Integrated

Environmental Management Systems

Implementation Guide

+--------------+----------------------------------------+--------------+
| ![]          | Design for the Environment Program     | ![           |
| (media/image |                                        | ](media/imag |
| 1.png){width | Economics, Exposure, and Technology    | e2.wmf){widt |
| ="1.29375in" | Division                               | h="1.1652777 |
| height       |                                        | 777777779in" |
| ="1.22847222 | Office of Pollution Prevention and     | heigh        |
| 22222222in"} | Toxics                                 | t="1.1451388 |
|              |                                        | 88888889in"} |
|              | U.S. Environmental Protection Agency   |              |
+--------------+----------------------------------------+--------------+

For further information about DfE's Integrated Environmental Management
Systems Programs, please contact:

The Design for the Environment Program

Economics, Exposure, and Technology Division

Office of Pollution Prevention and Toxics

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue N.W. (MC 7406)

Washington, D.C. 20460

202-260-1678

www.epa.gov/dfe

To order additional copies of this Guide, please contact EPA's Pollution
Prevention Information Clearinghouse (PPIC) by phone (202-260-1023) or
e-mail (ppic@epa.gov). You may also download this Guide from the Design
for the Environment website (www.epa.gov/dfe).

**Acknowledgments**

This Guide is part of an effort to show how Design for the Environment
(DfE) technical work can be used to support development of an
**Environmental Management System (EMS)**. This Guide is based primarily
on EMS reference documents acknowledged in the references section, and
on DfE guidance documents such as the Cleaner Technologies Substitutes
Assessment Methodology. The Guide was prepared by Abt Associates Inc.,
Cambridge, MA, with Jean E. (Libby) Parker as lead author. The Abt
Associates project team included Cheryl Keenan, Dennis Chang, Susan
Altman, and Jonathan Greene.

The EPA Project Manager was Karen Chu, with the Design for the
Environment Program in the Economics, Exposure and Toxics Division,
Office of Pollution Prevention and Toxics. Bill Hanson is Director of
the Design for the Environment Program. Important contributions were
made by Carol Hetfield, Heather Tansey, Ted Cochin, and Jenny Fisher,
EPA.

The Guide was developed in close collaboration with the Eastern Research
Group, Inc. (ERG), Lexington, MA. The ERG project team included Jeff
Cantin, Dave Galbraith, and Owen Davis. We would also like to
acknowledge the important contributions of the University of Tennessee's
Knoxville Center for Clean Products and Clean Technologies and Tellus
Institute. The University of Tennessee project team included Lori
Kincaid, Mary Swanson, and Kerry Kelly. Karen Shapiro at Tellus
Institute helped develop the cost comparison section and provided
Appendix F. EPA\'s Pollution Prevention Division\'s Environmental
Accounting Project provided funding to Tellus for this contribution.

Valuable insights also were provided by Marci Kinter and Dan Marx of the
Screenprinting & Graphic Imaging Association International (SGIA),
Fairfax, VA, and by Foster Knight and Bob Ferrone of The Lexington
Group, Lexington, MA. Useful comments were received from William T.
Engel, Jr. of the Strategic Environmental Management Institute at the
University of Florida's Center for Training, Research and Education for
Environmental Occupations (UF/TREEO), Gainesville, FL.

Contents

Foreword i

DfE Program Principles iii

Figure A: DfE Substitutes Tree iv

Figure B: Pollution Prevention Hierarchy iv

How to Use This Guide v

Figure C: IEMS Process viii

Figure D. Road Map between ISO 14001 and IEMS ix

**MODULE 1: LAYING THE GROUNDWORK page 1**

Figure 1-a. The Continuous Improvement Cycle page 2

Figure 1-b. Functions to Include in Your IEMS Team page 7

Figure 1-c. Examples of Environmental Aspects and Associated Impacts
page 12

Figure 1-d. How an Activity Becomes an Impact page 12

Figure 1-e. Generic Process Map for Business Activities page 14

Figure 1-f. Product X --- Extended Responsibility page 15

Figure 1-g. Input-Output Diagram for a Step in a Manufacturing Operation
page 16

Figure 1-h. Input-Output Diagram for a Copier page 16

Figure 1-i. Input-Output Diagram for Cleaning a Printing Press page 17

Figure 1-j. Inputs and Outputs of a Company's Products and Services page
18

**MODULE 2: CREATING AN ENVIRONMENTAL POLICY page 23**

**MODULE 3: DETERMINING SIGNIFICANT ENVIRONMENTAL ASPECTS AND SETTING
OBJECTIVES page 35**

Figure 3-a: Ranking Symbols page 38

Figure 3-b: Information on an MSDS page 41

Figure 3-c: Screen Printing Exposure Pathways page 46

Figure 3-d: Dry Cleaning Exposure Pathways page 47

**MODULE 4: EVALUATING ALTERNATIVES page 62**

**MODULE 5: SETTING TARGETS AND MEASURING SUCCESS page 88**

Figure 5-a. Root Cause Diagram page 92

**MODULE 6: DEVELOPING OPERATIONAL CONTROLS page 94**

**MODULE 7: IMPLEMENTING YOUR IEMS page 106**

Figure 7-a. Sample Environmental Management Project Plan page 107

Figure 7-b. Sample Environmental Management Project Plan page 108

**MODULE 8: BUILDING ORGANIZATIONAL SUPPORT page 113**

Figure 8-a. Documentation Levels page 119

Figure 8-b. Levels of stakeholder interest page 125

**MODULE 9: ESTABLISHING CONTINUING IMPROVEMENT page 132**

**APPENDICES**

APPENDIX A: GLOSSARY 142

APPENDIX B: SAMPLE QUESTIONS TO ASK YOUR SUPPLIER 146

APPENDIX C: EXAMPLE PERFORMANCE EVALUATION WORKSHEETS 148

APPENDIX D: EXAMPLE ALTERNATIVES EVALUATION WORKSHEET 153

APPENDIX E: ALTERNATIVES EVALUATION SAMPLE WORKSHEETS 160

APPENDIX F: HOW TO EVALUATE COSTS AND SAVINGS OF ALTERNATIVES 182

APPENDIX G: REFERENCES AND RESOURCES 195

APPENDIX H: BLANK WORKSHEETS 202

Foreword

EPA's Design for the Environment (DfE) Program has over eight years of
experience building voluntary partnerships with industry, public
interest groups, universities, research institutions, and other
government agencies to develop cleaner, safer alternatives to existing
products and processes and to manage change in the systems businesses
use to address environmental concerns. The DfE Program has developed
technical methodologies that provide businesses with environmental,
economic, and performance information on traditional and alternative
manufacturing methods and technologies. These approaches help businesses
integrate environmental concerns into their daily business activities so
they can reduce cross media impacts, use energy and other resources
efficiently, better manage the risk associated with using hazardous
chemicals, practice product and process responsibility, and integrate
environmental and worker safety and health requirements. In addition,
DfE has gained valuable experience in communicating with a wide variety
of people with varying degrees of technical knowledge, and in
establishing and maintaining diverse stakeholder groups. The DfE Program
is offering this experience to support the development of **Integrated
Environmental Management Systems** in companies.

Tip

Words or phrases in **bold type** are defined in the Glossary (Appendix
A).

Tip

The IEMS process described in this Guide will help you develop a
results-oriented EMS, but it may not include all steps or core elements
necessary for ISO **certification**.

An Environmental Management System (EMS) is a set of management tools
and principles designed to guide the allocation of resources, assignment
of responsibilities and ongoing evaluation of practices, **procedures**,
and processes that a company needs to integrate environmental concerns
into its daily business practices. The EMS developed and outlined by the
International Standards Organization (ISO) in their standard ISO14001 is
one such example. The ISO 14001 EMS provides a widely recognized set of
principles and standards for integrating environmental management into
quality control and other business activities. Although the principles
discussed in this document can apply to any EMS based on a
plan-do-check-act approach, this document uses ISO14001 as a starting
point. In addition to administrative procedures, steps to implement an
EMS involve some technical work, such as identifying and prioritizing
environmental concerns, evaluating options for addressing those
concerns, and measuring the success of implementing those options. The
ISO14001 standard does not specify *how* to carry out the technical
work.

Tip

An Environmental Management System provides a systematic way to review
and improve operations for better **environmental performance** and
improved profitability, by setting up **procedures** that ensure the
work gets done. An EMS requires both administrative and technical work.

The DfE Program's approach to creating an EMS provides the DfE Program's
technical methods to carry out the technical work of developing the EMS.
The technical methods to integrate cleaner technology business methods
with the management methods required for an EMS are presented in the DfE
Program's Integrated Environmental Management System (IEMS). This
approach emphasizes reducing **risk** to humans and the environment,
pollution prevention, and wise resource management. The DfE Program
principles follow this section. Those elements of the EMS that require
strictly management or administrative expertise will be presented so as
to demonstrate how the management and technical elements fit together.
More detail on the management elements will be found in other referenced
sources. This Guide takes you and your company through the IEMS creation
process, step by step.

Tip

-   There are many types of organizations that could make use of this
    Guide.

-   A company could use it to develop an IEMS.

-   A trade association could customize it and develop a sector-based
    approach to provide training for their members.

-   A large company could use it to green their supply chain and their
    customer chain.

-   Federal facilities can use it to fulfill requirements in the
    Executive Order: Greening of the Government Through Leadership in
    Environmental Management.

-   Other government facilities could use it to comply with
    environmental regulations and to be more environmentally proactive.

In January 1999, the DfE Program teamed with the Screenprinting and
Graphic Imaging Association International (SGIA) to conduct a pilot
project with seven screenprinting companies who wanted to develop IEMSs.
The pilot project was designed to enable both the DfE Program and SGIA
to further develop these training materials. This Guide has undergone
major revisions, and the *Company Manual Template* was developed in
response to lessons learned during the pilot project.

DfE Program Principles

A goal of the DfE Program is to create healthier environments for
workers, communities, and the ecosystem. The DfE Program accomplishes
this goal by promoting system change in the way a company manages
environmental concerns. The DfE Program principles and approaches are
useful in meeting regulatory requirements and augmenting environmental
protection beyond compliance. Using the DfE Program's approach can help
a company integrate environmental protection by:

-   managing the risk associated with using regulated and unregulated
    hazardous chemicals,

-   considering cross-media impacts of activities and products,

-   using energy and other resources efficiently,

-   practicing extended product and process responsibility, and

-   integrating environmental and health & safety requirements.

Approach

The DfE approach to creating an IEMS has six main steps:

-   Identify and compare alternatives to evaluate trade-offs and
    information gaps.

-   Use the DfE Substitutes Tree outline (see Figure A) to evaluate
    alternatives.

-   Use the Pollution Prevention Hierarchy (Figure B) to evaluate and
    rank approaches.

-   Integrate environmental considerations into daily business decision
    making that includes performance and cost to provide environmental
    solutions that promote competitiveness.

-   Recognize need for a commitment to continuous improvement.

```{=html}
<!-- -->
```
-   Work in partnership with **stakeholders**; engage participation and
    support of employees; encourage open communication.

![](media/image3.wmf)Figure A: DfE Substitutes Tree

Figure B: Pollution Prevention Hierarchy

![](media/image4.wmf)

How to Use This Guide

This Guide has been designed to help companies integrate environmental
concerns into business decision making using the DfE Program's
Integrated Environmental Management System (IEMS). This Guide follows
the guidelines of ISO14001, an international standard for EMSs, and it
is designed to help businesses set up and implement a simple,
straightforward EMS. This Guide does not intend to give guidance for
ISO14001 certification.

This Guide is laid out in nine modules designed to be completed through
group discussions with your IEMS team members and other managers and
employees as appropriate. Most modules can be completed in several
hours, but some may take longer. Sessions may be held once a week, once
every other week, or once a month until the job is done. Use whatever
time these modules require for your company. It is more important to
complete each module than to finish in any particular time frame. Most
companies find that it takes about a year to work through the EMS
development process. And it generally takes up to three years for the
EMS to be fully understood and implemented. Developing a company IEMS is
a commitment to change, and change takes time.

Tip

Every choice you and your employees make can affect the environment.
Involving everyone helps produce cost-effective long-term results.

Best results will be achieved by involving everyone in the company in
some way. There are two benefits to involving all employees: first, they
will be more likely to take ownership of managing environmental
concerns; second, they often have valuable insight into how improvements
can be made.

Tip

You should not try to perfect each step on your first attempt. Many of
the steps will need to be revisited as you proceed with developing the
IEMS.

You should consider regular sessions as suits your schedule to complete
the work in each module. You will need to appoint a responsible person
and a committee to head the development of your IEMS. The committee
members could also meet regularly with other employees to provide
progress reports and solicit input. The importance of regular
communication and involvement cannot be overemphasized. Getting people
to think about environmental concerns in their daily work is as
important a process as any step in setting up your IEMS.

Tip

A companion document, A Company Manual Template, contains sample
procedures and formats to help you document important components of your
IEMS. Refer to this Guide frequently as you develop your IEMS. This
document is available on the DfE website (www.epa.gov/dfe). See Appendix
G for details about the Template.

Some of these modules will have to be revisited during the process. For
example, it is useful to develop a communication plan in the beginning,
but you will need to add to it as environmental concerns are identified
and as other parts of the IEMS are developed. Some modules may not be
completed at the outset, but may be revised as needed throughout the
process.

Finally, you don't need to do everything at once. This Guide will help
you identify possible projects and then help you prioritize these
projects, given your resources and time. You may, for example, want to
start out by developing the IEMS for only one part of your company or
operation. You can expand later as your resources permit. It's important
to start small with projects that will achieve success, so that you and
your employees gain experience with the process and build confidence in
your ability to make changes.

What are the Steps in Developing an IEMS?

Each module in this Guide explains a step in the IEMS development
process. The modules contain worksheets to assist you in completing this
work. Figure C is a flow chart showing the steps in the process. Figure
D is a "roadmap" showing how the IEMS modules relate to the components
of the ISO 14001 standard. The Appendices contain a Glossary, example
questions to ask your suppliers about chemical risk, an alternatives
evaluation worksheet and performance evaluation worksheet from the DfE
Printing Project, resources for more information, and blank forms that
correspond to the worksheets in each module. In addition to the
Appendices, more tools and guidance can be found on the DfE\'s website
at www.epa.gov/dfe. In particular, there is a more extensive Risk Guide
and Cleaner Technology Substitutes Assessment Guide.

Module 1: Laying the Groundwork

This module provides a general discussion of what an IEMS contains. It
will help you build understanding of and support for your IEMS among
your company's managers and employees, about what an IEMS is and why the
company is developing one. This module also will help you understand how
your company currently impacts the environment by identifying
environmental impacts of your company's products, processes and
services.

Module 2: Creating an Environmental Policy

An early step in the process of developing a IEMS is reviewing your
company's current methods for managing environmental concerns. Next you
will write your company's environmental policy statement and decide on
the scope of your IEMS. The environmental policy will be based on what
is important to your company. This module contains some sample
principles and policy statements.

Module 3: Determining Significant Environmental Aspects and Setting
Objectives

You will need to determine which environmental aspects are significant,
and prioritize them to determine what you want to address first. This
module provides a method to estimate environmental risk to help you
prioritize environmental aspects. The module then helps you to translate
those priorities into objectives to reduce environmental impact.

Tip

**Environmental aspects** are elements of your business, such as air
pollutants or hazardous **waste**, that can have negative impacts on
people and/or the environment.

![](media/image5.wmf)Figure C: IEMS Process

Figure D: Road Map Between ISO 14001 and IEMS Approach

+-----------------------+----------------------------------------------+
| **ISO14001 EMS        | **IEMS GUIDE MODULES**                       |
| COMPONENTS**          |                                              |
+-----------------------+----------------------------------------------+
| Commitment and Policy | Module 1: Laying the Groundwork              |
|                       |                                              |
|                       | Module 2: Creating an Environmental Policy   |
+-----------------------+----------------------------------------------+
| Planning              | Module 1: Laying the Groundwork              |
|                       |                                              |
|                       | Module 3: Determining Significant            |
|                       | Environmental Aspects and Setting Objectives |
+-----------------------+----------------------------------------------+
| Implementation        | Module 4: Evaluating Alternatives            |
|                       |                                              |
|                       | Module 5: Setting Targets and Measuring      |
|                       | Success                                      |
|                       |                                              |
|                       | Module 6: Developing Operational Controls    |
|                       |                                              |
|                       | Module 7: Implementing Your IEMS             |
|                       |                                              |
|                       | Module 8: Building Organizational Support    |
+-----------------------+----------------------------------------------+
| Evaluation            | Module 5: Setting Targets and Measuring      |
|                       | Success                                      |
|                       |                                              |
|                       | Module 8: Building Organizational Support    |
+-----------------------+----------------------------------------------+
| Review                | Module 9: Establishing Continuing            |
|                       | Improvement                                  |
+-----------------------+----------------------------------------------+

Module 4: Evaluating Alternatives

Before deciding how you will meet your objectives, it is important to
consider a wide array of approaches. This module shows how the IEMS
methodology considers a hierarchy of alternatives, which include
substitutes, pollution prevention, and wise resource management.

Module 5: Setting Targets and Measuring Success

For those significant environmental aspects where you have set an
objective, you will need to develop specific targets that describe how
you will achieve your goal and you need to develop ways of measuring
that achievement.

Module 6: Developing Operational Controls

For some environmental aspects, you will need to write procedures to
ensure that activities are performed in a way that reduces environmental
impact. This module lays out how to develop operational controls,
measure for success of those controls, and provide corrective action
when necessary.

Module 7: Implementing Your IEMS

Effective implementation is essential to getting your IEMS off to a good
start. This module helps you plan the IEMS development process and set
up environmental management projects for your objectives.

Module 8: Building Organizational Support

The long-term success of your IEMS will depend on solid organizational
support. Such support includes developing documentation, meeting
training needs, and implementing effective communication and stakeholder
involvement processes.

Module 9: Establishing Continuing Improvement

To ensure success and continuing improvement, regular reviews of your
overall IEMS are needed. These reviews include progress made in
communication, documentation and developing stakeholders as well as the
specific environmental targets. The reviews provide critical information
to ensure continuing improvement.

How much work each of the steps entails depends entirely on the scope of
work that you decide to undertake. It is not necessary for your IEMS to
include all your operations, especially for your first effort. As you
gain experience in managing environmental concerns along with your daily
operations, you will develop your IEMS further.