Introduction
Appendices
Milan Screw Products
Hach Company
This Guide is intended to support and facilitate the development o environmental management systems (EMS) among small and medium-sized organizations. The Guide explains how you can develop and implement an effective EMS and how it can support your organization's mission and goals. Development of an EMS is a voluntary approach to improving your organization's environmental performance.
The Guide is designed primarily for use by EMS implementers - the people within a small or medium-sized organization that will lead the EMS development effort. The heart of the Guide is found in Section 4, "Key Elements of an EMS." For each of the recommended EMS elements, this section discusses the importance of the element, how your can get started, and some key suggestions for implementation. In addition, examples of how other organizations have addressed various EMS elements are provides in Section 4.
The Guide uses de ISO 14001 Standard as a model for an EMS. The ISO 14001 Standard is
the widely accepted official international standard for environmental management systems.
This Guide is not intended for use by registrars (or others) for
registration purposes, nos is it intended to provide specific interpretation of the ISO
14001 Standard.
How this Guide is Organized
Section 1 Describes the many benefits of
an EMS and how it can help your organization to
compete and prosper in today's global marketplace.
Section 2 Summarizes the overall
management systems concepts. This section explains
what a management system is and how it can support your organization's mission.
Section 3 Describes the overall process for
building an EMS and provides
recommendations for planning the overall EMS development effort.
Section 4 Provides detailed guidance on how your EMS
should be designed and
implemented. This section discusses each of the key elements of an EMS and how
you can put them in place.
Section 5 Describes the process for registering an EMS and selecting a registrar.
Section 6 Discusses other sources of assistance your
organization can use to build and
sustain its EMS.
Appendices Provide case studies, sample environmental policies, other
sources of information,
and information on EMS standards. In addition, the Tool Kit provides
sample
EMS procedures and other tools that your organization can tailor to fit its EMS
needs. The sample procedures are adapted from actual EMS procedures used by
other companies that have implemented an EMS.
Use of Icons
A variety of icons are used in this Guide to highlight key concepts and suggestions for the reader. A few of these icons include:
The light bulb is used to highlight EMS examples and experiences from small and medium-sized organizations. It is also used to indicate that additional help is provides in the Tool Kit or available from other sources.
The had is used to point out key hints for implementing EMS elements.
The speech balloon is used to indicate quotes from representatives of organizations that have implemented an EMS (as well as definitions from the ISO 14001 Standard).
This section explains why an EMS can help your organization to compete and
prosper in today's global market.
A systematic approach to meeting your environmental and business goals
Key EMS Benefits
" We view the establishment of an EMS as a process that forces us to better organize our priorities and projects and to identify problems and exposures before they occur". - K.J.Quinn $ Co. (A small secialty chemical company)
If you answered YES to one or more of the above questions, an environmental management system (EMS) can help your organization - and so will this Guide!
As one of your organization's leaders, you know that interest in environmental protection and sustainable development is growing. Like many others, your organization may be increasingly challenged to emonstrate its commitment to the environment. Implementing an EMS can help in a nunmber of important ways.
First, an effective EMS makes good business sense. By helping your identify the causes of environmental problems (and then eliminate them), an EMS can help you save money. Think of it this way:
. Is it better to make a product right the first time or to perform a
lot of re-work later?
. Is it cheaper to prevent a spill in the first place or clean it up
afterwards?
. Is it more cost-effective to prevent pollution or to manage it after it
has been generated?
Second, an EMS can be an investment in longterm viability of your organization. An EMS will help you to be more effective in achieving environmental goals. And, by helping businesses to keep existing customer and attract new ones, an EMS adds value.
Much of what your need for an EMS may already be in place. The management system framework described in this Guide contains many elements that are common to managing other business processes, such as quality, health $ safety, finance, or human resources. As you review this Guide, you may find that you already have many EMS processes in place, but for other purposes (such as quality). Integrating environmental management with other key business processes can improve the organization's financial and environmental performance.
The key to effective environmental management is the use of a systematic approach to planning, controlling, measuring and improving an organization's environmental efforts. Potentially significant environmental improvements (and cost savings) can be achieved by reviewing and improving your organization's management proceses. Not all environmental problems need to be solved by installing expensive pollution control equipment.
Of course, there is some work involved in planning and implementing an EMS. Buy many organizations have found that the develpment of an EMS can be a vehicle for positive chage. These organizations believe that the benefits of an EMS can be a vehicle for positive change. These organizations believe that the benefits of an EMS far autweigh the potential costs (see next page). As they say in the Total Quality Management (TQM) world, "quality is free" - as long as you are willing to make the invetments that will let your reap the rewards. The same holds true for environmental management.
Want to know more about EMS costs and benefits?
Read on...
"We found that an EMS could improve employee retention, new hire selection,
working conditions, and the perceptions of our customers, suppliers, lenders, neighbors,
and regulators"
Milian Screw Products (A 32-person manufacturer of precision fittings)
Costs Benefits
. Staff / employee time
. Improved environmental performance
. Possible consulting assistance
. Improved compliance
. Training of personnel
. New customers / markets
. Increased efficiency / reduced costs
. Enhanced employee morale
. Enhanced image with public
. Reduced training effot for new employees
. Enhanced image with regulators
If your organization already has or is considering a quality management system (such as ISO 9000), you will find some significant synergy between what you need for quality management and for environmental management.
. Quality Policy
. Environmental Policy
.
Adequate Resources
. Adequate Resources
. Responsibilities and Authorities
. Responsibilities
and Authorities
. Training
. Training
. System Documentation
. System Documentation
. Process Controls
. Operational Controls
. Document Control
. Document Control
. System Audits
. System Audits
. Management Review
. Management Review
One final note: Small and medium-sized organizations often have some advatages over largar organizations in ensuring effective environmental management. In smaller organizations, lines of communication are generally shorter, organizational structures are less complex, people often perform multiple functions, and access to management is simpler. All of these can be real advantages for effective environmental management.
Are you interested in learning more about how an EMS can help your organization? If so, let's look at some key management systems concepts and how they are applied in the environmental area.
This section explains what a management system is and how it can help your
company.
The focus on quality principles
Definition of an EMS:
A continual cycle of planning, implementing, reviewing and improving the actions
that an organization takes to meet its environmental obligations.
* An effective EMS doesn't just happen. An effectve EMS needs ongoing management support.
You have probably heard of Total Quality Management (TQM). Your organization may apply TQM principles to some or all of its operations and activities.
An effective EMS is built on TQM concepts. To improve environmental management, your organization needs to focus not only on what things happen but also on why they happen. Over time, this systemtic identification and correction of system deficiencies leads to better environmental (and overall business) performance.
Most EMS models (including the recently issued ISO 14001 Standard, which will be described later) are built on the "Plan, Do Check, Act" model introduced by Shewart and Deming. This model endorses the concept of continual improvement
In the ISO 14001 EMS Standard, these "plan, do, check, act" steps have been expanded into seventeen EMS elements. Each element i discussed in Section 4 of this Guide.
Putting TQM principles into practice in the environmental area is the job of top
management. To build and sustain an effective EMS, management must communicate to all
employees the
importance of:
. making the environment an organizational priority
(thinking of effective environmental as fundamental to the organization's survival)
. building environmental management in everywhere
(thinking about the environment as part of product and process development, among
other activities.
.looking at problems as opportunities
(identifying problems, determining root causes and preventing their recurrence).
The concept of continual improvement recognizes that problems will occur. But a committed organization learns from its mistakes and prevents similar problems from occurring in the future.
An effective EMS must be dynamic to allow, your organization to adapt to a quickly changing business environment. For this reason, you should keep your EMS flexible and simple. This also helps make your EMS understandable for the people who must implement it you and your organization's employees.
As you build and implement an EMS, some roadblocks may be encountered. Some people in the organization may view an EMS as bureaucracy or extra expense - an ''add-on" to what you do now. There may be resistance to change or fear of new responsibilities. To overcome these potential roadblocks, make sure that everyone understands why the organization needs an effective EMS and how an EMS will help you control environmental impacts in a cost-effective manner. Getting people involved in designing and implementing the EMS will demonstrate the organization's commitment to the environment and help to ensure that the EMS is realistic, practical and adds value.
Building or improving your EMS (with the help of this Guide) is a great opportunity to assess how your organization manages environmental obligations and to find better (and more cost-effective) solutions. While you will probably identify some areas where your current EMS can be improved, this does not mean that you should change things that are working well! By reviewing what your organization does and how well it works, you can ensure that your EMS will be viable and effective, both now and in the future.
Don't get discouraged if your system has some bugs at first this is to be expected. Remember, the focus is on continual improvement.
* Flexible + simple = adaptable + understandable
** Employee involvement is crucial
Regulators have begun to incorporate management system concepts into regulatory programs (or example, OSHA's Process Safety Management Standard and EPA's Risk Management Program for Chemical Accidental Release Prevention).
This section explains the process of building an EMS.
Putting the theory of EMS into practice
Steps to Consider
. Gain management commitment
. Choose a champion
. Prepare budget and schedule
. Build cross- functional team
. Involve empleyees
. Conduct preliminary review
. Modify plan
. Prepare procedures / other documents
. Plan for change
. Train employees
. Assess performance
Milan Screw Products found that the use of a cross-functional group (the environmental task group) was the key to progress in evaluating and implementing their EMS. Participation of shop floor employees is essential in successfully implementing an EMS.
K.J. Quinn & Company found that it could perform a initial self-assessment of its environmental programs in 20-25 hours.
Building an EMS might sound like an overwhelming task for a small organization, but it need not be. Time and other resources are limited in any small organization, so it is important that your resources are used wisely. One way to do this is by following a simple, effective plan. Fortunately, you can build on the experiences of other organizations who have alredy implemented an EMS. Examples are provides throughout this Guide.
Figure 2 illustrates some key steps in the EMS building 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 which people must be involved will pay big dividens down the road.
Using a team approach for building your EMS is a good way to improve commitment and ensure that the objectives, procedures and other system elements are realistic, achievable, and cost-effective. Ideas for using your team and involving employees are discussed on the following pages.
A few hints to keep in mind as you build your EMS:
. Help is available don't hesitate tu use it. (See Sectuib 6 of this
Guide for more on resources.)
. Consultants can provide help in evaluating your EMS and suggesting
approaches used successfuly elsewhere. Look for ways to hold consulting costs down. For
example, you may be able to join forces with other small businesses in your area to hire a
consultant.
Some Thoughts on the Use of Consultants
. Assess your own in-house resources first.
. Make sure bot parties understad the scope of work.
. Get refrences and check them. Look for consultants with experience in
small business and your specific industry.
. Use consultants to gain insights on approaches used by other companies.
. An EMS developed by consultants "in isolation" will not work.
Your own people need to be involved in the process.
. Look at your existing environmental compliance plans and programs to
assess how effective they have been and how they might be improved.
Creating Your Own EMS: Key Steps
1) Obtain Management Commitment
The first step in the EMS-building process is gaining top management's commitment
to supporting the EMS. Management must understand the benefits of an EMS and what it will
take to put an EMS in place. Management commitment and vision should be clear and
communicated across the organization.
2) Choose a Champion
Not all small or medium-size 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 organization, and project management
skills. The champion should be a "systems thinker" (some ISO 9000 experience
would be a plus, but is not necessary) and must have the time to commit to the
EMS-building process.
3) Prepare Budget and Schedule
The project champion should prepare a preliminary budget and schedule for developing the
EMS. Costs will likely include staff and empleyee time, training, some consulting
assistane, materials, and possibly some equipment (such as a computer or word processor).
The schedule should consider the various tasks described below, among others.
4) Build Project Team
A team with representation from key management functions and production or service areas
can identify and assess issues, opportunities, and existing processes. Your may want to
consider including contractors, suppliers, and other external parties to be part of the
project team where appropriate. This team will need to meet frequently, especially in the
early stages of the project. The cross-functional team can help to ensure that procedures
are reasonable and will build commitment to the EMS.
5) Involve Employees
Employees are a great source of knowledge on environmental and health & safety issues
related to their areas as well as on the effectiveness of current processes and
procedures. They can help the project team in drafting procedures. Employee ownership of
the EMS will be greatly
enhanced by meaningful employee involvement in the EMS development process.
6) Conduct Preliminary Review
The next step is to conduct a preliminary review of your current environmental
programs and system and compare these against the criteria for your EMS (such as ISO
14001). Evaluate your organization's structure and ists procedures, polices, environmental
impacts, training programs, and other factor. Determine which elements of your current
system are in good shape and which need additional work.
7) Modify Plan
The project plan might need to be modified based on the results of the preliminary review.
The modified plan should describe in detail the key actions needed, who will be
responsible, what resources are needed, and when the work will be completed.
8) Prepare Procedure & Documents
At this point, your are ready to develop procedures and other system documents. In some
cases, this might involve modifying existing environmental procedures or adapting other
business procedures (such as quality or health & safety management procedures) for EMS
purposes. In some cases, your might need to develop new procedures. Get help from
employees and the cross-functional team, as discussed above.
9) Plan for Change
In building your EMS, make sure that the system is sufficiently flexible. While you will
likely need to modify your EMS over time, try to avoid making your EMS so rigid that you
must change it frequently to reflect the realities of your operation.
10) Train Employees
Once the procedures and other documents have been prepared, your are ready to implement
the EMS. As a first step, train your employees on the EMS, especially with regard to the
environmental impacts of their activities, any new / modified procedures, and any new
responsibilities.
11) Assess EMS Performance
After ther EMS is up and running, be sure to assess system performance. This will be
accomplished through periodic EMS audits and ongoing monitoring and measurement.
Assessment of EMS performance provides the opportunity to improve the system and your
environmental performance over time.
This section provides guidance on how to build and implement an EMS.
As mentioned earlier, your EMS should be built on the "Plan, Do, Check, Act" model to ensure that environmental issues are systematically identified, controlled, and monitored. Using this approach will help to ensure that performance of your EMS improves over time.
This section describes seventeen EMS elements included in the ISO 14001 Standard. While there are several good EMS models available, this Guide uses the ISO 14001 Standard as a starting point for describing EMS elements for several reasons:
. ISO 14001 is a widely accepted international Standard for EMS;
. Companies may be asked to demonstrate conformance with ISO 14001 as a
condition of doing business in some markets; and
. The Stardard is consistent with the key elements found in most EMS
model
Elements of an ISO 14001 EMS: A Snapshot
. Environmental policy - Develop a statement of your organization's commitment to the environment. Use this policy as a framework for planning and action.
. 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 (and other requirements to which your organization adheres).
. Objectives and targets - Establish environmental goals for your organization, in line with your policy, environmental impacts, views of interested parties and other factors.
. Environmental management program - Plan actions to
achieve objetives and targets
. Structure and responsibility - Establish roles and responsibilities and
provide resources.
. Training, awareness and competence - Ensure that your employees ara 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 EMS and related documents.
. Document control - Ensure effective management of procedures and other system documents.
. Operational control - Identify, plan and manage your operations and activities in line with your 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.
. Nonconformance and corrective and preventive action - Identify and correct problems and prevent recurrences.
. Records - Keep adequate records of EMS performance.
. EMS audit - Periodically verify that your EMS is operating as intended.
. Management review - Periodically review your EMS with an eye to continual improvement.
How Does the ISO 14001 Standard Support Environmental Compliance?
ISO 14001 requires an organization to:
While these requirements relate directly to an organization's compliance management, each of the seventeen elements of the ISO 14001 Stardard can contribute to enhanced compliance (e.g.,commucation, training, documentation, records, nonconformace and corrective / preventive action, EMS audits, management review, etc.). An EMS based on the ISO 14001 Standard can complement and improve your organization's compliance management and help your organization to meet objectives and targets that go "beyond compliance". An EMS based on the ISO 14001 Standard can also help your organization to meet objectives and targests that address issues that are not subject to regulation.
The following is a overview of each of the 17 elements of the ISO 14001 Standard in greater detail ...
Why do we need an environmental policy?
What is my organization's commitment to the environment?
An environmental policy is your management's declaration of commitment to the environment. The policy should serve as the foundation for your EMS and provide a unifying vision of environmental concern by the entire organization.
Your policy should be more than just flowery prose. Since it serves as the framework for setting environmental objectives and targest, the policy should be brought to life in your plans and deeds.
Everyone in the organization should understand the environmental policy and what is expected of them in order to achieve the organization's objectives and targets.
Your policy should contain three key commitments (see box, below), including a commitment to continual improvement. This doesn't mean that you must improve in all areas at once, but that the policy should drive your overall efforts to continually improve your organization's environmental management.
Sample environmental policies (which contain the three key policy commitments are provides in the Tool Kit (see page 92)
Hints:
. Your organization probably has an environmental policy now, even if it's not written. For example, your organization is probably committed to complying with the law and avoiding major environmental problems, at a minimum. Document your existing commitments as a starting point.
. Your policy should be related to your products and services, as well as supporting activities. Consider the results of your preliminary review before finalizing the policy. Also, make sure the policy reflects the environmental aspects of your products, services and activities (as described in the next section)
. Keep your policy simple and understandable. Ask yourself: What are we trying to achieve? How can I best communicate this to the rest of the organization? Will we do what we said we would? Keep in mind that your policy should be explicit enough to be auditable.
. The 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 in your organization should increase commitment and ownership.
. Make sure that your empleyees undestand the policy. Options for communicating your policy internally include posting it around the site (e.g., in the lunch room), paycheck stuffers, incorporating the policy into training classes and materials, and references to the policy at staff or all-hands meetings. Test awareness from time to time by asking employees what the policy means to them.
. The policy should also be communicated externally. Options for external communcation include business cards, newspaper advertisements and annual reports, among other options. You can choose to communicate the policy proactively or in response to external requests.
How does my organization interface with the environment?
To plan for and control its significant environmental impacts, an organization must first know what these impacts are. But knowing what the impacts are is only part of the challenge - you also should know where these impacts como from.
If your organization has undertaken pollution prevention projects, your are probably familiar with this concept your must know how a waste is generated in order to minimize or eliminate it. As with pollution prevention, the identification and management of environmental aspects can (1) have positive impacts on the bottom line and (2) provide significant environmental improvements.
Your EMS should include a procedure to identify the environmental aspects that your organization:
. can control, and
. over which it can have an influence.
The relationship between aspects and impacts is one of cauce and effect. The term "aspects" is neutral, so keep in mind that your environmental aspects could be either positive (such as making a product out of recycled materials) or negative (such as discharge of toxic materials to a stream).
Your organization is not expected to manage issues outside its sphere of influence. For example, while your organization probably has control over how much electricity it uses, it likely does not control the way in which the electriciy is generated.
Once you have identified the environmental aspects of your products, activities, and services, you should determine which aspects could have significant impacts on the environment. These environmental aspects should be considered when you set your environmental objectives and define your operational controls (as discussed later).
A multi-step process (see figure al left) can be used to make this evaluation. Keep the resulting information up-to-date, so that potential aspects of new products, services, and activities are factored into your objectives and controls.
Hints:
. In identifying aspects and impacts, you should also look at activities not controlled by applicable laws and regulations. But because many of your aspects/impacts may be addressed by legal requirements, your compliance program might yield some valuable information. Permits, audit reports, and other such documents can serve as useful inputs. Beyond regulations, look at issues such as land, energy, and other natural resource use.
. Once you have identified environmental aspects and related significant impacts, use this information in setting your objectives and targets. This does not mean that your need to address all of your impacts at once. There may be good reasons (such as cost, availability of technology, and scientific uncertainty) for addressing some impacts now and deferring action on others. Keep in mind that managing environmental aspects could have positive business impacts.
. Remember to look al services as well as products. While the need to examine your on-site operations might be obvious, you should also consider the potential impacts of what you do off-site (such as servicing equipment al customer sites). Similarly, the environmental aspects of the products, vendors, and contractors your use may be less obvious, but should still be considered.
. Identifying significant environmental aspects is one of the most critical elements of the EMS - and can be one of the most challenging. Decisions you make in this task can affect many other system elements (such as, setting objectives and targets, establishing operational controls, and defining monitoring needs). Careful planning and conduct of this activity will pay dividens in latr steps.
Getting Started
. To understand your environmental aspects, it helps to understand the processes by which you generate products and services. A flow chart of your major processes might help you undesrstad the inuts and outputs of your processes and how materials are used. A sample flow chart is provided in the Tool Kit (see page 96). You may also want to consider the views of interested parties - some organizations have found external parties to be a good resource to help you identify your organization's environmental aspects.
. There are many readily-available sources of information to help you perform your assessment. For starters, look at your permits, various regulations that apply to your operations, audit reports, EPCRA reports, and monitoring records. Trade associations, regulatory agencies, your customers and suppliers also might provide useful information to support your assessment.
. Various techniques exist for evaluating environmental impacts. Find one that can be readily adapted for your use in identifying environmental aspects and significant impacts. Consider techniques used for compliance with the OSHA Process Safety Management Standard, environmental impact assessments, and life cycle analysis. More information on these techniques can be found in the Tool Kit (see page 98).
. Once you've found a process that works for your organization, describe the process in a written procedure. A sample procedure for performing the assessment is provided in the Tool Kit (see page 100).
. You can start out with a simple process for identifying aspects and then refine the process over time as needed. You also can address the more obvious impacts or "low hanging fruit" first, then tackle the more complex issues later.
The Link Between Aspects and Impacts - Some Examples from a Real Company
Aspects
Potential Impacts
Emissions
of volatile organic
Increase in
ground level ozone
compounds
Discharges
to stream
Degradation of aquatic habitat and drinking
water supply
Spills and
leaks
Soil and groundwater contamination
Electricity
use
Air pollution, global warming
Use of
recycled paper
Conservation of natural resources
What standards affect the organization?
Setting the legal framework for your EMS
To be in compliance with the laws and regulations that apply to your organization, you must first know what the rules are and how they affect what you do. As discussed earlier, compliance with legal requirements is one of the "three pillars" upon which your environmental policy should be based. Costs of non-compliance (in terms of dollars, public image and possible damage to the environment) can be very high.
An effective EMS will include a process for:
. Identifying applicable legal and other requirements, and;
. ensuring that these requirements are factored into the organization's
efforts.
Changing legal requirements might require that you modify your environmental objectives or other elements of your EMS. By anticipating new requirements and making changes to your operations, you can avoid some future compliance obligations and their associated costs.
Getting Started
Your EMS should include a procedure for identifying and having access to the legal and other requirements that apply to your organization. These "other requirements" might include industry codes, the CERES Principles, or similar requirements to which your organization may subscribe.
The process of identifying applicable regulations, interpreting them, and determining
their impacts on your operations can be a time-consuming task. Fortunately, there are many
ways in which your organization can obtain information about applicable laws or
regulations.
These include:
. commercial services (offered on-line, on computer disk, and on paper);
. regulatory agencies (federal, state and local);
. trade groups / associations;
. public libraries;
. seminars and courses;
. newsletters / magazines;
. consultants and lawyers;
. the internet; and
. customers, vendors and other companies
Small business assistance programs exist in every state. Under the Clean Air Amendments of 1990, each state environmental regulatory agency must establish a technical and compliance assistance program to help companies comply with air quality rules. These programs are being expanded into other environmental "media" (e.g., water, waste management) as well. In addition, National Compliance Assistance Centers can provide compliance assistance for certain industry sectors (see Section 6 & Annex C for more information).
Once the applicable legal and other requirements have been identified and analyzed for their impacts, you should communicate these requirements (and plans for complying with them) to be appropriate people within the organization. Communicating the "other requirements" that apply to your organization (as well as their impacts) is an important - and often overlooked- step.
A list of some resources you can use to identify and track environmental lawas and regulations is provided in the Tool Kit (see page 104). Annex C also contains additional sources of information about environmental laws and regulations. The Tool Kit contains a sample procedure for tracking environmental laws and regulations (see page 106).
Commonly Applicable Feferal Environmental Laws in the US
| Clean Air Act (CAA) [40 CFR Parts 50-99] |
Establishes ambient and sources emisssion standards and permit requirements for conventional and hazardous air pollutants. |
| Clean Water Act (CWA) [40 CFR Parts 100-145, 220-232, 410-471] |
Establishes ambient and point source effluent standards and permit requirements for water pollutants, including those discharged directly to a waterbody and to a public sewer. |
| Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) [40 CFR Parts 150-189] |
Establishes a program for the review of, registration, and control of pesticides. |
| Resource Conservation and Recovery Act (RCRA) [40 CFR Parts 240-299] |
Establishes regulations and permit requirements for hazardous waste management. Also, creates standards for underground storage tanks holding oil or hazardous substances. |
| Toxic Substances Control Act (TSCA) [40 CFR Parts 700-799] |
Regulates de use, development, manufacture, distribution and disposal of chemicals. Certain chemicals (such as PCB's) targeted for specific management standards. |
| Comprehensive Environmental Response, Compensation and Liability Act (CERCLA, also known as "Superfund") [40 CFR Parts 300-311] |
Establishes program for cleaning up contaminated sites and establisches liability for clean-up costs. Also, provies reporting requirements for releases of hazardous substances. |
| Emergency Planning and Community Right-To-Know Act (EPCRA) [40 CFR Parts 350-374] |
Establishes a program to inform the public about the hazardous and toxic chemicals used by industries. Reporting requirements apply to companies using, processing, or storing specific chemicals over specified quantities. |
| Hazardous Materials Transportation Act (HMTA) [49 CFR Parts 100-180] |
Establishes standards for the safe transportation of hazardous materials. |
How will objectives and targets help my organization?
What does my organization do to achieve its policy?
Objectives and targets help you translate purpose into action - they should be factored into your strategic plan and can facilitate the integration of environmental management with other business management processes.
You determine what objectives and targets are appropriate for your organization. These goals can be organization-wide or applied to individual units or activities. In setting objectives, keep in mind your environmental policy, including its three "pillars". You should also consider your significant environmental aspects, applicable legal and other requirements, the views of interested parties, your technological options, and financial, operational, and other business requirements
There are no "standard" environmental objectives that fit all organizations. Your objectives and targets should reflect what your organization does and what it wants to achieve.
Hints:
. Objectives and targets should be set by the people in the functional area involved - they will be best positioned to establish, plan for, and achieve these goals.
. Involving people in the area will help to build commitment.
. Objectives should be consistent with your overall business mission and plan ant the key commitments established in your policy (pollution, prevention, continual improvement, and compliance).
. Be flexible in your objectives. Define a desired result and let the people responsible determine how to achieve the result.
. Keep your objectives simple initially, gain some early successes, and then build on them.
. Communicate objectives and targets (as well as your progress in achieving them) across the organization. Consider a regular report on progress at staff meetings.
. To obtain the views of interested parties consider holding an open house or establishing a focus group with people in the community. These activities can have other payoffs as well.
. Make sure your objectives and targets are realistic. Determine how you will measure progress towards achieving them.
. Keep in mind that your suppliers (service or materials) can help you in meeting your objectives and targets (e.g., by providing more environmentally friendly products).
** Pollution prevention**
The most significant savings from Pacific Gas & Electric's EMS have como from
reductions in hazardous waste generation and disposal. Ten years ago the hazardous waste
generated by operations exceeded 90,000 tons per year - now that number is below 10,000
tons per year and is still falling.
Comparing Objectives and Targets - Some Examples
| Objectives | Targets |
| Reduce energy use | . Reduce electricity use by 10% in 1996 . Reduce natural gas use by 15% in 1996 |
| Reduce usage of hazardous chemicals | . Eliminate use of CFC's by 1997 . Reduce use of high-VOC paints by 25% |
| Reduce hazardous waste generation | . Reduce chrome wastes in plating area by 50% in 1997 |
| 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 1997 |
** Pollution Prevention**
Warner-Lambert Company used a "holistic"
approach to identify its waste streams.
The company looked beyond emissions from its property and considered all of the
ramifications of its activities...
By replacing chillers and redesingning the chilling system to be more efficient, the company has realized $250,000 in energy savings. Because the company is more energy efficient, it has reduced emissions at the local power plant!
By redesigning and revising dust collection, the company now uses 40 hp instead of 100 hp (without compromising the effectiveness of the dust collection system), has lowered its opreating costs (and reduced emissions at the local power plant).
Why do we need an environmental management program?
A road map for achieving your environmental goals
So far, this Guide has focused on the foundations of your EMS (the
planning elements) and on defining what your organizaion intends to achieve in the
environmental area.
To ensure that objectives and targets are achieved, you need an action plan.
The environmental management program should be linked directly to your objectives and targests - that is, the program should describe how the organization will translate its goals into concrete actions so that environmental objectives and targets will be achieved.
To ensure its effectiveness, your environmental management program should:
. designate responsibilities for achieving goals, and
. define the means and time frame for achieving those goals.
Keep in mind that your program should be a dynamic one. Consider modifying the program when:
. objectives and targets are revised or added;
. progress in achieving your objectives and targets is made - or not
made; or
. products, processes, or facilities change or other factors arise.
Your action plan need not be compiled into a single document. A "road map" to several plans is an acceptable alternative, as long as the key resposibilities, tactical steps and schedules are adequately defined in these other documents.
Keep in mind that this program should not be developed in a vacuum it should be coordinated or integrated with other business plans, strategies, and budgets. For example, if you are planning changes to a manufacturing proces (say, for quality or production purposes), then it makes sense to look at the possible environmental issues associated with this process change at the same time.
Hints
. Involve your employees early in establishing and carrying out the program
.. Clealy communicate the expectatios and resposibilities
laid out in the program to those who
need to know.
. Build on the plans and programs you have now for
environment compliance, health & safety,
and/or quality management purposes.
. Re-evaluate your action plan when you are considering
significant changes to your products,
processes, facilities or materials. Make this re-evaluation part of your change
management
process.
. Keep it simple (see sample tool, below) and focus on
continual improvement of the program
over time.
Thought to Keep in Mind: There may be real opportunities here!! Coordinating your environmental program with your overall business plans and strategies may position your organization to exploit some significant cost-saving opportunities.
Environmental Management Program--Sample Tool
| Action Items |
Priority | Responsibilities | Schedule | Resources Needed | Comments |
| . . . . . |
(Note: A full-size copy of this tool is provided in the Tool
Kit - )
A Sample Schedule for an EMS Action Plan is provided in the Tool Kit
How does our organizational structure affect environmental management?
Aligning your resources to succeed
For your EMS to be effective, roles and responsibilities must be clearly defined and communicated. In a small organization, the commitment of all employees is needed.
Top management plays a key role by providing the resources needed to ensure that the EMS is implemented effectively. Ensuring this capability is one of the most important jobs of top management (see "Finding Resources" on next page).
Any effective management system needs an advocate. Top management should appoint a management representative. This representative (1) ensures that the EMS is established and implemented; (2) reports on its performance over time; and (3) works with others to modify the EMS when necessary. The management representative could be the same person who serves as the project champion (as discussed in Section 3), but this is not mandatory. Management can use information on EMS performance to improve the system over time. (A business owner, plant or shop manager, or any number of other people might serve as an effective management representative.)
Small and medium -sized businesses may have an advantage over larger businesses in structuring their organizations for environmental management. Because personnel and other resources are generally more limited in small businesses, people often "wear more than one hat" and are experienced in performing multiple functions. In some cases, the individual responsible for environmental management in a small firm is also responsible for quality, health & safety, facilities, or other related functions. For this reason, integrating environmental responsibilities with other functions can be greatly simplified.
Getting Started:
The following questions can help you determine the right organizational structure for environmental management:
. Look at the scope of your environmental management program: What capabilities do we need? Who needs to be involved to make the system effective? What training or other resources will they need?
. Look at your significant environmental impacts": What operations / activities need to be controlled? Who needs to be involved to ensure that controls are implemented?
. Look at the results of previous audits or other assessments:What does this information tell us about the effectiveness of our organizational structure? How could it be improved?
. Look at the current responsibilites for environmental management: How can we enhance ownership of environmental management across the organization? How can other business functions support the EMS? (See next page).
. Look at your quality management and / or other existing management systems: What roles and responsibilities exist in these management systems: Where are the opportunities for integration?
Consider flow charting your organization's activities relating to environmental management. This can help your understand how processes work and the final product can be a great communicatio and training tool. Flow charts might be useful to look at processes such as chemical purchasing and distribution, employee training, and preventive maintenance, among others.
Hints:
. Build flexibility into your organization's EMS. Recognize that environmental (and other) management needs will change over time.
. Be sure to communicate to people what their roles are (as well as the roles of others). One tool for communicating these responsibilities is a responsibility matrix (an example of which is provided in the Tool Kit.
Finding Resources
In most cases, developing and maintaining an EMS will not require large capital autlays. What an EMS will require is time. Many small organizations have found that they can make effective use of interns or temporary employees to perform potentially time-consuming EMS development tasks (such as collecting data, drafting and typing procedures, etc). This approach allows in-house personnel to focus on more complex EMS development tasks.
Also, exploit the links between environmental management and other aspects of your organization. Look for areas where environmental management can support other business functions.
How Various Functions Can Support Your EMS
| Functions | How They Can Help (Possible Roles) |
| Purchasing | .Develop and implement controls for chemical/ other material purchases |
| Human Resources | . Define competency requirements and job descriptions for various EMS
roles .Integrate environmenal management into reward, discipline and appraisal systems |
| Maintenance | . Implement preventive maintenance program for key equipment. |
| Finance | . Track data on environmental management costs .Prepare budgets for environmental management program .Evaluate economic feasibility of environmental projects. |
| Engineering | .Consider environmental impacts of new or modified products and processes. . Identify pollution prevention opportunities |
| Top Management | .Communicate importance of EMS throughout organization .Provide necessary resources .Track and review EMS performance |
| Line Workers | . Provide first-hand knowledge of environmental aspects of their
operations . Support training for new employees |
Why is training important to he success of our EMS?
Building internal capabilites
There are two excellent reasons for training employees about environmental management and your EMS:
. Every employee can have an impact on the environment.
. Any employee can have good ideas about how to improve environmental management efforts.
Each person an function withing your organization can play a role in
environmental maangement. For this reason, your training program should cast a wide net.
Everyone in the organization should be trained on the environmental policy, significant
enrironmental impacts of their work activities, key EMS roles and responsibilities,
procedures that apply to their activities, and the importance of conformance with EMS
requirements.
All personnel should receive appropiate training. However, training is just one element of establishing competence, which is typically based on a combination of education, training, and experience. For certain key roles (including tasks which can cause significat environmental impacts), you should establish criteria for measuring the competence of individuals performing those tasks.
Getting Started:
. A critical first step in developing your training program is assessing your training and skill needs. In assessing these needs, your should consider both general and specific aspects (e.g., "What EMS procedures affect Joe's daily work and what happens if they aren't followed?" "What environmental impacts might Joe's work cause?" "What broader understanding of environmental issues and our EMS does Joe need?")
. Look at the training you conduct already, for compliance with environmental and health and safety regulations and other purposes. Your may find that your existing training efforts go a long way towards satisfying the requirements for the EMS.
Key Steps in Developing a Training Program
Step 1: Assess training needs & requirements
Step 2: Define training objectives
Step 3: Select suitable programs and methods
Step 4: Prepare training plan (who, what, when, where, how)
Step 5: Implement training program
Step 6: Track training (and maintain records)
Step 7: Evaluate training effectiveness
Step 8: Improve training program (as needed)
Hints:
. Because of the level of effort involved in a training program, this is one EMS area where your don't want to start from scratch. Many employees may already be qualified on the basis of ther experience and previous training. (Keep in mind that all training should be documented.) Since some employees may require training on how to run a process safely, on the-job training certainly plays a role.
. Plan and schedule training opportunities carefully. While finding enough time for training can be a challenge, there may be creative ways to make "more time" (see box above left). Use venues like safety meetings, staff meetings, and tool box meetings to provide "training" and reinforce key messages.
. New emplyees can pose a significant training challenge. Consider developing and EMS training package for new employee orientation. Even better, videotape one of your current EMS training, courses to show new employees.
. In reviewing training needs, don't forget to consider the qualifications and training needs of your environmental manager and your trainers. Professional certification programs may be appropriate for certain functions.
. Factor your EMS skills requirements into your recruiting, selection, and new employee orientation efforts (as noted above).
. Establishing competency for various tasks can be a challenge. Competency criteria for jobs that can cause significant environmental impacts should be as objective as possible.
One informal method for assessing competency is to question employees in critical functions as to how they perform various aspects of their jobs (e.g, "Show me how you......."). Use responses to determine whether they have the requisite skills and understanding to do the job safely. This will help your gauge whether additional training may be needed.
. Consider "job aids" to supplement training or help establish competence. Examples of job aids include written or pictorial job procedures, decision tables or flow charts.
How are communications critical to the success of our EMS?
Opening the information lines
The importance of employee involvement in developing and implementing your EMS has been discussed earlier. Effective environmental management requires effective communications.
Communications will help you:
. motivate the workforce;
. explain the environmental policy (both internally and externally) and
how it relates to the overall business vision / strategy;
. ensure understanding of roles and expectations;
. demostrate management commitment;
. monitor performance, and,
. identify potential system improvements.
Effective internal communications require mechanisms for information to flow top-down and bottom-up. Since employee are on the "front lines", they are often an excellent source of information, issues and ideas.
Communication with external parties is also important for effective environmental management. Obtaining the views of neighbors, community groups, and customers, (among others), will help your understand how your organization is perceived by others. Information from external sources can be critical in setting environmental and other business goals.
An effective EMS should include procedures for:
. communicating internally (between levels and functions), and
. soliciting, receiving, documenting and responding to external
communications.
Getting Started:
The first step in designing a communications program is determining your audiences. Make a list of internal and external audiences.
Once you identify the audiences, your should ten determine what your need to cummunicate with them. (What do they need to know about your productos or operations? What are their concerns?)
Next decide how you can best reach them. Appropriate communication methods might vary from audience to audience. Start by looking at your existing methods for communicating, both internally and externally. These might include:
Internal Methods External Methods
. newsletters
. open houses
. staff meetings
. focus groups
. employee meetings
. press releases
. bulletin boards
. annual reports
. brown bag lunches
. advertinsing
Hints:
. Determine how proactive your external communications strategy will be. Select an approach that fits your organization's culture and strategy. For example, will reporting on environmental performance and progress give your an edge over the competition?
While a proactive external communications program may require more resources, some organizations have found that a proactive strategy can be quite beneficial. Weigh the costs and benefits for yourself, but keep in mind that there might be many interested audiences.
. In communicating with employees, it is helpful to explain not only what they need to do but why they need to do it. For example, when describing a requirement based on a regulation, simply saving "the regulations require it" is not sufficient explanation. Try to explain the purpose behind the rule and why they need to do it. For exampli, when describing a requirement based on a regulation, simply saying "the regulations require it" is not sufficient explanation. Try to explain the purpose behind the rule and why it is important. Also make a clear connection between the requirement and how it applies to each person's job.
. Keep the message simple - all communications should be clear, concide, and accurate.
. Managing responses to external inquiries does not habe to be a burdensome task. Use a simple method, such as stapling an inquiry to its written response and then filing them together. The key is to be able to demonstrate that the organization has a system for responding to external inquiries.
Why do we need documentation of our EMS?
Describing your EMS and how the pieces fit together
To ensure that your EMS is well undestood and operating as designed, your need to get information to the people doing the work. In addition, there are external parties that might need to understand how your EMS operates, such as customers, registrars, regulators, lending institutions, and the public. A "road map" of your EMS explaining how the pieces fit together can be a very useful tool.
EMS documentation can be viewed as a series of explanations or statements of how EMS criteria (such as ISO 14001) apply to your organization. While you don't need to maintain a single ''manual", you should maintain EMS information in a form that:
. describes the core elements of your EMS (and how these elements
relate to each other), and
. provides direction to related documentation.
You maintain this documentation either on paper or electronically. There may be some advantages to maintaing documents electronically, such as easier updating, access control, and enruring that the most up-to-date version of a document is used by all readers.
EMS documentation is related to (but not the same as) EMS records. EMS documentation describes what your system consists of (i.e., what you do) while EMS records demonstrate that you are doing what your said you would do. EMS records are described later in this Guide.
Policy
EMS Manual
Procedures
Forms, Drawings, etc.
One way to thing about your EMS documentacion is to use the figure shown above, which also applies to ISO 9000 documents.
Hints:
. Keep your EMS documentation simple and choose a format that works best for your organization. The documentatios does not need to describe every detail of your EMS or how your organization conforms to the ISO 14001 Standard (or other EMS criteria). Instead, consider providing references to other documents or procedures.
. Use the results of your preliminary assessment to prepare your EMS documentation. In the course of conducting the preliminary assessment, you should have collected or prepared useful material on how your organization satisfies the EMS criteria.
. The usefulness of your EMS documentation can be improved by including the organization's mission statement, vision, guilding principles and annual objectives (if these exist). These will help readers undestand the organizational context and how the EMS supports overall business goals.
. An EMS manual can be a useful tool for explaining your EMS to new emplyees, customers, or others. A sample outline for an EMS manual is provides in the Tool Kit.
. EMS documentation should be updated as needed, based on any system improvements you put in place. However, if you put too much detail in an EMS manual, you may have to update the manual frequently.
How do we ensure everyone is working with the right information?
People in your organization probably use various documents (drawings, work instructions and the like) as they perform their duties. To ensure that your personnel are consistently doing the job right, the organization must provide them with the right tools. In this case, the tools needed are the correct and up-to-date procedures, drawings and other documents, the organization has no way of knowing (or veryfying) that people are working with the right tools.
To ensure that everyone is working with the proper EMS documents, your organization should have a procedure that describes how documents are controlled. Implementation of this procedure should ensure that:
Your document control 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 change documents and what the change process is.
Getting Started:
. EMS document control requirements are almost a mirror image of the ISO 9000 requirements. Organizations that have or are developing an ISO 9000 management system can enjoy some advantages here.
. Even if your organization doesn't have an ISO 9000 system, you might be better off than your think. Your organization probably has document controls in place for other business purposes (such as finance, human resources or purchasing). Assess how well these controls work and if they can be adapted for your EMS.
Hints:
. Don't make your procedure more complicated than it needs to be. While larger organizations often have complex processes for document control, smaller organizations can use simpler systems.
. Limiting distribution makes the job easier. Does everyone have access to one or a few copies? Determine how many copies your really need and where they should be lacated for ease of access.
. If the people that need access to documents are connected to a local area network, consider using a paperless system. This can facilitate control and revision of documents considerably.
. Prepare a document control index that shows all of your EMS documents and the history of their revision. Put this index in your manual. Also, if multiple copies of documents are available at the facility, prepare a distribution list, showing who has each copy and where the copies are located.
. As your precedures or other documents are revised, highlight the changes (by underlining, boldface, etc.). This will make it easier for the reader to find the changes.
The Tool Kit contains a sample document control procedure and a sample index of EMS controlled documents.
| Document Requirements | EMS Documentation |
Procedures | Policy | Others... |
| Document Control Requirements | Preparation | Issuance | Revision | Disposition |
| Records Requirements | Identification | Retention | Storage | Disposition |
Linkages among EMS documentation, document control and records
What operations and activities must be controlled for environmental management?
Building in performance
To ensure that your environmental policy is followed and that your objectives are achieved, certain operations and activities must be controlled. Where an operation or activity is complex and/or the potential environmental impacts are significant, these controls should take the form of documented procedures. Procedures can help your organization to ensure regulatory compliance and consistent environmental performance. Procedures can also play a key role in employee training.
Documented procedures should cover those situations where the absence of procedures could lead to desviations from the environmental policy or your objectives and targets. Determining which operations should be covered by documented procedures and how those operations should be covered by documented procedures and how those operations should be controlled is a critical aspect of developing an effective EMS.
In deciding which activities need to be controlled, look beyond routine production on the shop floor. Activities such as maintenance, management of on-site contractors and relationships with suppliers or vendors could affect your organization's environmental performance significantly.
Getting Started:
. Start by looking at the environmental aspects and potentially significant impacts which you identified earlier. Idently the processes from which these significant impacts arise, and consider what types of controls might be needed to prevent or manage these impacts. If you have flow charts of these processes, identify the points in each process where some type of control may be appropriate.
. Prepare draft procedures and review them with the people who will need to implement them. This will help to ensure that the procedures are accurate and realistic.
Hints:
. Look at procedures your already have in place to comply with environmental and health & safety regulations. Some of these may be adequate to control significant impacts (or could be modified to do so). Develop a chart to keep track of what is needed:
| Procedure needed (none exists) |
Procedure exists, but is not documented |
Procedure exists and is documented |
No procedure needed |
| . . . .
|
. Rules of Thumb: the more highly skilled and trained your employees are, the less critical procedures will be. The more complex the work or the greater the potential impact on the environment, the more important these procedures will be.
. Once you have identified operations that require control, consider what kinds of maintenance and calibration may be appropriate. However, the need for maintenance on equipment that could have significant environmental impacts should be obvious, and the need to plan and control such maintenance should not be overlooked. This does not mean that an elaborate preventive or predictive maintenance program is needed in all cases. Assess your existing maintenance program and tis effectiveness before making significant changes.
Hints on Writing Procedures
- Understad the existing process (start with a flow
chart, if one is available). Build on informal procedures where possible.
- Focus on steps needed for consistent implementation.
- Use a consistent format and approach.
- Review draft procedures with emplyees that will have to implement them.
(Better yet, enlist employees to help write them.)
- Keep procedures simple and concise. Excessive detail doesn't provide
more control and is not needed.
. Some of your identified environmental aspects may be related to he 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 develpment of procedures can be time consuming, some organizations have como up with creative ways to reduce the data collection burden. Consider having a college intern or temporary employee interview your employees "on the line" to collect information on what employees do and how they do it.
. If your organization uses a "work team" concept, ask the work teams to draft procedures for their areas (or to modify existing procedures for EMS purposes).
How should we be prepared for accidents and emergencies?
Minimizing the impacts of uncontrolled events
Despite an organization's best efforts, the possibility of accidents and other emergency situations still exits. Effective planning and preparation can reduce injuries, protect employees and neighbors, reduce asset losses and minimize production downtime.
An effective emergency preparedness and response program should include
provisions for:
.assesing the potential for accidents and emergencies;
. preventing incidents and their associated environmental impacts;
. plans / procedures for responding to incidents;
. periodic testing of emergency plans / procedures, and,
. mitigating impacts associated with these incidents.
Consistent with your organization's focus on continual improvement, it also is a good idea to review emergency response performace after an incident has accured. This review can help determine if more training is needed or if emergency plans / procedures should be revised.
Getting Started:
. This is another area where you should not have to start from scratch. Several
environmental and health and safety regulatory programs require emergency plans and/or
procedures. Look at what you have in place now and assess how well it satisfies the items
discussed above.
. One area where additional work is often needed is on identifying the potential for accidents and emergencies. A team of site personnel (from engineering, maintenance and Environmental Health & Safety, for example) can identify most potential emergencies by asking a series of "What if" questions related to hazardous materials, activities, and processes employed at the site.In addition to normal operations, the team should consider start-up and shutdown of process equipment, and other abnormal operating conditions.
. Ask yourself: Does everyone (including new employees) know what to do in an emergency? How would contractors or site visitors know what to do in an emergency situation?
. Communicate with local officials (fire department, hospital, etc) about potential emergencies at your site and how they can support your response efforts.
Hints:
. Mock drills can be an excellent way to reinforce training and get feedback on the effectiveness of your plans/ procedures.
. Post copies of the plan (or at least critical contact names and phone numbers) around the site and especially in areas where high hazards exist. Include phone numbers for your on-site emergency coodinator, local fire department, local police, hospital, rescue squad, and others as appropriate.
How do we know how we are doing?
Assessing how well the system is working
An EMS without an effective monitoring and measurement program is like driving at night without the headlights on you know that you are moving but you can't tell where you are going! Monitoring and measurement enables you to:
. gauge your environmental performance;
. analyze root causes of problems;
. identify areas where corrective action is needed; and,
. improve performance / increase efficiency.
In short, monitoring helps you manage your business better. Pollution prevention and other strategic business opportunities are identified more readily when current and reliable data is available.
Your organization should develop procedures to:
. monitor key characteristics of operations and
activities that can have significant environmental impacts;
. track performance (including how well your meet your objectives and
targets);
. calibrate and maintain monitoring equipment; and
. through internal audits, periodically evaluate your compliance with
applicable laws and regulations.
Getting Started:
. Monitoring and measuring can be resource-intensive. One of the most importan steps you can take is to clearly define your needs. While collecting information is clearly important, resist the urge to collect data "for data's sake"
. Review the kinds of monitoring you do now for regulatory compliance and other purposes (such as quality or health and safety management). How well does this serve your EMS purposes? What additional monitoring or measuring might be needed?
. You can start with a relatively simple monitoring and measurement system, then build on it as you gain experience.
Hints:
. Monitoring key process characteristics: Many management theorists endorse the concept of the "vital few" - that is, that a limited number of factors can be measured to determine the outcome of a process. The key is to figue out what those factors are and how to measure them. Root cause analysis is one way to identify what those factors might be.
. Most effective environmental measurement systems use a combination of process and outcome measure. 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, on the other hand, look at "upstream" factors, such as the amount of paint used per unit of product or the number of employees trained. A combination of process and outcome measures may be right for your organization.
. Equipment calibration: Identify process equipment and activities that truly affect your environmental performance. As a starting point, look at the key process characteristics you identified earlier. Some companies choose to puy key monitoring equipment under a special calibration and preventive maintenance program. This can help to ensure accurate monitoring and lets employess know which instruments are most critical for environmental monitoring purposes. In some cases, it may be more cost-effective to subcontract calibration and maintenance of monitoring purposes. In some cases, it may be more cost-effective to subcontract calibration and maintenance of monitoring equipment than to perform these functions internally.
. Assessing regulatory compliance: Determining your compliance status on a regular basics is very important. You should have a process to systematically identify, correct, and prevent violations. Performance of the compliance management program should be considered during EMS management review. The box below describes some of the characteristics of a good compliance management program.
. Evaluating environmental performance: Go back and look at your significant environmental aspects and the objectives and targets associated with those significant aspects. What information will you need to determine if the company is achieving its objectives and targets?
Focus on things that you can do something about!
. Start by selecting a few performance indicators that are:
- simple and undestandable
- objetive
- verifiable
- relevant to what your organization does (i.e., its activities, products, and
services)
. Make sure you can commit the necessary resources to track this information over time. It is OK to start small and build over time as your company gains experience in evaluating its performance. Keep in mind that no single measurement will tell your organization how it is doing in the environmental area.
. People respond best to information that is meaningful to "their world". Putting environmental information in a form that is relevant to their function increases the likelihood they will act on the information. Be sure to link your measurement program with your communications program and other elements of the EMS (such as management reviews, as discussed later).
. The distinction between audits and environmental performance evaluation can be confusing. The figure below is intended to explain the two concepts. Both are important to your EMS.
Distinguishing
Auditing from Environmental
Performance Evaluation
Audits EPE
. periodic
. ongoing
.
sample of data
. frequent
.
independent
. line function
. verifies conformance
. assesses performance
What do we do when we find a problem?
Fixing EMS problems and avoiding them in the future
No EMS is perfect. You will probably find problems with your system, especially in the beginning (through audits, measurement, or other activities). Your EMS will also need to change as your organization changes and grows. When system dificiencies are encountered, your organization will need a process to ensure that:
EMS nonconformities and other system deficiencies should be analyzed to detect patterns or trends. Identifying these trends will allow your to anticipate and prevent future problems.
Focus on correcting and preventing problems. Preventing problems is generally cheaper than fixing them after they occur (or after they reoccur). This approach is consistent with the continual improvement philosophy
Hints:
. If your organization has an ISO 9000 management system, you should already have a corrective / preventive action process for quality purposes. You can use this as a model (or integrate with it) for EMS purposes.
. Small companies might find they can combine their management review and corrective action processes, especially if the same people are involved in both. At the very least, a strong link should exist between the two processes.
. The amount of planning and documentation needed for corrective / preventive actions can vary with the severity of the problem (and its potential environmental impacts). Don't go overboard with bureaucracy - simple methods often work best.
. Once you document a problem, the organization must be commited to resolving it. Corrective actions should be implemented as quickly as possible. Be sure that your corrective / preventive action process specifies responsibilities and schedules. Review your progress regularly and follow up on any deficiencies.
. Make sure you collect the right data / information to make good decisions. While many corrective actions may be "common sense", you need to look below the surface to determine why a problem has occurred.
. Initially, most EMS problems may be identified by your auditors. However, over the long run, most problems and good ideas may come from the people in the shop doing the work. This should be encouraged. Find ways to get employees involved in the system improvement process (for example, via suggestion boxes, contests and incentive programs).
How do we probe that our EMS is working?
Evidence that the EMS is working properly
The value of records management is fairly simple you should be able to prove that your organization is actually implementing the EMS as designed. While records have value internally, over time you may need to provide evidence of EMS implementation to external parties (such as customers, a registrar, or the public). Records management is often viewed as bureaucratic, but it is hard to imagine a process or system operating consistently without keeping accurate records.
Basic records management is straightforward you need to decide what records you will keep, how you will keep them and for how long. You should also think about how you will dispose of records once you no loger nedd them.
Íf your oganization has an ISO 9000 management system, you should have a system for managing quality records.
Hints:
. Focus on records that add value avoid bureaucracy. If records have no value, then don't collect them. The records your choose to keep should be accurate and complete.
. You may need to generate certain forms as you develop your EMS . These forms should be simple and understandable.
. Consider combining your records management processes for environmental and health & safety records.
. Establish a records retention policy and stick to it. Make sure that your policy takes into account records retention requirements specified in applicable environmental regultations.
. In designing your records management system, be sure to consider:
-who needs access?
-to what records?
-in what circumstances?
. If your organization uses computers extensively, consider usig an electronic EMS records management system. Maintaining records electronically can provide an excellent means for rapid retrieval of records as well as controlling access to sensitive records.
. Think about which records might require additional security. Do you need to restrict access to certain records? Should a back-up copy of critical records be maintained at another location?
Types of Records You Might Maintain (Examples):
. legal, regulatory and other code requirements
. results of environmental aspects identification
. reports of progress towards meeting objectives and targets
. permits, licenses and other approvals
. training records
. EMS audit and regulatory compliance audit reports
. reports of identified nonconformities, corrective action plans and
corrective action tracking data
. hazardous material spill / other incident reports
. communications with customers, suppliers, contractors and other
external parties
. results of management reviews
. sampling and monitoring data
. maintenance records
. equipment calibration records
* ISO 14001 requires that organizations have procedures for training records and the results of audits and reviews *
Are we doing what we said we would do?
Objective evidence of conformance with EMS requirements
Once your organization has established its EMS verifying the implementation of the system will be critical. To identify and resolve EMS deficiencies you must actively seek them out.
In a small organization, audits are particularly relevant since managers are often so close to the work they may not see problems or bad habits that have developed. Periodic EMS audits will establish whether or not all of the requirements of the EMS are being carried out in the specified manner.
For your EMS audit program to be effective, you should:
. develop audit procedures and
protocols;
. establish an appropriate audit frequency;
. train your auditors; and,
. maintain audit records.
The results of your EMS audits should be linked to the corrective action system (as
described earlier).
While they can be time-cosuming, EMS audits are critical to EMS
effectiveness. Systematic identification and reporting of EMS deficiencies to management
provides a great opportunity to:
. maintain management focus on the environment,
. improve the EMS, and
. ensure its cost-effectiveness.
Getting Started:
. How frequently do we need to audit? In determining the frequency of your EMS audits, some issues to consider are:
- the nature of your operations
- the significant environmental aspects / impacts (which you identified
earlier),
- the results of your monitoring program, and
- the results of previous audits.
As a rule of thrumb, all parts of the EMS should be audited at least annually. You can audit the entire EMS at one time or break it down into discrete elements for more frequent audits. (There may be advantages to more frequent audits, but the decision is up to you).
. Who will perform the audits? You will need trained EMS auditors. Auditor training should be both initial and ongoing. Commercial EMS auditor training is available, but it might be more cost-effective to link up with businesses and other organizations in your area (perhaps through a trade association) to sponsor an auditor training course. A local community college might also provide auditor training.
EMS auditors should be trained in auditing techniques and management system concepts. Familiarity with environmental regulations, facility operations, and environmental science is a big plus, and in some cases may be essential to adequately assess the EMS. Some auditor training can be obtained on-the-job. Your organization's first few EMS audits can be considered part of your auditor training program (but make sure that an experienced auditor takes part in those "training" audits).
If your company is registered under ISO 9000, consider using your internal ISO 9000 auditors as EMS auditors. Although some additional training might be needed, many of the required skills are the same for both types of audits.
. How should management use audit results?
Management can use EMS audit results to identify trends or patterns in EMS deficiencies.
The organization must also make sure that any identified system gaps / deficiencies are
corrected in a timely fashion and that the corrective actions are documented.
Hints:
. Your EMS audits should focus on objective evidence of conformance. (If you cannot tell whether or not a particular procedure has been followed, then you should consider revising the procedure). During the actual audit, auditors should resist the temptation to evaluate why a procedure was not followed - that step comes later.
. During the course of the audit, auditors should discuss identified deficiencies with the people who work in the area. This will help the auditors verify that their understanding is correct. It also allows audits to take place when one auditor has a schedule conflict (which is unavoidable in a small organization).
Some Options for Auditing
- Barter for audit services with other small companies
- Use external auditors
- Have office personnel audit production areas (and viceversa)
. Before you start an audit, be sure to communicate the audit scope, schedule, and other pertinent information with the people in the affected area (s). This will help avoid confusio and will facilitate the audit process.
. Consider linking your EMS audit program to your regulatory compliance audit process. But keep in mind that these audit programs have different purposes, and while you might want to communicate the results of compliance audits might need to be communicated in a more limited fashion (in order to maintain attorney- client or attorney work product privilege, for example).
. The Tool Kit includes a sample EMS audit procedure
How do we ensure that our EMS will remain viable?
Just as a person should have periodic physical exams, your EMS must be reviewed by manageent from time to time to stay "healthy". Management reviews are the key to continual improvement and to ensuring that the EMS will continue to meet your organization's needs over time.
Management reviews also offer a great opportunity to keep your EMS efficient and cost-effective. For example, some organizations have found that certain procedures and processes initially put in place were not needed to achieve their environmental objectives or control key processes. If EMS procedures and other activities don't add value, eliminate them.
The key question that a management review seeks to answer is:
"Is the system working?" (i.e., is the EMS suitable, adequate and effective, given our needs?)
Hints:
. There are two kinds of people who should be involved in the management review process:
- people who have the right information / knowledge
- people who can make decisions
. Determine the frequency for management reviews that will work best for your organization. Some organizations combine these reviws with other meetings (such as director meetings) while other organizations hold "stand-alone" reviews. For ISO 9000 purposes, management reviews are typically held once or twice per year.
. Regardiess of what approach your organization takes, make sure that someone takes notes on what issues were discussed, what decisions were arrived at, and what action items were selected. Management reviews should be documented.
. The management review should assess how changing circumstances might influece the suitability, effectiveness or adequacy of your EMS. Changing circumstances may be internal to your organization (i.e, new facilities, new materials, changes in products of services, new customers, etc). or may be external factors (such as new laws, new scientific information, or changes in adjacent land use).
. Once you have documented the action items arising from your management review, be sure that someone follows-up. Progress on these items should be tracked.
. As you evaluate potential changes to your EMS, be sure to consider your other organizational plans and goals. Environmental decision-making should be integrated into your overall management and strategy.