaging materials are
not generally considered severe except that
materials do take up limited space
Air emissions from meat
smoking
3
1
4
5
20
Significant
Air emissions can adversely effect local and
adjacent properties (if there are nearby
residences for example)
Air emissions from the boiler
1
1
2
5
10
Not Significant
A boiler is not a major air emissions source
in the area but does operate year round
Floor washing and cleanup
3
1
4
5
20
Significant
Floor washing generates large quantities of
waste water and occurs frequently
Page 4-10 of 23
-------
EMS Implementation Guide for the Meat Processing Industry
Module 4: Determining Significant Environmental Aspects and Setting Objectives
and Targets
Example Significance Procedure 2
Purpose
This procedure defines another method for the determination of significance for aspects
that have actual or potential significant impacts on the environment.
Procedure for Determination of Significant Environmental Aspects
Using the Significance Determination portion of Table 4-2, the EMS Core Team or a
subset thereof shall evaluate, using its best judgment, each identified aspect and
determine whether or not it is agnificant. The environmental aspects of ABC Meat
Processing may be considered by the EMS Core Team to be "significant" where the
aspect has an impact on the environment and meets one or more of the following criteria:
1. Subject to specifically relevant regulation and/or permit requirements that address
significant impacts to the environment. This will likely include aspects associated
with processes and activities if (1) environmental regulations specify controls and
conditions, (2) information must be provided to the authorities, and/or (3) there are or
may be periodic inspections or enforcements by the authorities. Potential aspects that
are subject to environmental regulations in the event of incidents will be recognized
as significant when such as event occurs.
2. Subject to or associated with environmentally related company goals, directives,
policies or subject to or associated with voluntary covenants to which the company
had committed.
3. Subject to or associated with community concerns, such as those previously
expressed in the form of complaints or critical inquiry. This criterion only shall be
reviewed when an aspect is not significant because criteria 1 or 2 apply.
4. Based on technical and business conditions has a high potential for pollution
prevention or resource-use reduction. This criterion only shall be reviewed when an
aspect is not significant because criteria 1 or 2 apply.
5. Associated with potential release to the environment from the high environmental
loading due to one or more of the following:
a. Toxicity (compositional characterization of materials and wastes)
b. Amounts (volumes and masses or release)
c. Amounts (consumption of renewable and non-renewable resources)
d. Frequency of episodes
e. Severity of actual or potential impacts
Page 4-11 of 23
-------
EMS Implementation Guide for the Meat Processing Industry
Module 4: Determining Significant Environmental Aspects and Setting Objectives
and Targets
This criterion only shall be reviewed when an aspect is not significant because criteria
1 or 2 apply.
Frequency
This procedure is to be repeated at least annually, if not more frequently. More frequent
updates apply especially to new project or processes that affect the list of the facility's
significant aspects.
Records
Table 42 is maintained by the Environmental Management Representative (EMR) or
their designee.
Page 4-12 of 23
-------
EMS Implementation Guide for the Meat Processing Industry
Module 4: Determining Significant Environmental Aspects and Setting Objectives and Targets
Table 4-2: Sample Form for Identification and Significance Determination of Environmental Aspects
Person Completing Form: Area/Process: Date:
ASPECT IDENTIFICATION
SIGNIFICANCE DETERMINATION
OBJECTIVES AND
TARGETS
Category/ Aspect
Mode
SD=shutdown,
ST=startup,
NM=normal,
E=emergency
Quantity or
Volume
(e.g. Ibs/month)
Legal
Requirements
Company goal or
policy
Community
Concern
Potential Release
to the
r ii\ imil men 1
Pollution
Prevention
Potential
I or S
Rationale for
Significance (S)
or
Insignificance
0)
Objective &
Type
C=control or
maintain
S=study or
investigate
I=improve
Target
Supplies:
Chemicals:
Energy Use:
Water Use:
Products:
Air Emissions:
Noise/Odor/Radiation:
Page 4-13 of 23
-------
EMS Implementation Guide for the Meat Processing Industry
Module 4: Determining Significant Environmental Aspects and Setting Objectives
and Targets
Setting Environmental Objectives and Targets
Objectives and targets help an organization translate purpose into action. These
environmental goals should be factored into your strategic plans and can facilitate the
integration of environmental management with your other management processes.1
First the terms environmental objective and environment target will be defined.
An environmental objective
refers to an overall environmental goal, arising from the environmental policy, that an
organization sets itself to achieve, and which is quantified where practicable.
An environmental target
refers to a 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. (28)
Example of both objectives and targets is given in the Table 4-3 below.
Table 4-3: Comparing Objectives and Targets - Some Examples
Objectives
Targets
Reduce energy usage
Reduce electricity use by 10% in 2001
Reduce natural gas use by 15% in 2001
Reduce usage of hazardous chemicals
Eliminate use of CFCs by 2002
Reduce use of high-VOC paints by 25%
Improve employee awareness of environmental
issues
Hold monthly awareness training courses
Train 100% of employees by end of year
Improve compliance with wastewater discharge
permit limits
Zero permit limit violations by the end of 2001
(30)
In setting environmental objectives and targets, keep in mind not only your significant
environmental aspects and the reduction of adverse impacts, (see Figure 4-3), but also:
• Your environmental policy commitments;
• Preventing non-compliance with applicable legal and other requirements;
• Performance commitments your plant has made and improving performance;
• Pollution prevention (see Module 2 for description);
1 NSF International, Environmental Management Systems: An Implementation Guide for Small and
Medium-Sized Organizations (Michigan: NSF International, January 2001) 28. Subsequent references to
this document will be given in parentheses in text.
Page 4-14 of 23
-------
EMS Implementation Guide for the Meat Processing Industry
Module 4: Determining Significant Environmental Aspects and Setting Objectives
and Targets
• Minimizing cross media pollutant transfers (for example reducing a waste-water
impact only to increase a solid waste disposal issue);
• The views of interested parties;
• Technological options;
• Financial, operational; and
• Other organizational considerations. (28)
Not all of these lac tors will necessarily apply to a specific objective or target. Use your
judgement on a case-by-case basis.
Figure 4-3: Considerations for Setting Objectives and Targets
Policy
Environmental
Aspects
/ \ X
Legal I Other
Requirements
Views of
Interested Parties
\ I
Organizational
Commitments
Objectives
and
Targets
Technology
and P2
X /
Finance
\ \
Other
Business
Operations
and
Performance
One approach for setting objectives and targets is as follows.
Before considering setting specific objectives and targets, you must first examine your
current management programs and operational controls. It is important to go
through an exercise of knowing everything your plant does, formally and informally, to
manage the environment. In this process, you will likely discover that certain programs
are already performing effectively and therefore do not need further improvement or
control. In which case, it would be redundant to set objectives and targets for them
If you have followed the significance determination procedure outlined earlier in this
module, there may a number of aspects that you have not defined as being significant
because of the existence of current management programs and operational controls.
Page 4-15 of 23
-------
EMS Implementation Guide for the Meat Processing Industry
Module 4: Determining Significant Environmental Aspects and Setting Objectives
and Targets
This is a reflection of the fact that you are already doing good things to protect the
environment. Take credit for your existing work by recognizing that you are already
succeeding in preventing some aspects from being significant.
These existing successes may include:
• Operation and maintenance programs for equipment and for other operations that
ensure that you are in legal compliance;
• Operation and maintenance programs for equipment and for other operations that
ensure that other environmental aspects are not significant; and
• Existing pollution prevention activities that are effective in reducing
environmental impacts.
Be sure that these are understood to a sufficient level of detail so that:
• Where appropriate they can be used as a starting point to reference when setting
new objectives and targets; and
• To ensure that all existing practices are included in the EMS and that the good
work which currently exists is not lost.
Any process you design for developing objectives and targets should include an
evaluation of the effectiveness of your facilities current operational controls. Operational
controls are discussed in detail in Module 5 and are the environmental equivalent to the
controls required for HACCP program critical control points. Some objectives and
targets may be geared towards general process improvements rather than any one specific
significant aspect.
Review your plant's significant environmental aspects. In developing objectives and
targets, it is important to gain an overview of the significant aspects at your plant, as
these will be the main source for your objectives and targets. This basically involves
reviewing the significant aspects that were identified earlier in this module.
The degree and complexity of objectives and targets you decide to develop for each of
the significant aspects on your list will vary. Therefore, the next task is to establish a
review process in which you gather and analyze information about your significant
aspects in order to identify for which ones you will develop more detailed objectives and
targets.
In your review of your identified significant aspects for potential objective and target
development, consider the feasibility of implementation. How feasible would it be to
implement potential objectives and targets and management programs for your significant
aspects?
Page 4-16 of 23
-------
EMS Implementation Guide for the Meat Processing Industry
Module 4: Determining Significant Environmental Aspects and Setting Objectives
and Targets
With consideration of your current operating procedures and their feasibility, you will
determine:
• Which associated aspects you will develop objectives and targets for; and
• Which associated aspects you will monitor without creating formal objectives and
targets.
Do not expect to develop one objective and target for each significant aspect. One aspect
may have several objectives associated with it and likewise one objective may have a
number of targets associated with it. See Figure 4-4.
Figure 4-4: Significant Aspects and Objectives and Targets
OR TFTTIVF^
SIGNIFICANT ASPECTS
Multiple objectives may
need to be established for a
single significant aspect.
One objective may
satisfy several
significant aspects.
Multiple targets may be
needed to achieve a single
objective.
One target may satisfy
several objectives.
Page 4-17 of 23
-------
EMS Implementation Guide for the Meat Processing Industry
Module 4: Determining Significant Environmental Aspects and Setting Objectives
and Targets
As your objectives and targets become clearer, the next step is to decide what specific
measurable indicators you will use to measure progress towards meeting them.
For each target, identify a measurement for success (e.g., volume of waste produced or
percent of water recycled, etc). These measurements should be:
• Simple and understandable;
• Objective;
• Verifiable;
• Linked to production; and
• Relevant to your objectives.
Targets should be sufficiently clear to answer the question: "Did we achieve our
objective?"
More details on monitoring and measurement will be presented in Modules 5 and 8.
You should document your objectives and targets. It is recommended that this
documentation be combined, with the corresponding management programs in a single
document.
Note: It is important to keep in mind that the objectives and targets that you have
determined only represent a first draft of your final objectives and targets. As you work
through Module 5 and learn what resources are needed for achieving your objectives and
targets, they may change. Again, don't be discouraged, rather keep in mind that the
process of determining objectives and targets is an iterative one, and subject to change as
you progress in achieving improved environmental management.
Once you have established your objectives and targets and decided how you will measure
progress towards them, your next task is to set up Environmental Management Programs
(EMPs) to implement these objectives and ensure achievement of the targets. This is the
focus of Module 5.
Attachment 4-A provides an example objectives and targets procedure.
Homework
Your homework will be to define your plant's specific aspect significance determination
procedure and then apply it to the aspects you have identified to date. Then draft
objectives and targets. Be sure to develop an understanding of the various environmental
management activities including operational controls that are already in place at your
plant.
Page 4-18 of 23
-------
EMS Implementation Guide for the Meat Processing Industry
Module 4: Determining Significant Environmental Aspects and Setting Objectives
and Targets
Prepare to take your recommended objectives and targets to management for approval.
You should also determine what management requires in order to approve these
objectives and targets.
Page 4-19 of 23
-------
EMS Implementation Guide for the Meat Processing Industry
Module 4: Determining Significant Environmental Aspects and Setting Objectives
and Targets
Attachment 4-A: EMS Procedure: Setting and Tracking of Environmental
Objectives and Targets
I. Purpose
The purpose of this procedure is to ensure that ABC Meat Processing establishes and
maintains documented environmental objectives and targets.
II. Scope
This procedure applies to environmental objectives and targets set at all relevant levels
within ABC Meat Processing.
III. Definitions
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 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
ABC Meat Processing establishes environmental objectives and targets in order to
implement the environmental policies. Objectives and targets also provide a means for
ABC Meat Processing to measure the effectiveness of its environmental efforts and
improve the performance of the environmental management system. In establishing
environmental objectives, ABC Meat Processing considers:
• Applicable laws and regulations (and requirements of other programs);
• Environmental aspects of the ABC Meat Processing's activities and products;
• Technological, financial, operational, and other ABC Meat Processing
requirements and commitments;
• Opportunities for pollution prevention and minimization of cross-media pollutant
transfers; and
• The views of employees and other interested parties.
Based on the ABC Meat Processing's environmental objectives, targets are established
for different functions within ABC Meat Processing and for different areas of the plant.
For example, ABC Meat Processing 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 ABC
Meat Processing's objective was achieved. An ABC Meat Processing-wide
Page 4-20 of 23
-------
EMS Implementation Guide for the Meat Processing Industry
Module 4: Determining Significant Environmental Aspects and Setting Objectives
and Targets
environmental objective might also be translated into individual projects (such as changes
in production processes, materials or pollution control equipment) in different plant areas.
V. Procedure
1. ABC Meat Processing'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.
2. Objectives are action and prevention oriented and are intended to result in
meaningful improvements in the ABC Meat Processing 's environmental
performance.
3. 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.). ABC Meat Processing'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).
4. As a starting point, ABC Meat Processing'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.
5. 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. ABC Meat Processing's environmental manager reviews proposed
objectives to ensure consistency with the overall environmental policy.
6. 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.
7. Each manager is responsible for communicating objectives and targets (and
the means for achieving them) to others in his / her part of ABC Meat
Processing.
Page 4-21 of 23
-------
EMS Implementation Guide for the Meat Processing Industry
Module 4: Determining Significant Environmental Aspects and Setting Objectives
and Targets
8. 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.
9. At the end of each calendar year, ABC Meat Processing'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. (118-119)
Page 4-22 of 23
-------
EMS Implementation Guide for the Meat Processing Industry
Module 4: Determining Significant Environmental Aspects and Setting Objectives and Targets
Environmental Objectives
The following is a list of ABC Meat Processing's current environmental objectives.
Objective
Related Significant
Environmental Aspect
Related Environmental Policy
Provision
T arget(s)
Contact Person: Date Completed:
Page 4-23 of 23
-------
Environmental
Management System
(EMS) Implementation
Guide for the
Meat Processing Industry
Module 5: Environmental Management
Programs (EMPs)
-------
EMS Implementation Guide for the Meat Processing Industry
Module 5: Environmental Management Programs (EMPs)
Table of Contents
Introduction 5-2
Evaluating Alternatives 5-5
Operational Controls 5-6
Monitoring and Measurement 5-9
Homework 5-11
Attachment 5-A: Conducting an Alternatives Evaluation 5-12
Attachment 5-B: Development of Operational Controls 5-19
List of Figures
Figure 5-1: Sample Environmental Management Program Form 5-4
Figure 5-2: Environmental Management Program - Sample Tool 5-5
Figure 5-3: Root Cause Diagram 5-8
Page 5-1 of 21
-------
EMS Implementation Guide for the Meat Processing Industry
Module 5: Environmental Management Programs (EMPs)
Introduction
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?); and
• The time frame for achieving those goals (when?). (32)
Your environmental management programs need not be detailed "how-to" manuals, but they
should outline specific tasks and assignments of responsibility. It is not necessary that the
programs be documented; however, we recommend that you prepare written programs.
Experience shows that it is difficult, if not impossible, to implement an environmental
management program consistently at a plant without a written program outline.
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. (32)
1 NSF International, Environmental Management Systems: An Implementation Guide for Small and Medium-Sized
Organizations (Michigan: NSF International, January 2001) 32. Subsequent references to this document will be
given in parentheses in text.
Page 5-2 of 21
-------
EMS Implementation Guide for the Meat Processing Industry
Module 5: Environmental Management Programs (EMPs)
An outline for such a program might include:
• Objective;
• Target;
• Person(s) responsible;
• Budget;
• Date of expected completion;
• Date of actual completion; and
• Performance indicators for measurement.
Your EMP(s) need not be compiled into a single document. A 'i*oad 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. (32)
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. (32)
Hints:
Build on the plans and programs you have now for compliance, health & safety, HACCP, or
quality management.
Involve your employees/colleagues early in establishing and carrying out the program.
Clearly communicate the expectations and responsibilities defined in the program to those who
need to know.
In some cases, your environmental management programs 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 in Figure 5-2) and focus on continual improvement of the
program overtime. (32-33)
There may be real opportunities here! Coordinating your environmental program with your
overall plans and strategies may position your plant to exploit some significant cost-saving
opportunities.
Page 5-3 of 21
-------
EMS Implementation Guide for the Meat Processing Industry
Module 5: Environmental Management Programs (EMPs)
Note: Similar to Module 4, Figure 4-4 where there may be more than one objective per target or
vice versa, there may be several EMPs for a single objective or a number EMPs may help to
achieve a single objective or target. This is especially true in larger more complex organizations
and those where management has decided to use a combination of enhancements to existing
programs and new programs to achieve the objectives and targets.
Organizations often do not have a formal procedure on how to develop EMPs but rather use
some subset of the guidance and hints noted in this section with a format for outlining the
primary components of the EMP. This allows the EMPs to vary in level of detail as appropriate.
Figure 5-1 provides a format to demonstrate the connection between significant aspect, objective,
target, EMP and operational controls. Figure 5-2 provides a simplified EMP format.
Figure 5-1: Sample Environmental Management Program Form (121)
(Note: Use one form per EMP)
Date Individual Responsible:
( / / )
Environmental Objective(s):
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)
Page 5-4 of 21
-------
EMS Implementation Guide for the Meat Processing Industry
Module 5: Environmental Management Programs (EMPs)
Figure 5-2: Environmental Management Program - Sample Tool (122)
Objective / Target #1:
Action
Items
Priority
Responsibilities
Schedule
Resources
Needed
Comments
Evaluating Alternatives
In the development of strategies to reduce the impacts associated with your environmental
aspects, it is necessary to evaluate alternatives for material substitution. The following is a
summary of a detailed approach to material substitution provided in EPA's Integrated
Environmental Management System Guide EPA 744-R-00-011, available at
http://www.epa.gOv/opptintr/library/ppicdist.htm#DfE. Evaluation of materials for substitution
can help you achieve both environmental and economic advantages.
For the Meat Processing Sector the best opportunities for alternatives may be in materials used to
process, handle, store, and treat residuals associated with the primary process.
Alternative evaluation consists of the following steps:
• Define the baseline by understanding the current chemical, activity or technology that is
the source of the environmental aspect;
• Define the function of the activity with which the aspect is associated;
• Develop a list of alternatives by asking how could this function be accomplished in other
ways:
Substitute products;
Reduced product use through technology changes and improved work practices;
Improve treatment technologies; and
Improve disposal technologies.
• Decide how detailed an evaluation of the alternatives is feasible (economically,
practically, and will regulations allow the evaluation);
• Evaluate the changes in impacts associated with the alternatives;
• Evaluate how well the alternatives perform;
• Tract regulatory changes are associated with implementing the alternatives;
• Evaluate the economic advantages and disadvantages of each alternative (short and long
term); and
• Look at all of the information above and make an informed decision.
Page 5-5 of 21
-------
EMS Implementation Guide for the Meat Processing Industry
Module 5: Environmental Management Programs (EMPs)
This type of detailed examination of alternatives will not be practical for all issues at your plant,
but you should consider this type of approach where the solution is not immediately evident, a
major process change is being contemplated, or major capital expenditures are being
contemplated.
Attachment 5-A provides an example procedure for conducting an Alternatives Evaluation.
Operational Controls
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, operational controls should be considered. (53)
An operational control:
refers to those documented procedures that can help your plant manage its significant
environmental aspects, ensure regulatory compliance, and achieve environmental objectives
and targets. (53)
Procedures should be established for operation or activities where their absence 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 procedures and how those operations should be controlled is a critical step
in designing an effective EMS. Keep in mind that you may need operational controls in order to
manage some aspects, regardless of whether you established objectives and targets for each of
them. (53) Some of these already exist as part of your existing EMPs.
Rule of thumb for documenting operational controls: If experience has shown that someone in
your plant needed to write it down to be sure that it was done correctly, or in order to teach or
show someone new how to effectively ensure the control worked, then you should consider
creating a documented procedure. Conversely, do not start generating procedures for the sake of
having them if they do not add value to your EMS.
In determining which operations and activities need to be controlled, look beyond routine
production or services. Activities such as equipment maintenance, management of on-site
contractors, and services provided by suppliers or vendors could affect your plant's
environmental performance. (53)
Your plant should have operation and maintenance programs for equipment and for other
operations that are related to legal compliance and significant environmental aspects.
HACCP Principle III: Establish Critical Limits for each Critical Control Point (CCP). This may
prove a useful building block for the development of environmental operational controls. The
CCPs are typically either an upper limit that is not to be exceeded or a specified performance
range. This type of control can also be a requirement for environmental concerns. Just setting a
limit in itself does not however ensure that it will be met. The steps your plant takes (e.g.,
equipment, and proactive measures) to meet these limits are the controls.
Page 5-6 of 21
-------
EMS Implementation Guide for the Meat Processing Industry
Module 5: Environmental Management Programs (EMPs)
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. (53)
Examples of activities and operations that might require operational controls:
• Management / disposal of wastes;
• Approval of new chemicals;
• Storage & handling of raw materials and chemicals;
• Equipment servicing; or
• Wastewater treatment. (53)
Attachment 5-B provides a sample procedure describing how to develop operational controls.
A useful tool for understanding the root causes of impacts (and therefore assists in developing
the best operational controls) is the root cause diagram (also known as a fishbone diagram). The
root cause diagram, shown in Figure 5-3, will help you organize your thinking when you analyze
the potential for an environmental impact. This analysis can be done by one person or by a
group, with one person writing down the ideas. Each diagonal line represents a main
component of the production process. Your plant may have different or additional components
(for example, "disposal") beyond those represented here. Each horizontal line stemming from
the diagonal represents an important element contributing to each of the main components. For
example, elements of work practices might contribute to the labor component. This diagram is
simply a device to help organize the analysis of the cause of potential environmental impacts.
Use it if it helps, but don't get hung up on trying to make it work. Root cause diagrams will also
be discussed in Module 8 of this guide.
Hint: Review procedures you already have in place to comply with environmental regulations.
Some of these may be adequate to control significant aspects (or could be modified to do so).
Develop a chart to keep track of what controls are needed, such as:
Operation or
Activity
Procedure is needed
(none exists)
Procedure exists, but
is not documented
Procedure exists
and is documented
No procedure is
needed
X
X
X
X
Page 5-7 of 21
-------
EMS Implementation Guide for the Meat Processing Industry
Module 5: Environmental Management Programs (EMPs)
Figure 5-3: Root Cause Diagram
t
c
0
CO
_£=
l_
o
o
Q_
E
CD
c
ii
0)
3
.Q
C
0
c
"i_
C
Ci
c
o
o
Q_
03
o
E
c
o
c
0
o
o
%N
"C
E
c
o
0
"(0
a:
0
E
1/
O /
10
m
c
8)
"35
o
A
O
o
c
(0
c
o
(0
m
Page 5-8 of 21
-------
EMS Implementation Guide for the Meat Processing Industry
Module 5: Environmental Management Programs (EMPs)
Rules of thumb: In general, the more highly skilled and trained your employees are, the less
critical documented work instructions are. As work becomes more complex, or as the potential
impact on the environment increases, the more important the documented work instruction
becomes.
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 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. (54)
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.
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 plant uses a "work team" concept, ask the work teams to draft procedures for their work
areas (or to modify existing procedures for EMS purposes). (55)
Once you have identified operations that require control it is necessary to consider what kinds of
monitoring and measurement are needed.
Monitoring and \I easurement
Monitoring and measurement is necessary in order to gauge progress in meeting your objectives
and targets. In general, 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 e fficiency. (60)
In short, monitoring helps you manage your plant better. Monitoring and measurement
procedures should be developed to:
Factors that could affect the
need for documented
procedures:
• Risk of activity
• Complexity of
activity/method
• Degree of supervision
• Skills/training of
workforce (54)
Page 5-9 of 21
-------
EMS Implementation Guide for the Meat Processing Industry
Module 5: Environmental Management Programs (EMPs)
• Track performance in achieving objectives and targets;
• Monitor the environmental critical control points (the environmental equivalent of
monitoring CCPs for HACCP);
• Calibrate and maintain monitoring equipment; and
• Through internal audits, periodically evaluate your compliance with applicable laws and
regulations. (60)
This discussion on monitoring and measurement focuses on these activities as they relate to
being a part of EMPs and operational controls. Monitoring and measurement of the EMS in
general is discussed further in Module 8 of this guide.
Monitoring and measuring can be a resource-intensive effort. One of the most important steps
you can take is to clearly define your needs.
You can start with a relatively simple monitoring and measurement process, then build on it as
you gain experience with your EMS. (60)
Hints: 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 wastes generated or the number of spills that took place. Process measures look at
"upstream" factors, such as the amount of packaging material 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 plant.
Equipment calibration: Identify process equipment and activities that truly affect your
environmental performance. 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. One example might be the calibration of wastewater monitoring
equipment.
Operational performance: Consider what information you will need to determine if your
plant is implementing operational controls as intended. (61)
Satisfying HACCP Principle IV: Establish Monitoring Procedures is a good example of
monitoring and measurement directly linked to operational controls. Your HACCP monitoring
of CCPs should be designed to allow your plant to know if you are operating within the
parameters you have established. You may wish to examine F the lessons you have learned
(i.e., how often you must measure to get the performance you desire) in implementing HACCP
can be applied to your EMS in this area.
Page 5-10 of 21
-------
EMS Implementation Guide for the Meat Processing Industry
Module 5: Environmental Management Programs (EMPs)
Homework
Your homework is to develop new EMPs where required and modify or expand existing EMPs
to detail how objectives and targets will be met.
You are also asked to determine what operational controls and process monitoring and
measurements are needed in order to meet the objectives and targets.
Remember create formal and written procedures where they improve the performance of your
EMS but avoid building a paperwork empire.
Page 5-11 of 21
-------
EMS Implementation Guide for the Meat Processing Industry
Module 5: Environmental Management Programs (EMPs)
Attachment 5-A: Conducting an Alternatives Evaluation
I. Purpose
ABC Meat Processing periodically conducts an alternatives evaluation to identify viable
approaches to reaching an environmental objective. An alternatives evaluation is a tool for
identifying alternative products and/or processes and evaluating them compared to the baseline
based on business and environmental criteria.
II. Procedure
1. The EMS coordinator appoints a small group, overseen by a committee member or by
the relevant operations manager, to identify and evaluate alternatives to a particular
activity or process where an alternatives evaluation is required for meeting an
environmental objective.
2. The group first identifies the function that this activity or process performs in ABC
Meat Processing's operations. The group also characterizes the baseline, or the
current manner in which the function is being carried out.
3. The group then brainstorms alternative ways of accomplishing this function.
Potential alternatives include using a different material or chemical, changing work
practices, and/or changing process technologies. Alternatives are recorded using
format AE-01 and the most promising alternatives are assigned to individual
members of the group for further research.
4. The group then evaluates the baseline and alternatives based on the following
considerations: operational performance, cost, regulatory implications, and
environmental impact. The group uses formats AE-02 to record its findings (and
formats AE-03 to AE-06, as needed).
5. The group makes a recommendation and presents its recommendation to the EMS
committee and appropriate operations managers.
III. Frequency
As often as necessary in the context of developing targets and action plans to meet
environmental objectives.
IV. Records
Formats AE-01 (Alternatives Identification) and AE-02 (Evaluation of Alternatives) are
maintained by the EMS coordinator, as well as AE-03 to AE-06 to provide, as necessary,
supporting documentation.
Page 5-12 of 21
-------
EMS Implementation Guide for the Meat Processing Industry
Module 5: Environmental Management Programs (EMPs)
AE-01: Alternatives Identification
Significant Environmental Aspect(s):
Function:
Baseline
Potential Alternatives
Products
Technologies
Work Practices
Recycling/Reuse
Treatment
Disposal
Contact Person:
Date Completed:
Page 5-13 of 21
-------
EMS Implementation Guide for the Meat Processing Industry
Module 5: Environmental Management Programs (EMPs)
AE-02: Evaluation of Alternatives
Significant Environmental Aspect(s):
Function:
Alternative
Performance
Regulatory
Considerations
Cost
Environmental Effects
Overall Evaluation
Baseline
Contact Person: Date Completed:
Page 5-14 of 21
-------
EMS Implementation Guide for the Meat Processing Industry
Module 5: Environmental Management Programs (EMPs)
AE-03: Evaluation of Environmental Effects
Significant Environmental Aspect(s):
Function:
Alternative
Regulatory
Concern
Worker Safety
Other Community
Issues
Natural Resources
Overall Ranking
Preferred
Alternative? (Y/N)
Baseline
Contact Person: Date Completed:
Page 5-15 of 21
-------
EMS Implementation Guide for the Meat Processing Industry
Module 5: Environmental Management Programs (EMPs)
AE-04: Evaluation of Performance
Significant Environmental Aspect(s):
Function:
Alternative
Mow Well it Works
Time
Ease of Use
Overall Performance
Evaluation
Baseline
Contact Person: Date Completed:
Page 5-16 of 21
-------
EMS Implementation Guide for the Meat Processing Industry
Module 5: Environmental Management Programs (EMPs)
AE-05: Evaluation of Regulatory Concerns
Significant Environmental Aspect(s):
Function:
Alternative
Applicable Regulations
Required Controls
Cost of Compliance
Overall Regulatory Concerns
Evaluation
Baseline
Contact Person: Date Completed:
Page 5-17 of 21
-------
EMS Implementation Guide for the Meat Processing Industry
Module 5: Environmental Management Programs (EMPs)
AE-06: Evaluation of Costs
Significant Environmental Aspect(s):
Function:
Alternative
Raw Material
Labor
Disposal
Total Cost
Savings
Net Cost
Baseline
Contact Person: Date Completed:
Page 5-18 of 21
-------
EMS Implementation Guide for the Meat Processing Industry
Module 5: Environmental Management Programs (EMPs)
Attachment 5-B: Development of Operational Controls
I. Purpose
By developing operational control procedures for critical activities (i.e., those activities
associated with significant environmental aspects), ABC Meat Processing intends to mitigate and
control, to the extent possible, the environmental impacts associated with its significant
environmental aspects.
II. Procedure
1. The EMS committee, with additional input from other employees as needed, carries
out a root cause analysis of each significant environmental aspect to determine the
underlying cause(s) of the environmental impact. As part of the root cause analysis,
the committee will determine the need for (and adequacy of, if already existing)
operational control procedures to control the critical activities related to the
significant environmental aspects in question and record its findings on format OC-
01. The committee, with input from operations managers, will also select one or
more indicators per significant environmental aspect for purposes of monitoring ABC
Meat Processing environmental performance.
2. Where there is a need to create or modify an operational control procedure, the EMS
committee assigns a member of the committee to draft an operational control
procedure, based on consultation with the employees who undertake that procedure.
In many cases, a separate operational control procedure may not be required, rather
environmental control procedures can be integrated into an existing procedure. The
operational control procedure should take the form of a "Work Instruction," namely a
summary list of required steps or measures. In addition to describing the steps
necessary to carry out the particular activity in an environmentally sound manner, the
work instruction should also include steps to conduct monitoring, where applicable.
3. After the operational control procedure has been developed and implemented, its
status is recorded as such on format OC-01. The procedure itself enters into the
relevant ABC Meat Processing operator's handbook and/or is posted at the site of the
activity in question.
III. Frequency
As new significant environmental aspects are identified and for existing significant
environmental aspects, a review of the associated root cause analysis and operational control
procedures is conducted yearly.
Page 5-19 of 21
-------
EMS Implementation Guide for the Meat Processing Industry
Module 5: Environmental Management Programs (EMPs)
IV. Records
Format OC-Ol (EMS Operational Control Procedures) is maintained by the EMS coordinator.
The procedures themselves are maintained in the relevant Meat Processing operator's handbook
and/or posted at the site of the activity in question.
Page 5-20 of 21
-------
EMS Implementation Guide for the Meat Processing Industry
Module 5: Environmental Management Programs (EMPs)
OC-Ol: EMS Operational Control Procedures
Significant
Environmental
Aspects
Indicator(s)
Associated Job
Functions
Existing Operational
Control Procedures
Operational Control Procedure
Development / Modi Ilea lion
Needed
Responsible /
Status
Location
Posted
Contact Person: Date Completed:
Page 5-21 of 21
-------
Environmental
Management System
(EMS) Implementation
Guide for the
Meat Processing Industry
Module 6: Supporting EMS Elements
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
Table of Contents
Introduction 6-2
Structure and Responsibility 6-2
Environmental Training Needs 6-5
Training Program 6-7
Communication Programs 6-9
Working with Stakeholders 6-12
Homework 6-15
Attachment 6-A: Example Organizational Chart 6-16
Attachment 6-B: Matrix of Accountabilities 6-17
Attachment 6-C: Procedure for Environmental Training (Awareness and Task-Specific)... 6-20
Attachment 6-D: Procedure for Communication with Stakeholders 6-23
List of Figures
Figure 6-1: Graphic Representation of EMS Implementation 6-3
Figure 6-2: Internal Versus External Communication 6-10
Figure 6-3: Levels of Stakeholder Interest 6-14
Page 6-1 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
Introduction
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. 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). Resources might include, for example, human resources, specialized skills,
technology and financial resources.1
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 h 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. (35)
More organizational advantages of small business:
• Shorter lines of communication;
• Less complex organization;
• Limited delegation; and
• Simpler access to management. (35)
Structure and Responsibility
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.
This section discusses and provides specific examples of processes and methods to consider as
you develop the structure of your EMS and define, document, and communicate roles,
responsibilities, and authorities. Figure 6-1 provides a graphic representation of EMS
implementation.
Roles are required for all personnel or departments who have an involvement with the EMS.
Responsibility details what, when, and how the individual or department interacts with the EMS.
These details provide the basis for auditing the "human" aspects of the EMS performance.
1 NSF International, Environmental Management Systems: An Implementation Guide for Small and Medium-Sized
Organizations (Michigan: NSF International, January 2001) 35. Subsequent references to this document will be
given in parentheses in text.
Page 6-2 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
Authority related to who must and can (if permitted) make decisions. Authority includes general
management and operational authority and includes corrective action and emergency authorities.
All responsibilities should be linked to authorities and reporting structures.
Figure 6-1: Graphic Representation of EMS Implementation
Organization & Capabilities &
Accountability Communication ^
Identify Environmental Tasks and Personnel
Before you can begin assigning roles, responsibilities, and authorities within your EMS, you will
need to identify how each individual's job affects the environment. Conversely if you have
determined that activities need to be performed which have not been assigned, the right people
for the job will need to be assigned and possibly trained (see next section of this Module).
Take time to revisit and review your environmental aspects, legal requirements, objectives and
targets, and environmental management programs and identify required tasks and appropriate
personnel for undertaking the tasks. The important point is that before you can assign
appropriate roles, responsibilities, and authorities for environmental activities, you must first
have a detailed understanding of these activities. This should be easier for the areas identified by
your assessment of existing environmental programs in Module 4.
In fact the process of the 3R's (roles, responsibilities, and resources) should be occurring at the
same time as the objectives, targets, EMPs and operational controls are being developed. These
functions cannot be conducted in isolation but typically occur in an iterative process as options
are explored. Remember that when developing EMPs you need to consider responsibilities,
means (resources) and time frame (which will depend on resources available).
Page 6-3 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
Develop Methods of Defining, Documenting, and Communicating Roles
You need to assign roles, responsibilities, and authority for tasks within the EMS, document
these in some way, and ensure that they are communicated to personnel.
In this case, documented means written, but this does not necessarily mean a text description.
There are a variety of ways in which roles, responsibilities, and authorities can be documented,
and you are free to select any method. Similarly, roles, responsibilities, and authorities can be
communicated in a variety of ways.
Ways in which roles, responsibilities, and authorities in your EMS can be defined, documented,
and communicated may include:
• Organizational charts (see Attachment 6-A);
• Job descriptions (see Attachment 6-B for sample matrix showing accountabilities for
EMS elements); and
• Procedures.
Organizational charts provide the best visual depiction of responsibility and roles. Job
descriptions allow for the greatest level of details and procedures can be used to document them
(see the procedural model in Module 1 Attachment 1-D).
Hint: It is better to define and describe environmental roles and responsibilities by integrating
these with existing roles.
Identify and Track Resource Requirements
The term "resource" is most often used to imply human or financial resources, but there are
many types of resources, which may include equipment, materials, specialized skills, and
facilities.
Ensuring adequate resources for your EMS involves three general steps:
• Identifying resource needs. To identify EMS resource requirements, you will need to
assess the level of effort your plant's current environmental tasks require, the effect of
other plans your firm may have on the EMS, and resources the new pieces resulting from
implementation will require.
• Preparing a budget that addresses the needs. Most companies formulate resource
budgets covering a one- to five-year period. An EMS budget should include all labor,
capital expenses, and other items (such as specialized consultants) required to implement
your EMS.
• Tracking EMS costs on an ongoing basis to ensure that resources continue to ©fleet
current needs.
Page 6-4 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
By evaluating such information, you can develop a clear understanding of the time and resources
required for tasks within your EMS.
Hint: Be sure to identify resource requirements and track resources using existing systems in
your plant. Look at how other project resources get assigned and use the existing processes as
your starting point. You may need to add more detail in order to help management understand
what resources are required or how they have been used.
Ensure That a Management Representative Is Appointed
An effective management system needs an advocate. Thus, top management should appoint a
management representative and possibly an EMS Core Team as discussed in Module 2 of this
Guide.
This representative:
• Ensures that the EMS is established and implemented;
• Reports on its performance over time; and
• Works with others to modify the EMS as needed. (35)
The management representative can be the same person who serves as the project champion, 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. (35)
One of the most important considerations in establishing a workable and effective organizational
structure for your EMS is to build appropriate incentives into the system. To this end, you
should consider using environmental performance as an objective in employee performance
reviews. Environmental objectives should be based on the degree to which each employee's job
responsibilities affect the environment.
Employees with jobs that directly impact the environment, such as waste disposal, should be
reviewed, in part, based on the manner in which they ensured that those activities were carried
out in a responsible way (ie., wastes were disposed of in a manner having a minimal impact on
the environment). Employees in jobs with less environmental impact should be reviewed, in
part, based on the organization's achievement of the established environmental objectives and
targets.
The ultimate decision on whether to incorporate environmental performance in overall
performance reviews will most likely be made by the top management of your plant; however,
this is an important part of an EMS, and you should encourage top management to adopt such a
practice.
Environmental Training Needs
Environmental performance among employees can be directly linked to environmental training.
Training of employees about environmental management and your EMS is needed because:
Page 6-5 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
• Every employee can have potential impacts on the environment; and
• Any employee can have good ideas about how to improve environmental management
efforts. (39)
Each person and function within your plant 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 should also understand the
potential consequences of not following EMS requirements (such as spills, releases, fines or
other penalties). (39)
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. (39)
A recommended approach to defining environmental related training needs and establishing a
training program is described below.
Needs Analysis
The first step in setting up a training program is to conduct a training / skills needs analysis.
The goal of this needs analysis is to establish a clear understanding of who in your plant requires
training, what type(s) of training they need, and the skill sets required. 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?"). (39) The skill level can also be referred to as the competence level of the
individual.
Look at the training you conduct already, for compliance with environmental, health, safety,
and food safety regulations. 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. (39)
Establishing who requires EMS awareness training should be fairly simple, as everyone in your
plant must have a very basic awareness of the EMS. Therefore, all personnel at your plant
should receive EMS awareness training. The intensity and level of detail of awareness training
may vary by type of position. Your plant may wish to have a basic level of awareness training
for all staff (perhaps as little as 15 to 30 minutes of general introductory training) to be followed
by specific individual training, if appropriate.
Page 6-6 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
To identify job-specific training needs, you should focus on identification of job titles or roles
associated with:
• Any new procedures or needs related to significant environmental aspects;
• Those whose jobs and responsibilities involve awareness of the environmental policy and
activities directly related to achieving objectives and targets;
• Those whose jobs and responsibilities involve activities directly related to compliance
with leg^l requirements;
• Ability to recognize new problems;
• Technical work needed to solve problems; and
• Assignments of responsibility within the EMS itself.
Note: Be aware that you probably will not be able to identify all your EMS training requirements
until you have worked through all the modules.
For general positions in your plant you may determine that there are no prerequisite
environmentally related skills required. For some specialized areas, you may determine that a
prerequisite skill level that your plant is not equipped to provide is needed. In such cases, the job
may be contracted out, for example, maintenance of specialized water monitoring equipment.
Training Program
Effective training does not just happen - it must be planned and carried out consistently and
correctly. Once the training requirements have been specified, the next step is to plan the
training needed by employees at your plant.
Your first step in implementing your EMS training should be to develop a training plan. A
training plan serves as a "procedure" that describes the way EMS training is managed at your
plant. See Attachment 6-C for an example.
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) (40)
Page 6-7 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
Training Resources
• Internal trainers / experts;
• Consultants;
• Trade associations;
• Community colleges;
• Vendors / suppliers;
• EPA materials;
• State regulatory agencies;
• Customers;
• Technical associations;
• Self-study or study groups;
• Training consortia (teaming with other local companies); and
• Computer-based training. (40)
Employee Competency
You have the responsibility, as part of your EMS, to develop an approach to judge the
competence of employees to accomplish their assigned tasks. For example: The required level
of competency for the general workforce on the meat processing production line may be
accomplished by ensuring they are capable of reading and understand the warning signs
regarding waste diversion and wash down practices. Competency requirements for a line
foreman might include an understanding of the need to limit wash down of debris into the sewer
due to sewer use restrictions. This level of competency could be demonstrated as part of his
training program and periodic training updates. Some firms use combined health, safety and
environment meetings as an avenue to do 10-minute refresher talks on a variety of related topics.
The greater the employee's level of responsibility for ensuring that your EMPs are a success, the
higher the level of training and competency you should strive for with that employee.
When evaluation and 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 introduced;
• Plant changes objectives and / or targets;
• New regulations affects organization's activities; and
• Job performance must be improved. (41)
Your overall goal for your training program is to produce knowledgeable, skilled, and aware
employees who assist your plant in achieving its stated goals and objectives.
Page 6-8 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
Communication Programs
The importance of employee involvement in developing and implementing your EMS has been
discussed earlier, h addition, there may be parties with an interest in your environmental
performance and management efforts outside the plant. It is particularly important to
communicate with the community in which you operate. Effective environmental management
requires effective communications, both internally and externally. (43)
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;
• Improve your relationship with the community;
• Monitor and evaluate performance; and
• Identify potential system improvements. (43)
An effective EMS should include procedures/ processes for:
• Communicating internally (between levels and functions within the organization);
• Soliciting, receiving, documenting and responding to external communications; (43) and
• Working with stakeholders.
In order to develop effective procedures for internal and external communication, it is useful to
have an understanding of what is encompassed by the terms "internal communication" and
"external communication" and what the ultimate goal is of such procedures; see Figure 6-2.
Internal Communication
Internal communication refers to all communications within the organization between different
levels and functions (see Figure 6-2).
The goals of internal communication are to:
• Make employees aware of the environmental policy and any other environmentally
related procedures necessary to conduct their work;
• Inform employees about the overall performance of the EMS;
• Provide employees with an opportunity and mechanism to voice their concerns about
environmental issues; and
• Report back t) employees on the results of EMS monitoring, audit, and management
reviews.
Page 6-9 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
Figure 6-2: Internal Versus External Communication
Management
A
<
Complaints or
queries
el
Lateral
3
3
o
Environmental
and
Affected
Parties
statement or event
> f
Operations
J
Internal Communication
External Communication
The key to achieving the goals of internal communication in an EMS is to develop a two-way
communication pathway - "top down" communication from top management, and "bottom-up"
communication from line workers who collectively have the greatest ability to effect
environmental issues at the organization.
Effective internal communication will help to:
• Motivate your workforce in EMS implementation;
• Gain acceptance for EMS plans and efforts;
• Explain the environmental policy and EMS;
• Ensure understanding of roles and responsibilities in EMS implementation;
• Demonstrate top management commitment to EMS;
• Monitor and evaluate performance of EMS; and
• Identify areas of improvement.
External Communication
External communication broadly refers to any communication between an organization and
external interested parties regarding environmental issues at the organization (see Figure 6-2).
Interested parties could include regulators, customers, suppliers, vendors, public interest groups,
and neighbors.
A requirement of the National Environmental Performance Track program is to proactively
communicate with your community about your plants environmental performance. It is highly
encouraged that you take a proactive approach in communicating with your community, however
Page 6-10 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
"communication" from external interested parties may typically be in the form of inquiries. The
inquiries could be from regulators in the form of a letter or a site visit, from members of the
general public through a telephone call or letter, or from a stockholder group. For example, an
oil refinery may get inquiries from the public regarding odors that occur at certain times of the
day.
An external communication procedure should focus on the following items:
• How your plant will receive, document, and respond to communication from external
interested parties; and
• How to inform community members of important matters that affect them.
Your external communications procedures should strive to ensure that:
• Only correct information is sent out to external parties;
• The information has been appropriately reviewed; and
• The information is delivered by appropriately trained and qualified staff.
Effective external communication will help to:
• Improve relationships with stakeholders;
• Demonstrate due diligence; and
• Build trust in the community.
Begin early in the process
Let people know what you are doing. In most cases, you will need the cooperation of several
people within your plant to gather information and develop an EMS that will work. In small and
large organizations alike, early communication will pay off in greater acceptance of the EMS.
Set your communication objectives
Decide what you want to achieve in your communication. Setting this goal will help you get the
right message across without overwhelming people with too much information, spending too
much time, or missing the mark. It is helpful to create an EMS communication policy for your
plant. The policy should outline what kinds of information will be communicated to external
stakeholders, and how the plant will document and respond to communications from these
stakeholders. In addition, the procedure should discuss how the plant would report
environmental incidents, such as spills, accidents and "near misses". The procedure should
include who reports what, to whom, and when. Small and medium-sized businesses may not
need a written procedure for communication.
Communicate regularly and integrate EMS communication
To build support for the EMS, try to communicate on a regular basis. Some simple means of
regular communication can usually be accomplished without straining resources - for example, a
Page 6-11 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
bulletin board posting, email messages, or articles in the organization newsletter. Don't forget to
consider direct word-of-mouth communication, particularly in smaller organizations. Talking
directly with key individuals at intervals may be the best mechanism for ensuring good
communication. Use existing channels of communication to get the message out on your EMS
activities.
Examples of methods for communicating both internally and externally are given below.
Internal Methods:
External Methods:
• Newsletters
• Open houses
• Intranet
• Focus or advisory groups
• Staff meetings
• Web site or e-mail list
• Employee meetings
• Press releases
• Bulletin boards
• Annual reports
• Brown bag lunches
• Advertising
• Training
• Informal discussions
• Signs
• Attending community meetings (44)
Working with Stakeholders
Stakeholders are anyone who has an interest in your company's environmental performance.
Stakeholders can play an important role in helping your plant develop an EMS. Employees have
strong stakeholder interest in your plant and can provide strong support for EMS development.
Customers, suppliers, and neighbors can provide useful input. In addition, establishing
partnerships with trade associations, suppliers, professional associations, and community
colleges can be very helpful in developing parts of your EMS. This section addresses the kind of
stakeholders you may wish to include in the process and the potential benefits of including
stakeholders. While involvement of employees is critical to the success of your EMS, how far
you proceed with including additional stakeholders is your decision.
Note: Active stakeholder involvement programs are an EMS option that some companies find
highly beneficial to undertake. The decision to whether your plant will engage in active
stakeholder involvement is one that your management should consider by evaluating if it makes
sense for you. If the decision is to not engage in such a program then record the rationale for the
decision so that if conditions change, re-evaluation will be less complex.
Stakeholder Roles
Consider why you would want to include internal and external stakeholders and what roles they
can play. Before engaging stakeholders, be clear on what you expect their role to be. What do
you want from them? What do you intend to tell them? Would you be able to produce a list of
community/local references that are familiar with your plant? Do you have a list of current or
ongoing citizen concerns with your plant? What forms of reporting on the performance of your
EMS and your other performance commitments will you make available to various stakeholders?
Page 6-12 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
Consider the following:
• Internal stakeholder (e.g., employee) participation can facilitate implementation of
environmental projects as employees "take ownership" of the EMS process and the
process changes it may bring.
• Different stakeholders bring useful perspectives identifying environmental issues, often
identifying issues that might otherwise have been overlooked.
• Participation by all types of stakeholders can add credibility, transparency and value to
your EMS.
• Involving external stakeholders can help them understand your business operating
constraints.
• Sometimes being an environmental leader can help you giin customer recognition and
loyalty, and involving customers in your EMS helps them recognize your leadership.
• Forming partnerships with customers and suppliers can help to identify shared concerns
and ways to cooperate to resolve them. There may be ways that your company can help
your customers meet their environmental management needs. Forming partnerships with
suppliers can help your company obtain important information and may help you meet
your EMS goals.
Identifying Stakeholders
Almost every organization will have a wide array of internal and external groups that may be
interested in and helpful partners to that organization. These groups will not be homogenous.
Each will have its own priorities and perspectives, and each will have something different to
contribute in support of your EMS.
The following list provides types of stakeholders:
Internal Stakeholders
External Stakeholders
• Employees
• Neighbors
• Shareholders
• Community organizations
• Customers
• Environmental groups
• Suppliers
• Larger companies
• Investors & insurers
• The media
• Trading partners
• Local government
• Corporate HQ
• Regulators
Page 6-13 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
You may want to start with those stakeholders who have expressed interest in your operations. If
you wish additional input, you can contact the following sources in your effort to locate suitable
stakeholders:
• Ask your plant's own employees, including plant/site managers and public relations
personnel;
• Contact local officials for suggestions; and / or
• Contact local schools, community colleges, or universities; or contact a national
advocacy group to elicit suggestions as to which local or national groups may be
interested / suitable.
How to Work With Your Stakeholders
The next stage of the process is to establish dialogue with stakeholders. You may view this as an
opportunity to further refine your understanding of the various interests of the groups.
Develop stakeholder participation in stages and learn as you go. You might think about the
different kinds of stakeholders as forming ever-broader circles around your business (see Figure
6-3). Begin with the innermost circle and work outward.
Consider various methods of communication when informing stakeholders about your plant and
what you are doing, or plan to do, to protect the environment. Methods may include:
• Discussion in company meetings;
• Company web site;
• Producing a fact sheet about your plant's activities, the EMS program, and why and how
your company would like to include stakeholders;
• Establishing a phone line to answer questions, record concerns, etc.;
• Going to local schools, community colleges, universities, or civic organizations, such as
the Rotary, that may provide a focal point of interest about your plant; and
Figure 6-3: Levels of Stakeholder Interest
Page 6-14 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
• Holding public meetings when you feel it is appropriate.
Ensure That Stakeholder Dialogue is a Two Way Process
The stakeholders will want to know that their comments and concerns are being listened to and
taken into account. You need to convey that your plant is genuinely and actively including them.
A sample template which may be used to identify and keep track of stakeholders, their potential
interests, information needed to communicate to them, and the method of communication is
included in the sample stakeholder procedure in Attachment 6-D.
Point of Contact
In dealing with and managing feedback from these external parties, each plant should also
designate a point of contact who has direct assess to plant management and who can effectively
response and react to an inquiry from the public. When any form of communication is received
from the plant regarding environmental performance or management from an external party
member, that communication should be immediately forwarded to the contact person. This
individual will then consider the nature of the communication and make a decision on whether
and how to respond to the communication.
Homework
Your homework is to document roles, responsibilities and resources for your plant and ensure
that those with 3R functions are aware of them.
You should conduct a review of training needs based on both existing and environmental
activities in the plant and any new or planned activities associated with implementation of the
EMS. Where new or modified training is needed, define what is needed to ensure this occurs.
Define both formal and informal internal communication processes and note desired outcomes
from forms of communication. Also define external communication including proactive
programs such as community and stakeholder involvement.
Page 6-15 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
Attachment 6-A: Example Organizational Chart
Page 6-16 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
Attachment 6-B: Matrix of Accountabilities
EMS Reference
Title
EMS Manual Sec (ion Number & Tide
Accounlahilily
A-l. Index
• None assigned
A-2. Introduction
• Maintain Section: EMS Representative
A-3. EMS Scope
• Define Scope & Applicability: Core team
• Maintain Section: EMS Representative
A-4. EMS Manual Distribution
• Maintain Section & Distribute Manual: EMS Representative
A-5. EMS Manual Record of Revis ions
• Maintain Section & Review Manual: EMS Representative
Environmental
policy
B-l. Corporate Sustainable Energy
Development Policy and Principles
• Approve/Issue Environmental Policy: Chairman, CEO
• Comply with Policy: all staff
• Maintain Section: EMS Representative
B-1. Environmental Policy
• Approve/Issue Policy: Executive VP
• Comply with Policy: all staff
• Maintain Section: EMS Representative
Environmental
aspects
B-2. Identifying Environmental Aspects
• Establish/Maintain/Implement Process at Director Environmental Affairs
B-2. Determining Significant Environmental
Aspects
• Maintain/Apply Process & Develop/Maintain EMS Aspects Database:
Director Environmental Affairs, EMS Representative
• Division Input to EMS Aspects database: EMS Representatives, Divisions.
Legal and other
requirements
B-3. Interpreting Legal Requirements
• Implement & Maintain Process: VP, Regulatory Affairs
B-3. Interpreting Other Requirements
• Implement & Maintain Process: VP, Regulatory Affairs
• Maintain this Section: EMS Representative
Objectives and
targets
B-4. Developing Objectives and Targets
• Develop Objectives & Targets, Division Directors and EMS Core Team,
Director Environmental Affairs
• Approve Objectives & Targets: VP Operations
• Meet Objectives & Targets: Directors
• Maintain Section: EMS Representative
Environmental
management
programs
B-5 Environmental Programs
• Approve Programs Division Directors
• Develop and Maintain Programs: Director Environmental Affairs
• Maintain this Section: EMS Representative
Structure and
responsibility
C-l. Structure and Responsibility - Assigning
EMS Accountabilities
• Assign EMS Accountabilities: EVP
• Assign EMS Representatives: Director Environmental Affairs
• Co-ordinate EMS Planning & Strategy: Director Environmental Affairs
• Maintain this Section: EMS Representative
Page 6-17 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
EMS Reference
Title
EIVIS Manual Section Number & Title
Accountability
Training,
awareness and
competence
C-2. Training
• Setting of Environmental Training Standards, & Establishing Env. Training
Requirements: Training Support & Services
• Staff Environmental Training: VP Operations
• Record Performance: Immediate Supervisors
• Maintain Records: Human Resources
• Maintain Section: EMS Representative
• Develop Training Program - Director Environmental Affairs
Communication
C-3. Internal Communications and Reporting
• Internal Communications & Reporting: VPs, Directors
• Maintain Section: EMS Representative
C-3. External Communications and Reporting
and Public Outreach
• Implement and Maintaining the Process: EMS Representative
• Public Outreach: Director Environmental Affairs
• Maintain this Section: EMS Representative
Environmental
management
system
documentation
C-4. EMS Documentation
• Maintain this Section & EMS Manual: EMS Representative
Document control
C-5. Document Control
• Electronic & Paper Document Management: Clerical & Records Supervisor
• Maintain Electronic Documents: Intranet Administrator
• Prepare/Approve EMS Control Documents: VP Operations
• Maintain this Section: EMS Representative
Operational
control
C-6. Operational Controls
• Maintain Section: EMS Representative
• Establish, Approve & Maintain Operational Controls: Director
Environmental Affairs
• Comply with Operational Controls: all relevant staff & contractors
Emergency
preparedness and
response
C-7. Emergency Preparedness and Response
• Establish EPRPs: Directors Environmental Affairs
• Maintain Section: EMS Representative
Monitoring and
measurement
D-1. Monitoring and Measurement Programs
• Establish and Manage Monitoring/Measurement Programs, Director
Environmental Affairs
• Maintain this Section: EMS Representative
Nonconformance
and corrective and
preventive action
D-2. Conformances and Corrective and
Preventive Action
• Establish, Maintain & Implement Management System to Identify
Environmental Requirements and Respond to Non-conformances, etc.:
Director Environmental Affairs
• Maintain this Section: EMS Representative
Records
D-3. Environmental Records
• Maintain Section: EMS Representative
• Maintain Environmental Records: Clerical & Records
Page 6-18 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
EMS Reference
Title
EIVIS Manual Section Number & Title
Accountability
Environmental
management
system audit
And Compliance
Audit
D-4. Internal EMS Audits
• Authorize Internal EMS Audits: EVP
• Establish Process and Conduct EMS Audits, EMS Representative
• Compliance Audit: Director Environmental Affairs
• Maintain Section: EMS Representative
Management
review
D-5. Management Review
• Conduct EMS Management Review: EVP, EMS Core Team
• Conduct NHQ EMS Review; VP Operations
• Participate in Review, Site Reviews, Directors
• Maintain this Section & Provide Information to Review Committee, etc.:
EMS Representative
Page 6-19 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
Attachment 6-C: Procedure for Environmental Training (Awareness and Task-
Specific)
I. Purpose
ABC Meat Processing provides all employees with environmental awareness training on
environmental issues and provides task-specific training to those employees whose jobs are
associated with significant environmental aspects to ensure that its employees carry out their
duties in as environmentally responsible a manner as possible.
II. Procedure
Awareness Training
1. All new employees receive a 15-minute introduction to the ABC Meat Processing's
EMS, specifically its environmental policy, significant environmental aspects, and
environmental objectives. This introduction, which includes an opportunity for the
new employees to ask questions about the EMS, is given by the human resources
(HR) manager as part of general orientation. Records of employees who have
received this training are maintained by the HR department.
Task-Specific Training
1. Using the root cause analysis as a tool the EMS Core Team, working in coordination
with the appropriate operations managers, identifies the job functions that are
associated with each significant environmental aspect.
2. The EMS Core Team, in conjunction with the relevant operations manager, then
determines what training employees performing each of these job functions should
receive in order to control actual environmental impacts to the greatest possible
extent.
3. Operations managers are responsible for ensuring that their employees receive the
appropriate task-specific environmental training. Where possible, environmental
training is integrated with other types of training (e.g., operational) that employees
are receiving. The HR manager keeps records of the training received by each
employee.
4. Training programs include consideration of specific training for those whose jobs and
responsibilities involve activities directly related to achieving objectives and targets,
and those whose jobs and responsibilities involve activities directly related to
compliance with legal requirements.
Page 6-20 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
III. Frequency
Awareness training is given to new employees during their first week at ABC Meat Processing.
Task-specific training is given to relevant employees as they take on a new function that is
associated with a significant environmental aspect. Task-specific training is updated, as
necessary.
IV. Records
Records of the awareness and task-specific training received by each employee are maintained
by the HR manager. The job functions associated with environmentally critical activities (i.e.,
those functions that should receive task-specific training.
The following worksheet provides an example of a training record plan.
Page 6-21 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
Worksheet Training Plan Record
Jobs Affecting Environment
Training Needs
How to Train
When/ Length
Budget
Completion
Date
Who is
Responsible
Sample: Staff EH&S Person
Environmental Policy
Staff Training Session
Once/ Two hrs.
?
?
?
Production Employees
Emergency Preparedness
& Response
Contact Person:
Date Completed:
Page 6-22 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
Attachment 6-D: Procedure for Communication with Stakeholders
I. Purpose
To ensure that interested external stakeholders receive appropriate information about the plant's
environmental activities, ABC Meat Processing has developed a company policy for considering
and, where appropriate, responding to queries, comments, or complaints from stakeholders.
II. Procedure
1. The EMS committee identifies stakeholders and their potential interests in the
environmental performance of ABC Meat Processing using format CS-01,
Stakeholders and Environmental Issues. If the committee decides that proactive
communication on environmental issues is necessary with any group, that decision is
recorded on CS-01 and responsibility is designated.
2. When any form of communication is received regarding ABC Meat Processing's
environmental performance or management from a stakeholder, that communication
is immediately forwarded to the EMS management representative.
3. The EMS management representative considers the nature of the communication and
makes a decision on whether and how to respond to it based on the guidance below
and on the more specific guidance in CS-01. The EMS management representative is
responsible for maintaining records of each such communication and response using
format CS-02, Stakeholder Communication Record. Where internal actions are
necessary to address the communication, this is noted on CS-02 and a Corrective
Action Form is initiated.
III. Guidance for Communicating with Stakeholders on Environmental Issues
ABC Meat Processing's environmental policy is available to all stakeholders upon request. ABC
Meat Processing will do its best, however, to respond in kind to all good-faith communications
from stakeholders about environmental issues, including complaints, comments, and information
requests. However, ABC Meat Processing may not choose to respond in all cases, particularly if
the request is made in bad faith or if sensitive information is requested.
IV. Frequency
As per environmental communication.
V. Records
Records of environmental communications from stakeholders and ABC Meat Corporation
responses are kept by the EMS management representative and are tracked using format CS-02.
An updated version of CS-01, Stakeholders and Environmental Issues, is kept in this manual.
The following worksheet provides a supporting template for recording work with stakeholders.
Page 6-23 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
Working wilh Stakeholders
Your Stakeholders
Potential
Environmental
Interest
What von want
to tell them:
What you want
them to tell you:
IIow to communieale
with/tell them:
When
Person Responsible
(Example) Employees
Environmental
policy
How to get it done
Memo, bulletin board,
meetings, suggestion
box, intranet
(Example) Neighbors
Customers
Environmental
policy and EMS
plans
Environmental
policy and EMS
plans
Their
environmental
concerns
Their
environmental
concerns
Meetings, open house,
flyers, suggestion box,
web site
Above, plus inserts in
direct mail advertising,
or billing, web site
Contact Person:
Date Completed:
Page 6-24 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
CS-01: Stakeholders and Environmental Issues
Stakeholder
Potential Environmental Interest
Proactive Communication Plan
(if desired)
Person Responsible
Contact Person: Date Completed:
Page 6-25 of 26
-------
EMS Implementation Guide for the Meat Processing Industry
Module 6: Supporting EMS Elements
CS-02: Stakeholder Communication Record
Date Communication Received
Type of Communication
Received From
Address/Telephone Number/
Email
Content of Communication (attach copy ifpossible)
Will ABC Meat Processing Respond?
YES NO
Date of Response
Person Responding
Position
Nature of Response (attach copy ifpossible)
Are Internal Actions Necessary? (If Yes, fill out a Corrective Action Form.)
Contact Person:
Date Completed:
Page 6-26 of 26
-------
This page intentionally left blank.
-------
Environmental
Management System
(EMS) Implementation
Guide for the
Meat Processing Industry
Module 7: EMS Documentation and
Records
-------
EMS Implementation Guide for the Meat Processing Industry
Module 7: EMS Documentation and Records
Table of Contents
Introduction 7-2
Document Control 7-5
EMS Records 7-6
Emergency Preparedness and Response 7-11
Homework 7-13
Attachment 7-A: Documentation and Record Keeping 7-14
Attachment 7-B: Emergency Preparedness 7-16
List of Figures
Figure 7-1: Hierarchy of EMS Documentation 7-4
List of Tables
Table 7-1: Documentation of Records 7-9
Table 7-2: Record Control 7-9
Page 7-1 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 7: EMS Documentation and Records
Introduction
When undertaking a new activity like EMS development, documenting discussions, plans,
targets, and programs is crucial. Documentation ensures that no information is lost and lets you
track your plant's performance. Much of this documentation will become the content for your
plant's EMS "Manual" (remember the "Manual" may in fact be a number of separate but related
and coordinated documents). The various sample procedures in this guide and procedural
guidance within the modules of this guide are provided to give you starting points for building
your EMS documentation.
By now you will have already been creating procedures (possibly using the procedural guidance
in Module 1, Attachment 1-D). This module looks at documentation requirements in general for
your EMS.
Documentation is important to the success of your EMS for several reasons:
• Word-of-mouth information is rarely communicated consistently, whereas written
information is more likely to be constant from person to person and over time.
• Creating documentation helps you assess the progress of your EMS. Some
inconsistencies show up only as you commit your ideas to paper, and having a record
allows you to check on progress and evaluate results.
• Documentation is vital to maintaining consistency in an EMS over time and from
department to department. In most companies, change is a fact of life: new products are
developed, the company grows, and employees change positions or leave the company.
Accurate documentation will make it much easier to maintain an effective and flexible
EMS during these changes.
Hint: Think about the pace at which personnel tend to change in your industry and within your
plant. If it is not unreasonable to expect that key individuals associated with an EMS procedure
(determining aspects for example) may change within two EMS cycles (typically organizations
review their EMS annually), then consider formally documenting the procedure.
Conversely, you should not feel compelled to document everything about your EMS. For
example: If you are in a small plant where a lot of procedures are passed on via key workers
effectively apprenticing new workers, a list of the topics that are part of on-the-job training may
be sufficient.
Before discussing procedures on documentation, it is necessary to define what is meant by the
term documentation.
Page 7-2 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 7: EMS Documentation and Records
What is "documentation"?
This term has many different interpretations, and may refer to any or all of the following:
• Instructions for doing something;
• Records of what was done;
• Policies developed;
• Printed materials that are given or sent to clients, regulatory agencies, customers, and the
public; and
• Any electronic copy of the above items.
EMS Manual
An EMS Manual can be a very useful tool since it serves as a "road map" or description that
summarizes how the pieces of the EMS fit together.1
The size and complexity of your EMS documentation will depend on your particular plant. In
general, summarizing the EMS elements will be an easier task at a small plant with very few
significant environmental aspects than at a large plant or one with many significant aspects.
Note: If you used the significance procedure within Module 4 of this Guide, aspects and
associated impacts that are already well managed and in compliance will not necessarily be
considered significant. If in order to achieve this, your plant may have created documentation,
records and formal processes these should become part of your EMS.
Other EMS Documentation
In addition to your EMS "Manual", your plant 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.
EMS procedures offer a place to document:
• Roles, responsibilities and required skills / training;
• Communication requirements; and
• Relationship with other elements (i.e., support, required input).
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. (47)
1 NSF International, Environmental Management Systems: An Implementation Guide for Small and Medium-Sized
Organizations (Michigan: NSF International, January 2001) 47. Subsequent references to this document will be
given in parentheses in text.
Page 7-3 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 7: EMS Documentation and Records
One way to think about your EMS documentation is to use Figure 7-1 below, which also can be
applied to quality or other management system documents. (47)
Figure 7-1: Hierarchy of EMS Documentation
The basic steps in preparing EMS documentation include:
Determine how EMS documentation can be integrated into existing documents. Before you
dive into your documentation, learn how deep the water is. Find out what documentation already
exists, its purpose, and whether it works. The goal of this search is to locate materials you can
use to begin your EMS implementation and documentation. Many companies use the same
format for all their documents. An example of existing documentation might be a quality plan or
tracking reports.
Tailor the documentation to your plant's individual needs. You will probably have to
compromise in producing documentation that meets your needs while also meeting your budget.
Here are some questions to help you determine what fits your needs:
• Does your business operate in a single or multiple locations? This will affect who creates
some of the documents and where they are located. It may also affect how many versions
of a document might be necessary to cover different circumstances.
• What is your current computer capability? Many companies use an electronic system to
maintain documents. This allows them to have only one "original" with all printed copies
being dated when printed and also marked as a copy. This type of system can be
customized to indicate to all users that any printed copy is either for immediate use or
will expire within perhaps 14 days for the printed date.
• What security precautions do you need? As a computer system becomes larger and can
be accessed by more people, electronic information can be edited and destroyed.
Security, or at least restrictions on who can change data, may be a critical issue for many
companies.
Determine a format for all documents. Before developing your EMS documents, plan the
format (document and page appearance) for the documents to be created.
Page 7-4 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 7: EMS Documentation and Records
Note: This does not mean you should not start creating text while you are developing you EMS.
But, until you have defined how to store and organize your documents in the long run,
concentrate on the core content (see Attachment 1-D) of your documents. The basic unformatted
text content of documentation can be moved between most commercial word processing
programs with ease.
If your company has a standard, use it. If not, the need for EMS documentation provides an
opportunity to create a standard company format. Consider margins, header, footer, typefaces,
text, headings, etc. Include plans for bulleted and numbered lists, tables, and even paragraph
spacing. Once you have a consistent format for documents, anyone who writes one will use the
established electronic format and fill in the necessary text. All documents will look like part of
an organized, integrated system. Most important, documents will be easier to read and
understand.
Document Control
Document control means making sure that everyone who works with one of these tools has the
right tools.
People in your plant probably use various documents (procedures, work instructions, forms,
drawings, etc.) as they perform their duties. To ensure that personnel are consistently
performing their jobs in the right way, the plant 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 plant cannot be
sure that people are working with the right tools. (50)
Elements of document control include:
• Revision date / issue;
• Effective date;
• Approval (signature);
• Revision number;
• Document number;
• Copy number; and any
• Cross references.
To ensure that everyone is working with the proper EMS documents, your plant 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 (we make sure people don't use the wrong documents
by mistake). (50)
Page 7-5 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 7: EMS Documentation and Records
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. (50)
Your HACCP processes for document control should serve as a good starting point for this.
Hints:
Don't make your procedure more complicated than it needs to be. While larger organizations
may have complex processes for document control, smaller organizations can use simpler
processes. (51)
Limiting distribution can make the job easier. Could 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. (51)
Do they need to be in multiple languages?
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. (51)
EMS Records
An EMS record is related to (but not the same as) an EMS document. An EMS document
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. (47)
Records do not govern day-to-day operations. A wastewater discharge permit, for instance,
would be considered a document because it describes the tasks (e.g., sampling, reporting, etc.)
required for a plant to stay in compliance. However, the reports that a plant completes and sends
to the regulatory agency, as required by the permit, are records because they are historical data
that demonstrate that the plant is in compliance.
Typical records might include:
• Training records;
• Sampling and monitoring data;
• Calibration records;
• Permit and licenses;
• Job descriptions;
• Audit reports; and
• Management reviews.
Proper management of environmental records is important because such information
demonstrates a plant's efforts to comply with environmental regulations and its actions to reduce
its environmental impacts. Records also provide the necessary information required to track
progress towards objectives and targets.
Page 7-6 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 7: EMS Documentation and Records
The identification and management of environmental records should include consideration of the
following:
To identify all appropriate EMS records at your plant, you should review the various elements of
your EMS and determine what information is generated by each element, and what information
represents critical parts of the design or performance of your EMS.
For each element, you should ask the following key question:
What environmental information do you need to manage effectively?
Note: Be aware that you will not be able to identify all required EMS records until you have
worked through all of the modules of this guide. Even after completing all of the modules you
probably won't be able to sit down and create this list of records on your own in an afternoon.
The process of record identification may take place over several weeks or months, because many
EMS records, particularly those driven by some regulatory requirements, are generated
infrequently, for instance once a year or every two years.
Your EMS records should be properly identified so you can determine what kind of information
they record, and what processes, functions, or procedures to which they relate. At a minimum,
your records should include a name (or title), the date the record was generated, and the name
of the person generating the record. Other features might include a record identification number
or a citation to a procedure or permit from which the record results. A sample template is given
to help you organize existing records and records to be created for your EMS (see Table 7-1).
A key factor in the collection of records is to have a responsible person or "owner" assigned to
each record or type of record. In small facilities, one person may be responsible for all
environmental records. At larger facilities, each type of EMS record may have a different owner
for generation and collection. In developing an effective records maintenance system, you must
also incorporate procedures that cover proper record filing, storage, and access processes, and
protect records from loss.
Your plant should also think about establishing retention times for the records and develop a
disposition system (i.e., procedures to manage the final fate of the records).
A second template is provided as Table 7-2 to help you manage the records used in your EMS.
Note: In developing procedures for both documentation and record keeping, keep in mind the
KISS principle - Keep It Short and Simple. It is easy to get off-track and provide excessive
detail in your EMS documentation; however, the more detailed you make this information, the
more difficult and complicated it will be to update and maintain. Users of documentation find
shorter documents with lists, notes, hints, and graphics easier to understand.
Page 7-7 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 7: EMS Documentation and Records
Attachment 7-A provides a sample procedure for EMS documentation and record keeping.
Note: Establishment of a procedure for the identification, maintenance, retention and disposal of
records related to an EMS may be facilitated by already existing processes, in particular, those
developed under HACCP Principle VI: Establish Record Keeping Procedures. The primary
requirements of HACCP Principle VI are in line with the above requirements for an EMS. One
approach to developing a procedure for EMS record keeping will be to review the records you
already keep for HACCP requirements and see where they are suitable, in their present form or
with minor modifications, to serve the purposes of your EMS system.
Page 7-8 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 7: EMS Documentation and Records
Table 7-1: Documentation of Records
Lis! Existing
Records
Name / Title of the
Record
Date the Record was
Generated
Person
Generating
Record
Citation to a procedure
or permit
Person
Responsible lor
Record
Where Record
Is Located
List Records (<> he
Created
Contact Person: Date Completed:
Table 7-2: Record Control
Name / Title of Record
Who Will Use It
Permanent Location
Periodic Review
Schedule/ Who
When Can Be
Destroyed
Contact Person: Date Completed:
Page 7-9 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 7: EMS Documentation and Records
Examples of what organizations may find that as a minimum they need to document and keep
records of include the following:
• Environmental policy;
• The definition of the scope of the EMS;
• A record of who the members of your EMS core team /committee are, records of their
skills and areas of expertise and training in EMS (if any) they have received;
• The current listing of activities, products and services, the entire list of identified
associated aspects and impacts, and the method/procedure used for identification of these;
• Legal and other requirements;
• Permits, licenses and other approvals;
• Procedure for determination of significance and the basis upon which each aspect was
deemed significant;
• The procedure by which objectives and targets were established and the current
objectives and targets;
• Existing management programs including: method / means, responsibility, performance
indicators, timeframe for the program and approval of the programs by senior
management;
• Records of key communications;
• Management programs for the significant aspects (a brief outline description and notes on
responsibilities, means and timeframes);
• Records of performance relative to specified monitoring and measurement requirements;
• Records of performance relative to objectives and targets;
• Brief summary descriptions of topics to be covered under required training programs;
• Training records of: training courses given, successful completion and when reviews of
training are next required;
• Defined processes for external communication and stakeholder involvement;
• Key EMS roles, responsibilities and resource assignments;
• Records of decisions that the core team has made;
• Records of key decisions made by the EMS representative / coordinator;
• A "roadmap" or summary description of how the core EMS documents are linked and
interact with each other;
• Key contacts and processes to be followed in the event of an emergency;
• A record of the level of public access to the EMS your plant will be providing;
• Hazardous material spill/ other incident reports;
• Monitoring of progress towards objectives and targets;
• How corrective and preventive action needs in general are identified and for those have
been identified the means by which and confirmation that they have been resolved;
• Results of internal environmental compliance assessments and steps taken to resolve
identified issues;
• Results of EMS assessments and steps taken to resolve identified issues; and
• Results of reviews of the EMS by senior management and resulting direction given for
changes in the EMS.
Page 7-10 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 7: EMS Documentation and Records
Note: This is not the "complete list" since the exact list and level of detail associated with many
of the above items is something each plant will determine once its EMS is implemented and will
modify as a part of continual improvement.
Documentation and especially records are the last part in the EMS philosophy of "Say It - Do It
- Prove It". Do your documentation and records allow you to prove it?
Emergency Preparedness and Response
Despite your plant's best efforts to ensure that its EMS and general safety and operational
systems are functioning as designed, 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. (57)
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. (57)
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. (57)
Typical elements of an emergency procedure and phases to be managed include:
• Before
o Identification
o Prevention
o Preparedness
• During
o Priority actions
o Appropriate response
• After
o Recovery
o Review of causes
o Correction and prevention
Page 7-11 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 7: EMS Documentation and Records
Regulatory Requirements
An emergency response plan is required as part of your EMS. The following include some of the
commonly applicable emergency planning requirements under U.S. federal regulations:
• OSHA - Emergency Action Plan
Citation: 29 CFR 1910.38(a);
• OSHA - Fire Prevention Plan
Citation: 29 CFR 1919.38(b);
• OSHA - Hazardous Waste Operations and Emergency Response (HAZWOPER)
Citation: 29 CFR 1910.120;
• Emergency Planning and Community Right-to-Know Act (EPCRA) and EPCRA Release
Reporting
Citation: 40 CFR 355.30; 355.40;
• RCRA—Hazardous Waste Contingency Plan
Citation: 40 CFR 265.50 et. seq. (generators);
• RCRA Preparedness and Prevention Requirements
Citation: 40 CFR 265.30 et. seq. (generators);
• RCRA General Facility Standards
Citation: 40 CFR 262; 265 (generators);
• Clean Water Act (CWA) - Spill Prevention Control and Countermeasure (SPCC) Plan
Citation: 40 CFR 112;
• Superfund Amendments and Reauthorization Act of 1986 (SARA) Hazardous Chemical
Inventory Reporting
Citation: 40 CFR 370;
• CWA Spill Reporting
Citation: 40 CFR 110; 117;
• CERCLA Spill Reporting
Citation: 40 CFR 302; and
• CWA Best Management Practices (BMPs)
Citation: 40 CFR 125.
Typically an organization should consider regulatory, legislative, and other requirements for:
• Environment;
• Environment-related health and safety;
• Hazardous materials and materials handling;
• Transportation of dangerous goods;
• Water and energy;
• Spills; and
• Fire and building codes.
Existing emergency response plans can be incorporated into your EMS. Review your existing
plan to ensure that it meets the requirements for an EMS. If necessary augment the plan for the
EMS.
Page 7-12 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 7: EMS Documentation and Records
As indicated above, this is an 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 your plan describes the following:
• Potential emergency situations (such as fires, explosions, spills or releases of hazardous
materials, and natural disasters)?
• Hazardous materials used on site (and their locations)?
• Key organizational responsibilities (including emergency coordinator)?
• Arrangements with local emergency support providers?
• Emergency response procedures, including emergency communication procedures?
• Locations and types of emergency response equipment?
• Maintenance of emergency response equipment?
• Training / testing of personnel, including the on-site emergency response team (if
applicable)?
• Testing of alarm / public address systems?
• Evacuation routes and exits (map), and assembly points? (57-58)
When evaluating and designing emergency procedures, bear in mind two final points: 1) your
response mechanisms should be as simple as possible - emergencies tend to discourage clear
thinking; and 2) learn from past mistakes - incorporate lessons learned in previous emergencies
and near misses into your procedures. A sample template for developing procedures for
emergency preparedness and response is given in Attachment 7-B.
Homework
Using existing systems wherever possible for documentation and records that are clear, trackable
and useful. Determine both what documentation and records are needed as well as how best to
do this. Ensure your EMS documentation and records are in place. This will include procedures
you have been developing prior to this module and will require you to recognize that added
documentation and records will be needed for the remainder of the EMS and into the future after
you have completed implementation.
Review your existing emergency preparedness and response program to ensure it is satisfactory.
Page 7-13 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 7: EMS Documentation and Records
Attachment 7-A: Documentation and Record Keeping
I. Purpose
To ensure effective operation of the EMS, ABC Meat Processing documents the procedures of
its EMS and keeps records of the outcomes of EMS processes, and of the important
environmental issues facing the plant. This EMS Manual comprises this documentation.
Documentation is kept up-to-date.
II. Procedure
1. The EMS coordinator documents the procedures that define ABC Meat Processing
EMS in this manual. The EMS committee formally reviews and, if necessary, revises
this manual on an annual basis. Revised manuals are assigned a new revision number
(a minor set of revisions would change the number from, 1.1 to 1.2; a major revision
would change the number from, 1.1 to 2.0). Finally, the EMS coordinator ensures
that no employees or managers use outdated revisions of this manual.
2. The EMS coordinator maintains updated records of the following outcomes, or
results, of the functioning of the EMS:
• Environmental policy;
• Environmental aspects;
• Applicability of legal requirements to environmental aspects; note that copies of
the regulations themselves are maintained by the EMS management
representative;
• Significant environmental aspects;
• Objectives, targets, and action plans for environmental management programs;
• Results of alternatives evaluations;
• List of operational control procedures related to significant environment aspects;
• Results of internal assessments;
• Corrective actions taken; and
• Management reviews.
These items are described in more detail in the relevant procedures in this manual.
3. The EMS coordinator is not responsible for maintaining records of environmental
training and emergency response preparations; the operational control procedures
themselves; or the New Purchase Approval Forms, the Design Approval Forms, the
Plant Expansion, or Modification Plans. These records are maintained by the
appropriate person or group, as specified in the relevant procedures of this manual.
III. Frequency
Manual review and revision will be done on an annual basis.
Page 7-14 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 7: EMS Documentation and Records
IV. Records
Maintained as outlined in the procedure.
Page 7-15 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 7: EMS Documentation and Records
Attachment 7-B: Emergency Preparedness
[Note: this procedure assumes that your plant has a general emergency response plan in place,
into which environmental considerations can be integrated.]
I. Purpose
As part of its EMS, ABC Meat Processing strives to ensure that the environmental impacts
associated with any emergency situations are minimized to the greatest extent possible.
II. Procedure
1. ABC Meat Processing has an Emergency Response Committee charged with
identifying potential emergency scenarios and developing and ensuring the
implementation of appropriate procedures, should an emergency situation develop.
2. With the assistance of the EMS coordinator, the Emergency Response Committee a)
identifies the potential negative significant environmental impacts associated with
potential emergency scenarios, b) incorporates measures to minimize these impacts
into emergency response procedures, and c) ensures that adequate training (including
simulations) is provided to appropriate ABC Meat Processing staff to implement
these procedures.
3. The Emergency Response Committee maintains records of the potential emergency
scenarios it is prepared for, the potential environmental impacts associated with each
scenario, and the procedures established to minimize these impacts. The HR manager
keeps records of training received by staff on implementation of emergency response
procedures.
III. Frequency
The Emergency Response Committee meets quarterly to review the status of its work.
IV. Records
Records of emergency scenarios, associated potential environmental impacts, and procedures to
mitigate these impacts are kept by the Emergency Response Committee. Training records are
kept by the HR manager.
Page 7-16 of 16
-------
This page intentionally left blank.
-------
Environmental
Management System
(EMS) Implementation
Guide for the
Meat Processing Industry
Module 8: Monitoring and Measurement
and Corrective and Preventive Action
-------
EMS Implementation Guide for the Meat Processing Industry
Module 8: Monitoring and Measurement and Corrective and Preventive Action
Table of Contents
Monitoring and Measurement 8-2
Internal EMS Assessment 8-4
Corrective and Preventive Action 8-7
Homework 8-9
Attachment 8-A: Conducting an Internal Compliance Assessment 8-10
Attachment 8-B: Conducting an Internal EMS Audit 8-12
Attachment 8-C: Taking Corrective Action 8-15
List of Figures
Figure 8-1: Linkages Among EMS Audits, Corrective Action, and Management Review 8-5
Figure 8-2: Framework for Corrective Action Process 8-7
Page 8-1 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 8: Monitoring and Measurement and Corrective and Preventive Action
Monitoring and \I easurement
An organization should develop procedures for monitoring and measurement of its operations
and activities that can have significant environmental impacts. As mentioned in Module 5,
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.1
In short, monitoring helps you manage your plant better.
This Module contains some overlap with Module 5.
difference is that you should now be looking for ways to
monitoring and measurement beyond direct application to
and operational controls.
As noted in Module 5 your organization should develop procedures to:
• Monitor the environmental critical control points (the environmental equivalent of
monitoring CCPs for HACCP);
• 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. (60)
Monitoring and measuring can be a resource-intensive effort. One of the most important steps
you can take is to clearly define your needs. (60)
You can start with a relatively simple monitoring and measurement process, then build on it as
you gain experience with your EMS. (60)
The
) apply
i EMPs
Hint: 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 plant. (61) Note: This philosophy can also be applied to areas of performance not
directly related to any one process, the overall success the EMS or improvements in your
compliance record for example.
1 NSF International, Environmental Management Systems: An Implementation Guide for Small and Medium-Sized
Organizations (Michigan: NSF International, January 2001) 60. Subsequent references to this document will be
given in parentheses in text.
Page 8-2 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 8: Monitoring and Measurement and Corrective and Preventive Action
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
and to staff. To measure progress in meeting objectives, select appropriate performance
indicators. (61)
Selecting performance indicators: Performance indicators can help you 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).
(62)
Indicators of general environmental performance include some of the following:
• Number of spills per year;
• Amount of hazardous waste disposal;
• Amount of waste reduction;
• Number of legal non-compliance issues identified;
• Number of exceedances of regulatory standards;
• Number of incidents;
• Number of public complaints; and
• Number of fines and size.
Indicators for the management system include some of the following:
• Percentage of objectives and targets met on time;
• Number of closed corrective actions versus total number;
• Number of employees suggestions for improvement to environmental programs;
• Training recipients assessments of training delivered; and
• Number of non-conformances in internal EMS assessments.
Data collected on performance indicators can be quite helpful during management reviews.
Select indicators that will provide top management with the information it needs to make
decisions about the EMS. (62)
Note: It is important that the documented monitoring and maintenance procedures are kept up-to-
date with respect to changes at your plant; therefore, these procedures should be managed in
accordance with your document control system (Module 7). You may need to modify, add, or
delete operational procedures (Module 5) as operations, activities, and equipment at your plant
change. Your plant's objectives and targets (Module 4) may change due to achievement and
changing priorities. The environmental laws and regulations that apply to your plant will also
change. Your documented monitoring and measurement procedures should be periodically
reviewed and revised to ensure that they reflect current plant conditions.
Page 8-3 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 8: Monitoring and Measurement and Corrective and Preventive Action
An organization should also establish and maintain a documented procedure for periodically
evaluating compliance with relevant environmental regulations. To achieve this, you should
ensure that a documented environmental compliance audit procedure exists at your plant that at
least describes the roles, responsibilities, authorities, and schedule for evaluating regulatory
compliance at your plant. In some cases, corporate headquarters provides this service.
Attachment 8-A provides a sample procedure describing how to conduct an internal compliance
assessment. Use the content of Attachment 1-B and your plant's determination of applicable
legal requirements (federal, state, and local) for all aspects (both significant and not significant)
to assist the development of your internal compliance assessment process.
Internal EMS Assessment
Once your plant 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. Periodic
EMS assessments will help determine whether all of the requirements of the EMS are being
carried out in the specified manner. (71)
Note: Assessment, Review and Audit are often used interchangeably and with slightly different
meanings depending on the user. Any of these terms can be used in association with determining
environmental regulatory compliance or examination of the status of the EMS. Compliance is
assisted by an EMS but is not an EMS.
Assessment and review more often describes the status of item(s) being checked in general.
Where they are done internally, the process can generate a statement of the status of programs.
For this guide, the term assessment is used because at times either the determination of
compliance status or EMS conformance will be typically done using internal resources that are
often working in an advisory capacity at the same time.
An audit process is typically a more formal reporting process and is more often considered the
appropriate term when a neutral third party conducts a review of the EMS for use as
verification to enhance the transparency of your EMS for outside stakeholders (e.g. as part of a
registration audit). When a neutral third party performs a check of environmental regulatory
compliance then use of the term audit may also be appropriate.
For your EMS assessment program to be effective, you should:
• Develop assessment procedures and protocols;
• Determine an appropriate assessment frequency;
• Select and train your auditors; and
• Maintain audit records. (71)
An EMS assessment checks for conformance with the EMS as you have defined it. This may
include the EMS model you aspire to (e.g., ISO 14001, EMS Implementation Guide Meat
Processing, Performance Track), your commitments (e.g., policy commitments), and / or the
Page 8-4 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 8: Monitoring and Measurement and Corrective and Preventive Action
actual commitments you have made in your EMS procedures and documentation for
environmental management. (Note: ISO 14001 call these your "planned arrangements".)
ISO 14001 Registration
Registration Accreditation Board (RAB) accredits registrars in the U.S. These registrars agree to
codes of conduct and operate as commercial businesses. RAB certifies EMS auditors who have
taken RAB Accredited Courses and have the required experience. Auditors working for
Registrars audit EMS' and recommend registration to ISO 14001.
If you wish to pursue ISO 14001 registration, hire a registrar that understands your business and
that you can work with. The auditor will review your EMS documentation and make two site
visits to audit your EMS. If the auditor is satisfied with your conformance, they will recommend
registration and a certificate will be issued by registrar. Every 6 or 12 months after that, the
registrar will visit to re-audit the EMS or parts of it and once every three years the entire EMS
must be audited.
Results of your EMS assessments should be linked to the corrective and preventive action
process (see Figure 8-1), which will be described in a subsequent section of this module.
Figure 8-1: Linkages Among EMS Audits, Corrective Action, and Management Review
(73)
While they can be time consuming, EMS assessments 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. (71)
Before you start an assessment, be sure to communicate the assessment scope, criteria,
schedule, and other pertinent information to the people in the affected area(s). This helps to
avoid confusion and facilitate the assessment process. (73)
A key part of the assessment is the specific protocol. It should be based on the "standard(s)" to
which your plant subscribes. The checklist in Attachment 1-A that was used for the Gap
assessment of your plant at the start of your implementation could be used but may not provide
enough useful information. This is because during the process of development of your EMS you
Page 8-5 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 8: Monitoring and Measurement and Corrective and Preventive Action
may have identified different or additional commitments that you will want to determine if you
have met. Feel free to add to the checklist to make it reflect the commitments and
requirements you have set for your plant's EMS.
How frequently should you conduct the assessments?
To determine an appropriate frequency of your EMS assessments, 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 assessments. (71)
As a rule of thumb, all parts of the EMS should be assessed at least annually. You can assess
the entire EMS at one time or break it down into discrete elements for more frequent
assessments. (There may be advantages to conducting frequent assessments, but the decision is
up to you). (71)
Who will perform the assessments?
You should select and train EMS auditors/assessors. 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. (72)
Auditors should be trained in auditing techniques and management system concepts.
Familiarity with environmental regulations, plant operations, and environmental science can be a
big plus, and in some cases may be essential to adequately assess the EMS. (72)
Some auditor training can be obtained on-the-job. Your plant'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. (72)
The performance of an internal EMS assessment may serve to
provide more than just an analysis of the state of the EMS.
When conducted for internal purposes the auditors may be
requested to suggest possible options for resolution of identified
issues and overall improvement in the EMS.
How should management use assessment results?
Management can use EMS assessment 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 (72)
Traits of a good auditor:
• Independent (of the activity
being audited)
• Objective
• Impartial
• T actful
• Attentive to detail (72)
Page 8-6 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 8: Monitoring and Measurement and Corrective and Preventive Action
As a final thought, keep in mind that an EMS assessment is a check on how well your system
meets your own established EMS requirements. An EMS assessment does not normally include
an analysis of how well employees do their jobs. Finally, assessments should be judged on the
quality of findings, rather than on the number of findings. (73)
Attachment 8-B provides a sample procedure describing how to conduct an internal EMS
assessment.
Corrective and Preventive Action
In order for the audits, assessments and other inspections conducted as part of monitoring and
measurement and the EMS assessments to have any value, the findings of these audits and
inspections must be addressed. Identified problems must be appropriately investigated and
corrected. Figure 8-2 provides a framework for the corrective action process.
Figure 8-2: Framework for Corrective Action Process
Sources
of change
Investigate and
recommend
solutions
Institutionalize
Change
(67)
To deal with system deficiencies, your plant needs a process to ensure that:
• Problems (including non-conformances) are identified and investigated;
• Root causes are identified (See Module 5);
• Corrective and preventive actions are identified and implemented; and
• Actions are tracked and their effectiveness is verified (65)
EMS non-conformances 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. (65)
Key steps involved in taking corrective and preventive action are outlined below:
• Identify the problem;
• Investigate to identify the root cause;
Corrective
Action
Process
t
Management
Review
Page 8-7 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 8: Monitoring and Measurement and Corrective and Preventive Action
• Come up with solution;
• Implement solution;
• Document solution;
• Communicate solution; and
• Evaluate effectiveness of solution. (65)
Hint: 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. (66)
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,
resources and schedules for completion. Review your progress regularly and follow up to
ensure that actions taken are effective. (66)
Make sure your actions are based on good information and root cause analysis. 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 'hoot cause" in their corrective and
preventive action processes. While this term can be used to describe a very formal analysis
process (see Module 5), it can also mean something simpler - looking past the obvious or
immediate reason for a non-conformance to determine why the non-conformance occurred. (66)
Rule of thumb: Corrective actions should:
• Resolve the immediate problem;
• Consider whether the same or similar problems exist elsewhere in the organization; and
• Prevent the problem from recurring.
The corrective action process also should define the responsibilities and schedules associated
with these three steps. (66)
Preventive Action
While corrective action is based on the results of internal feedback mechanisms, the scope of
preventive action can go beyond internal sources. If your plant is affiliated with other similar
firms via corporate ownership or industry affiliation, this is often a good source of lessons
learned by others. When applied to your plant these can avoid undesirable consequences or
improve efficiency. Some organizations conduct benchmarking exercises in general or if only in
specific areas where they are aware they have a potential deficiency.
The more proactive the preventative action component of your EMS the more likely your plant is
to be or become a leader rather than a follower.
Attachment 8-C provides an example procedure for taking corrective action.
Page 8-8 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 8: Monitoring and Measurement and Corrective and Preventive Action
Homework
Your homework is to expand on EMS monitoring and measurement that you started in Module 5
to cover all appropriate areas of the EMS.
You should also develop and begin use of corrective and preventative action processes.
Finally, you should define compliance and EMS assessment programs and consider when you
will conduct them in the implementation process.
Page 8-9 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 8: Monitoring and Measurement and Corrective and Preventive Action
Attachment 8-A: Conducting an Internal Compliance Assessment
I. Purpose
ABC Meat Processing conducts a periodic compliance assessment to ensure that it complies with
all applicable local, state, and federal environmental regulations.
II. Procedure
1. The EMS management representative maintains copies of applicable legal
regulations. Based on these regulations, the EMS management representative and
coordinator compile a list of questions as a compliance assessment protocol. These
questions are intended to be sufficient to the compliance status of ABC Meat
Processing with respect to applicable environmental regulations (both the paperwork
and the performance-related components).
2. The EMS coordinator and another operations manager carry out the assessment by
determining and recording the answers to the compliance assessment protocol. When
they are done with the compliance assessment, they note any actual or potential
compliance issues on format CA-01 (Compliance Tracking Log). Each actual and
potential compliance issue is immediately referred to corrective action.
III. Frequency
Monthly? Annually? (Note: Frequency is dependent on the type of requirement as well as past
compliance history.)
IV. Records
Compliance assessment results are recorded by the internal assessment team using the
compliance assessment protocol and using format CA-01. Records are maintained by the EMS
coordinator.
Page 8-10 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 8: Monitoring and Measurement and Corrective and Preventive Action
CA-01: Compliance Tracking Log
Person
Responsible
Regulation
Root Cause
Compliance
Check Dale
Results
Corrective
Action/Dale
Compliance
Veri lied/Date
Page 8-11 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 8: Monitoring and Measurement and Corrective and Preventive Action
Attachment 8-B: Conducting an Internal EMS Audit
I. Purpose
ABC Meat Processing conducts periodic internal assessments of its EMS to ensure that it is
being implemented and operated according to the procedures laid out in this manual.
II. Procedure
1. At intervals, a team of two or three operations managers or employees, who are not
on the EMS committee, conducts an internal assessment of ABC Meat Processing's
EMS. The assessment team uses this manual as the basis for its assessment. In
particular, the assessment team checks to make sure that:
• Each procedure is being carried out as stated in this manual;
• ABC Meat Processing's environmental policy is being upheld; and
• Progress is being made in meeting the environmental objectives.
The assessment team bases its evaluation on objective evidence, including
documentation and records (e.g., those cited in this manual), interviews with key
employees, and observations. Note that this is not a compliance audit.
2. The assessment team completes the checklist on format IA-01 and writes up its
findings using format IA-02. A "major non-conformance" occurs when an EMS
procedure is clearly not being implemented, when one of the commitments in the
policy is not being upheld, or when no progress is being made in achieving an
environmental objective. A "minor non conformance" occurs when a procedure is
being implemented inconsistently, yet without causing major failings in the EMS as a
whole.
3. Each non-conformance is immediately referred to corrective action (see the Taking
Corrective Action procedure).
4. Records of each assessment (i.e., formats IA-01 and EMS Assessment [see
Attachment 1-A]) are maintained by the EMS coordinator.
III. Frequency
At least once a year.
IV. Records
Assessment results are recorded by the internal assessment team using formats IA-01 and IA-02
(Internal Assessment Checklist and Internal Assessment Record). Records are maintained by the
EMS coordinator.
Page 8-12 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 8: Monitoring and Measurement and Corrective and Preventive Action
IA-01: EMS Assessment Checklist
Internal Assessment Team:
Date of Internal Assessment:
Signed:
EMS Procedures (Note: the list below will need to reflect the requirements for procedures that
your plant has developed)
Check each item assessed (includes auditing of records, where applicable):
Environmental Policy (adherence to policy commitments)
Environmental Objectives (progress; implementation of action plans)
EMS Responsibilities
Identification of Environmental Aspects
Identification of Legal Requirements
Identification of Significant Environmental Aspects
Development of Objectives, Targets, and Action Plans
Development of Operational Controls
Environmental Training (Awareness and Task-Specific)
Emergency Preparedness and Response
Documentation
Conducting a Compliance Assessment
Conducting an EMS Assessment
Taking Corrective Action
Management Review
EMS Performance
Achieved objective #1
Achieved objective #2
Achieved objective #3
Contact Person: Date Completed:
Page 8-13 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 8: Monitoring and Measurement and Corrective and Preventive Action
IA-02: Internal Assessment Record
Internal Assessment Team
Date of Internal Assessment
Signed
Major Non-Conformities Observed
1.
2.
3.
Minor Non-Conformities Observed
1.
2.
3.
Is ABC Meat Processing making progress in meeting its EMS objectives?
Is ABC Meat Processing adhering to the commitments in its environmental policy?
Suggestions for Improving the EMS
Contact Person: Date Completed:
Page 8-14 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 8: Monitoring and Measurement and Corrective and Preventive Action
Attachment 8-C: Taking Corrective Action
I. Purpose
ABC Meat Processing uses a formal corrective action process to ensure that actual or potential
compliance issues and EMS non-conformance are addressed quickly and effectively.
II. Procedure
1. The management representative assigns responsibility for taking action to correct
each actual or potential compliance issue or non-conformance identified in a
compliance assessment or an internal assessment to an appropriate manager or
employee. Together they fill out the "Statement of the Problem" part of the
Corrective Action Notice (format TCA-01).
2. The person responsible then undertakes the corrective action required, calling upon
the management representative, the EMS committee, and others for assistance as
necessary.
3. The responsible person and the management representative fill out the "Completion
of Corrective Action" part of the Corrective Action Notice when corrective action is
complete.
III. Frequency
Whenever significant problems in the functioning of the EMS are identified, primarily through
the internal assessment process.
IV. Records
Corrective action is recorded using format TCA-01. The records are maintained by the EMS
coordinator.
Page 8-15 of 16
-------
EMS Implementation Guide for the Meat Processing Industry
Module 8: Monitoring and Measurement and Corrective and Preventive Action
TCA-01: Corrective Action Form
Statement of the Problem
Date
Description of non-conformance or actual or potential compliance issue
Description of potential solution
Person responsible for corrective action
Deadline for completion of corrective action
Completion of Corrective Action
Actions taken
Results
Date
Signed:
Management Representative Person Responsible
Page 8-16 of 16
-------
This page intentionally left blank.
-------
Environmental
Management System
(EMS) Implementation
Guide for the
Meat Processing Industry
Module 9: Continuous Improvement
-------
EMS Implementation Guide for the Meat Processing Industry
Module 9: Continuous Improvement
Table of Contents
Continuous Improvement 9-2
Measurement Criteria 9-2
Management Review 9-4
Homework 9-6
Attachment 9-A: Conducting a Management Review 9-7
List of Figures
Figure 9-1: EMS Program Measurement Criteria Form 9-3
Page 9-1 of 8
-------
EMS Implementation Guide for the Meat Processing Industry
Module 9: Continuous Improvement
Continuous Improvement
To first understand the process for continuous improvement,
recall the "Plan, Do, Check, Act" model introduced in Module 1.
To improve environmental management, your plant needs to
focus not only on what things happen but also why they happen.
Over time, the systematic identification and correction of system
deficiencies leads to better environmental (and overall
organizational) performance. This model emphasizes the concept
of continuous improvement.
The final steps in developing your EMS are to establish procedures for evaluation and
assessment of the overall functioning of the EMS. Results of these evaluation processes are
essential in beginning to plan for and modify the existing EMS structure in order to strive for
continuous improvement.
Tools that can be used to evaluate the overall performance of your EMS include:
• Determining program measurement criteria;
• Setting up an internal assessment process (see Module 8); and
• Establishing a management review process.
Measurement Criteria
Determining measurement criteria, also called environmental performance indicators, will
help you evaluate the success of your overall EMS program. These performance indicators focus
on how well the overall system for improving environmental management is functioning. Select
performance indicators that will help you and your plant's employees decide whether success has
been achieved or whether improvement in procedures needs to be made.
You will need performance indicators for all of the various components of your EMS. The
measurement criteria selected for each component of your EMS will probably be different. For
example, how will you measure the success of communication, documentation, stakeholder
outreach, or training programs?
One approach is to measure the activities, for example, number of meetings held with
stakeholders, number of documents created, number of employees trained, or number of hours of
training. Activity, however, does not always mean results. Consider the objective of each EMS
component and define a way to measure results so that you would feel satisfied that the
objectives are achieved. Figure 9-1 provides a sample template to help you organize evaluation
of your EMS components using measurement criteria.
Some examples of EMS results measurement for various program components that can be
tracked over time are:
Page 9-2 of 8
-------
EMS Implementation Guide for the Meat Processing Industry
Module 9: Continuous Improvement
• Number of environmental objectives and targets met;
• Percentage of employees completing environmental training;
• Average time for resolving corrective action;
• Number of non-conformances;
• Number of incidents of non-compliance;
• Pounds of hazardous waste generated per unit of production; and
• Energy or water use per unit of production.
It is the results shown by these environmental performance indicators that will become the basis
for your plans for next year and establishing continuous improvement.
Figure 9-1: EMS Program Measurement Criteria Form
EMS Program Measurement Criteria
Company Name Date
Measurement
Elements
EMS Components
Objectives of
Component
Activity
Measures
Results
Indicators
Review
Period
Environmental Policy
Communication Plan
Stakeholders Input
Environmental or EMS Training
Review of Aspects
Operational Controls
Environmental Review of New
Processes and Activities
Setting Objectives & Targets
Documentation
Regulatory Compliance
Pollution Prevention
Other
Contact person for form:
Date Completed:
Page 9-3 of 8
-------
EMS Implementation Guide for the Meat Processing Industry
Module 9: Continuous Improvement
Management Review
Management reviews are one key to continual improvement and for ensuring that the EMS will
continue to meet your plant's needs over time.1
What is a management review?
A management review is a strategic analysis of the EMS.
The key question that a management review seeks to answer is:
Do we have the right system—is this EMS appropriate for our particular plant with our specific
activities, products, and services, and corresponding environmental aspects?
The specific goals of management review of an EMS will also vary based on the specific needs
of your plant, but, in general, the overall goal is to determine if the EMS is functioning as
intended. Your plant's management review process should focus on answering the following
questions:
• Are environmental risks being managed effectively?
• Are we complying with environmental regulations and will we continue to do so?
• Are we achieving improvement in environmental performance?
It is difficult to recommend a specific approach for EMS management review because the
character of your management review process will be a function of your plant's organizational
structure, management style, and overall culture.
Hint: Two kinds of people should be involved in the management review process:
• People who have the right information / knowledge; and
» People who can make decisions about the plant and its resources (top management). (75)
Determine management review frequency that will work best for your plant. 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. (75)
1 NSF International, Environmental Management Systems: An Implementation Guide for Small and Medium-Sized
Organizations (Michigan: NSF International, January 2001) 75. Subsequent references to this document will be
given in parentheses in text.
Page 9-4 of 8
-------
EMS Implementation Guide for the Meat Processing Industry
Module 9: Continuous Improvement
Hint: It is unlikely that top management will value taking part in a process that involves
extensive meetings and discussions of detailed findings of compliance audit or EMS audit
results. To successfully engage top management, focus on current and potential value-added
EMS activities at your plant, such as cost avoidance (e.g., reduction in regulatory fines, costs
savings from reduced waste), and new and innovative ideas for improving environmental
performance.
Use the management review process to focus attention on overall EMS performance. The
information and data needed to make an overall evaluation of the success of the EMS may be
gathered from answering some of the following questions:
• 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/assessments)? What do the results
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?
• Are outreach programs working?
• Is there a better way? What can we do to improve? (76)
Page 9-5 of 8
-------
EMS Implementation Guide for the Meat Processing Industry
Module 9: Continuous Improvement
During management review meetings, make sure that someone records what issues were
discussed, what decisions were made, and what action items were selected. Results of
management reviews should be documented (75)
To facilitate the record-keeping process for management review meetings, consider the use of a
form to help remember what to document for the review (see Attachment 9-A). The form should
include the date of the meeting or discussion, attendees, items discussed and conclusions made,
and action items assigned.
Management reviews should assess how changing circumstances might influence the
suitability, effectiveness or adequacy of your EMS. Changing circumstances might be internal
to your plant (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). (75)
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. (76)
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. (76)
In conclusion, it is important to understand that management review is not something that is
conducted once every six months or once a year during one meeting. It is an ongoing process
by which top management is presented with data and other information about the progress and
general condition of the EMS and decisions regarding future actions are made.
Attachment 9-A provides a sample procedure for conducting a management review.
Homework
Define how your management review process will work and how the management review will
foster continuous improvement. You may elect to conduct management reviews before all areas
of the EMS are fully implemented and operational with the understanding that the review process
is ongoing.
Also review the EMS implementation process that has occurred to date in preparation for
Module 10.
Page 9-6 of 8
-------
EMS Implementation Guide for the Meat Processing Industry
Module 9: Continuous Improvement
Attachment 9-A: Conducting a Management Review
I. Purpose
To ensure the effectiveness of the EMS and its continual improvement, ABC Meat Processing
top management periodically reviews the important elements and outcomes of the EMS.
II. Procedure
1. In preparation for the management review, the EMS management representative
gathers the following information and makes it available to top plant management,
including the owner and President of ABC Meat Processing and the plant manager:
• Environmental policy;
• List of EMS committee and others responsible for major parts of the EMS;
• List of significant environmental aspects and criteria of significance;
• Update on compliance status of the plant and on any potential upcoming
regulations that might require an advance strategy;
• List of environmental objectives and targets;
• Environmental performance results (from monitoring and measuring significant
environmental aspect indicators and indicators of progress toward environmental
objectives and targets);
• Bullet-point description of other accomplishments of the EMS (e.g., number of
people trained, etc.);
• Results of most recent EMS internal assessment, compliance assessment, and
corrective actions taken;
• Description and documentation of feedback from stakeholders (if received); and
• Analysis of the costs and benefits of the EMS (as quantitative as possible).
2. Top plant management meets to review and discuss the information presented. The
EMS management representative and coordinator will also be present. Depending on
its review, top management may direct specific and/or significant changes in the scale
and direction of the EMS in order to improve its effectiveness and business value.
The conclusions and directives that result from the management review are recorded
using format MR-01 and kept by the EMS coordinator.
III. Frequency
Quarterly.
IV. Records
Results of management reviews are recorded using format MR-01. Records are kept by the EMS
representative.
Page 9-7 of 8
-------
EMS Implementation Guide for the Meat Processing Industry
Module 9: Continuous Improvement
MR-01: Management Review Record
Date of review meeting:
Persons present at meeting:
Name:
Position:
Conclusions:
Actions to be taken:
Person(s) responsible:
Signed:
EMS Representative Plant Manager
Page 9-8 of 8
-------
This page intentionally left blank.
-------
Environmental
Management System
(EMS) Implementation
Guide for the
Meat Processing Industry
Module 10: Lessons Learned
-------
EMS Implementation Guide for the Meat Processing Industry
Module 10: Lessons Learned
Table of Contents
Introduction 10-2
Lessons Learned 10-2
Page 10-1 of 4
-------
EMS Implementation Guide for the Meat Processing Industry
Module 10: Lessons Learned
Introduction
This purpose of this module is to share lessons learned from Modules 1 through 9 in
design and implementation of an EMS. This section contains the best practices and
examples of procedures that worked well for meat processing plants implementing an
EMS. Sharing of challenges faced and lessons learned will benefit both the existing and
future users of a program for EMS implementation.
Five meat processing plants were asked to note successes and areas for improvement that
they experienced and/or identified during their EMS implementation.
Lessons Learned
Hints or lessons learned from the five plants regarding EMS implementation are
described below.
• Top management support is critical. All five plants noted that when
implementing an EMS, visible support from top management was critical for
success. One of the first tasks of EMS implementation is to engage top
management, so the entire company is committed to the system. As a result of
having the EMS, environmental awareness and decision-making was elevated,
and senior management is currently asking questions they would not have asked
in the past. The more included management was in developing the EMS, the more
they benefited from the EMS.
• Corporate involvement matters. Four of the five plants who participated are
part of a larger corporation. These plants received corporate support, or direction
with the intent of using the internal lessons learned from the EMS implementation
in other areas of the company. The opportunities for long-term migration of the
EMS and benefit to the corporation were greatest where corporate support and
involvement was highest.
• Make visible the EMS policy. All employees needed to be made aware of the
commitments of the policy, in order to strive toward the goals of the management
commitments. For each individual or department, employees should determine
what the policy means to them and how the intent of the policy can be
incorporated into their daily operations and activities.
• Select an appropriate EMS representative. It was important to select an EMS
representative who believes in and was committed to EMS implementation, and
had the time and resources to dedicate to the EMS. The EMS Epresentative
should have the necessary authority, an understanding of the facility, and project
management skills.
Page 10-2 of 4
-------
EMS Implementation Guide for the Meat Processing Industry
Module 10: Lessons Learned
• Have a core team. From the early stages of EMS planning, there should be
involvement of a multi-discipline core team. All five plants found that their core
team was a critical element for success. The core team assisted in ensuring that:
the EMS is ingrained across the organization, communication works, and there is
the development of awareness among staff. A core team that included members
from different departments was more able to provide diverse input. Inclusion of
the core team from the beginning allowed for increased awareness of EMS
processes and implementation.
• Draw on all available personnel for EMS implementation. Besides the oare
team, it was necessary to seek out all personnel who had the time to participate in
EMS implementation. Like the core team, involve these individuals early on in
the process so they may be aware of the EMS implementation process.
• Involve all employees in the process. It was important in developing and
promoting an EMS to involve as many employees as possible in the process.
Employees should understand why the facility needs an effective EMS, what their
role is, and how an EMS will help to control environmental impacts in a cost-
effective manner.
• Provide EMS awareness training. It is essential to provide EMS awareness
training for all employees who are affected by the EMS, in addition to the specific
training that the core team had taken to implement the EMS.
• Time spent in EMS planning is highly valuable. For a majority of the plants,
time spent in the planning phase of the EMS was seen as valuable in helping them
identify and understand their plant environmental issues. It is necessary and cost-
effective to spend the time and energy in this phase rather than skimming through
the planning, only to be lost in the next steps of implementation.
• Define EMS procedures before drafting them. From a cost effectiveness
standpoint, some of the facilities found that it was more efficient to discuss and
define the procedures for EMS implementation before writing them. This allowed
for feedback to be obtained from the core team members, before time was spent
writing procedures.
• Measure it and they will care. None of the five plants implemented extensive
monitoring and measurement systems. They initially only conducted
measurement activities to support the gathering of data to enable them to develop
a better understanding of significant aspects. Measuring how much solid waste
was generated was a key driver that led to increased awareness by staff of the
significance of this aspect. This also encouraged floor-level development of
practical solutions. Employees now have a greater understanding of why
measurement of data is important, helping to ensure more consistent data
generation under existing programs.
Page 10-3 of 4
-------
EMS Implementation Guide for the Meat Processing Industry
Module 10: Lessons Learned
• Follow checks and balances. As implementation of the EMS proceeds, it is
important throughout the process to monitor and make adjustments to maintain
the original EMS implementation schedule. The EMS core team designated to
implement the EMS must not lose sight of its initial implementation plan.
• Do not get discouraged if the community does not show interest. One of the
companies decided to publish their EMS policy in the local newspaper. It
however did not evoke any reaction or comment from the community at large.
The lack of feedback could have been attributed to a lack of understanding among
the community members. Communicating benefits to the community of improved
environmental performance geared towards specific issues may gain more
attention.
• Scale down identification of significant aspects. It is important to consider the
time and effort you dedicate to identifying significant environmental aspects. This
can be a very time consuming activity if the core team decides to develop a
detailed list of significant aspects, which may not be necessary. A company is not
expected to manage issues outside its sphere of influence or control.
• Prepare for internal audits. Prepare and plan for your internal audit. This
planning is essential to ensure that the audit is appropriate to the facility and
covers all relevant operations. Internal audits will help determine whether all of
the requirements of the EMS are being carried out in the specific manner.
• Expect a learning curve when completing audits. The ideal internal auditor
knows the plant and knows how to do audits. If a facility decides to use internal
staff, who is not experienced in completing EMS audits, a lengthy learning phase
should be expected. After training has been completed, it is important for the
audit team to get out on the floor to do the audits, so as to find out what works for
them.
• Share lessons learned. Any EMS manual will be greatly enhanced if lessons
learned from the experience of similar organizations are given as examples in the
implementation plan. Along with these lessons learned, sample templates, detailed
programs, written procedures, and any other material used by these organizations
may be provided as examples.
Page 10-4 of 4
-------
This page intentionally left blank.
------- |