# Presentation: 366777

## Introduction to Environmental Management Systems

- Environment International Ltd.
- June 14-16, 2005

*Designing Your EMS:  A USDA Workshop*

**Notes:**
Self assessment was completed, Gap Analysis available at Area website

## EMS Requirements in Executive Order 13148

- Agency level EMS self assessment by October 2001
- Facility pilot EMS by April 2002
- EMS at all appropriate facilities  by December 2005

**Notes:**
Added “appropriate” facilities.  Not all facilities have to have them.

## Self Declaration

- Memorandum to Agency Environmental Executives dated January 27, 2004.
- Final version of protocol dated September 10, 2003.
- Verify conformance with ISO 14001.
- www.epa.gov/

## What is an Environmental Management System?

- “The part of the overall management system that includes organizational structure, planning activities, responsibilities, practices, procedures, processes and resources for developing, implementing achieving and reviewing the environmental policy.”   ISO 14001

## What is an Environmental Management System?

- An environmental management system brings together the people, policies, plans, review mechanisms, and procedures used to manage environmental issues at a facility or in an organization.

## An EMS is Environmental

- Facilitates environmental compliance
- Addresses environmental impacts
- Broadens environmental responsibilities to all whose work can have a significant impact on the environment
- Environmental office has technical expertise to contribute

**Notes:**
It has been my experience that the Environmental Manager is too overworked to have time to be the lead in developing an EMS.  The whole point of an EMS is to 

## An EMS is Management

- Must have commitment of top managers
- EMS owned by facility manager
- Must be consistent with other management systems

## An EMS is a System

- Requires awareness of formal structure
- Addresses policies, procedures, programs
- Doesn’t specifically address compliance components (drums, labels, etc.)

**Notes:**
I modified the third bullet, because an EMS does address emergency planning and training.

## ISO 14001 Components

**Environmental**
**Policy**

**Continual Improvement**

**Planning**

**Implementation &**
**Control**

**Checking & Corrective Action**

**Management**
**Review**

**Notes:**
This slide shows the components arranged to reflect the EMS cycle and the notion that the cycle supports the continual improvement concept that is the backbone of an effective EMS 

the next few slides will describe the various components

## Environmental Policy

- Issue a policy statement signed by facility manager
- At a minimum, commit to
- Continual improvement
- Pollution prevention
- Environmental compliance
- Identifies EMS framework
- Publicly available

**Notes:**
Added “At a minimum” to the description of elements of an E policy.  Some government agencies are moving toward sustainability.

## Planning

- Identify aspects and impacts from facility activities, products, and services
- Review legal requirements
- Set objectives and targets
- Establish formal EMS program

## Implementation & Operation

- Define roles and responsibilities
- Provide EMS training
- Establish internal and external communication mechanisms
- Establish document control system
- Establish operational controls
- Integrate with or establish emergency preparedness procedures

## Checking & Corrective Action

- Conduct periodic monitoring of environmental performance
- Identify root causes of findings and conduct corrective and preventive actions
- Maintain environmental records
- Conduct periodic EMS audit

## Management Review

- Conduct periodic senior management review of EMS
- Revise parts of the EMS as needed

## Benefits of an EMS

- Help maintain compliance
- Reduce operating costs
- Integrate environmental programs into mission
- Increase employee involvement
- Reduce environmental impacts

**Notes:**
Added a bullet on reducing environmental impacts of organization

## Getting Your EMS Started:Your EMS Team

- Environment International Ltd.
- June 14-16, 2005

*Designing Your EMS:  A USDA Workshop*

## Functions of the Team

- Educate all organizations at facility
- Conduct gap analysis
- Collect input from employees, management
- Plan and implement EMS
- Interact with local community as needed

## Knowledge and Skills Needed for Team

**Enthusiasm and energy**
**Project management skills**
**Patience and persistence**
**Training expertise**
**Excellent communication skills**
**Process/systems knowledge **
**EMS knowledge**
**Political savvy**
**Access to top management**

**Notes:**
Environmental manager has needed expertise for the Team, but may not be the best person to lead the Team.
	too busy
	other priorities prevent him/her from focusing on team’s work

## Environmental Policy Statement

- Environment International Ltd.

*Designing Your EMS:  A USDA Workshop*

## How not to create your environmental policy...

**How not to create your environmental policy...**

## Policy Statement Importance

- Demonstrates management commitment
- Defines framework for EMS
- Provides framework for setting objectives and targets
- Must be appropriate to activities at facility

## ISO 14001 Requirements

- In an ISO 14001 conforming EMS, an environmental policy statement must:

- Be appropriate to the nature, scale and env. impacts of its activities, products or services
- Be documented, implemented, maintained and communicated to all employees
- Be available to the public

**Notes:**
Documented
Implemented
Communicated

## ISO 14001 Requirements

**Notes:**
Documented
Implemented
Communicated

## Gap Analysis

- Environment International Ltd.

*Designing Your EMS:  A USDA Workshop*

## Definition

- A ***gap analysis*** is a process used to assess the current state of your facility’s EMS.  Other similar processes are “environmental management system reviews (EMRs).”

## Purpose of a Gap Analysis

- Identify gaps between your current management systems and the EMS standard
- Collect policies, procedures, programs, metrics, and personnel that support the current EMS
- Establish a list of actions to achieve conformance with the standard

## EMS Fenceline

- Factors that will define the scope of each NAA location’s EMS
- Physical size of your location
- Research mission of your facility
- Self-supporting location versus tenant of a larger facility having its own EMS
- State and municipal agencies that have environmental regulatory oversight over your location

**Notes:**
Entire organization, or specific operating units or activities  (14001 Annex A)
EPA Region 8 is tackling their internal functions for their EMS pilot.  Will incorporate their programmatic functions later.
Fort Riley is building EMS around DECAM functions – Directorate of Environmental Compliance and Management.

## Steps in a Gap Analysis

- Facility walk-through (reference fenceline)
- Document review
- Staff interviews
- Identify and document gaps

## Facility Walk Through

- Identify Activities, Products, and Services
- Main reason for facility’s existence
- Support activities
- Develop Comprehensive Picture of Facility
- Maps
- Pictures
- Lists of buildings and organizations

## Document Review

- Examples of relevant documents:
- Environmental policy statements
- Other policy statements
- Mission statements
- SOPs
- Position descriptions
- Environmental plans (HW, P2, INRMP, SPCC, STORMWATER, AS-BUILT, etc)
- Training materials

## Staff Interviews

- Identify organizational structure
- Identify requirements to fulfill mission
- Determine awareness of staff of EMS
- Awareness of environmental programs and goals

## Identify and Document Gaps

- Compare with EMS elements
- Make a list of specific actions to close gaps

## Identifying Environmental  Aspectsdefined as a part of activity or product that interacts with environment

- Environment International Ltd.
- March 22-23, 2005

*Designing Your EMS:  A USDA Workshop*

## Aspects and the EMS

- When first developing your EMS, do a comprehensive aspects review
- ISO 14001 requires organizations to:
- develop procedures to identify environmental aspects
- keep register of aspects up-to-date

**Notes:**

As you repeat the EMS cycle, you can revisit the aspects and impacts analysis in areas where changes have occurred or where you need a more detailed analysis to help you in your continuous improvement program.
Your most significant environmental impacts may be ones you weren’t thinking about initially.

## Building an Aspects Register

- Assemble list of activities,    products, and services
- Characterize activities, products, and services
- List aspects
- Organize and rank aspects as appropriate

## Characterizing Your Activities, Products, and Services

- Interviews with research and field staff (what are they doing, are they using hazardous materials, etc.)
- What are your location’s hazardous material purchases (review inventories)
- Hazardous waste records
- Records from emergency planning, accident reports, emergency incidents
- Water and energy consumption records

## Step 1  

**Look at the Comprehensive Picture of Your Facility**
- Research Activities
- Facility Operations Activities
- Construction and Demolition Activities
**Within Your “Fenceline”, Identify and List Activities**
- Crop research
- Animal research
- Use hazardous chemicals
- Generate hazardous waste

## STEP 2

- Determine if there are ***environmental aspects*** associated with each activity on your list
- An ***environmental aspect*** is the part of an activity, product, or service that interacts with the environment.  An aspect can be thought of as the actual or potential “cause” of an environmental impact.
- Aspects can be regulated or unregulated.

**Notes:**
Aspects include those for which there is a regulatory threshold.
Amounts released below the threshold should also be considered aspects, not just amounts which exceed a threshold.
Example:  even if you are a conditionally exempt hazardous waste generator, the hazardous waste you do generate is an aspect(s).

There may be no specific regulations covering a particular aspect.
	Non-hazardous solid waste
	Carbon dioxide releases
	Water and energy consumption

## Example 1 

**Activity, Product, or Service**
- Purchasing Hazardous Chemicals

**Environmental Aspects**
- Depletion of natural resources in the following ways:
- 	(a) Energy utilized in chemical manufacturing; and
- 	(b) Energy requirements for chemical storage (e.g., 	use of electricity for low-temperature 	refrigeration or ventilation
- Generation of hazardous waste by the following activities:
- 	(a) Duplicate purchasing of hazardous chemicals 	already on location inventory;
- 	(b) Large-scale purchasing of unusable quantities of 	chemical; and,
- 	(c) Chemical is not used, resulting in chemical 	entering hazardous waste stream due to 	expired use date.

## Example 2 

**Activity, Product, or Service**
- Facility Maintenance

**Environmental Aspects**
- Hazardous waste generation (spent fluorescent lamps, PCB containing lamp ballasts, spent solvents, paints)
- Generation of asbestos-containing waste
- Generation of universal waste (used oils, mercury-containing equipment)
- Ozone depletion (repair of older refrigeration equipment containing ozone depleting refrigerants)
- Generation of solid waste (excess furniture and equipment)
- Release of volatiles

## Example 3 

**Activity, Product, or Service**
- Vehicle maintenance

**Environmental Aspect**
- Hazardous waste generation
- Gasoline consumption
- Noise generation
- Electricity consumption
- Solid waste generation
- Water consumption
- Waste water generation
- Release of volatiles

## Example 4

**Activity, Product, or Service**
- Office work

**Environmental Aspect**
- Electricity consumption
- Water consumption
- Waste water generation
- Release of ozone depleting substances in air cooling units
- Solid waste generation
- Disposal of toxics from  computer toner, etc.

## Step 3

- A ***significant environmental aspect ***is an environmental aspect that has or can have a significant environmental impact.
- Significance could be tied to:
- Environmental concerns
- Natural resource concerns
- Regulatory or legal exposure
- Business or mission concerns
- Concerns of interested parties

##  Factors That May Play a Rolein Managing Aspects

- Size, severity and duration of environmental impact
- Ease of improvement
- Regulatory or Executive Order requirement
- Cost
- Mission impact
- Community impact
- Sustainability

## From Aspects to Impacts

- Environment International Ltd.
- March 22-23, 2005

*Designing Your EMS:  A USDA Workshop*

## Definition

- An ***environmental impact*** is a change to the environment, either adverse or beneficial, wholly or partially resulting from an organization’s activities, products, or services.

## 						    Potential

_**Aspect**__**	**__**	**__**	**__**	**__**	**__**Impact**_
- 	Cause					Effect Process					OutcomeVerb					Noun

## Examples of Aspects &  Impacts

- Vehicles emit exhaust
- Water leaks
- Fuel spills occur
- Spills happen from containers
- Lights, computers are left on when not in use
- Paper is bleached w/Cl2
- Bicycles used, not cars

- Air pollution
- Water resource depleted
- Stormwater contaminated
- Chemical contamination of soil, water
- Air pollution and use of resources
- Dioxins in wastewater
- Less air pollution

- 	    _**ASPECTS**_			  _**IMPACTS**_

**Notes:**
Examples of regulated, unregulated impacts
Example of natural resource impact
Examples of actual and potential impacts
Example of human impacts
Example of offsite impacts due to products used
Example of positive environmental impact

## EMS and Impacts

- Use the aspects register to identify impacts
- EMS addresses significant aspects
- Document your process for identifying aspects and impacts
- Add impacts to the aspects register

## Exercise:Aspects & Impacts

| Activities, products, services | Aspect | Impact |
| --- | --- | --- |
| Transportation | Fuel use | Air pollution 
Natural resource depletion |

## Legal and Other Requirements

- Environment International Ltd.

*Designing Your EMS:  A USDA Workshop*

## Potential Environmental Legal Requirements

- RCRA
- CAA
- CWA
- SDWA
- CERCLA
- ESA
- Natural and Cultural Resource regulations
- EOs

- NEPA
- EPCRA
- OSHA
- Pollution Prevention Act
- OPA
- Energy Policy Act
- Historical Preservation regulations
- FIFRA
- TSCA

## EMS and Environmental Compliance

- Commitment to compliance is a key part of an EMS
- Achieve compliance through application of source reduction techniques
- Use EMS to direct resources to source reduction projects that address compliance issues

## Updating Legal Requirements

- Required by ISO 14001
- Regular review of regulations
- Distribution to appropriate personnel

**Notes:**
ISO 14001 requires facilities to establish a procedure to identify and make accessible legal and other requirements

## Information Sources

- Code of Federal Regulations web site
- http://www.gpo.gov/nara/cfr/index.html
- Federal Register web site
- http://www.gpo.gov/su_docs/aces/aces140.html
- U.S. Code web site
- http://www4.law.cornell.edu/uscode/
- EPA web site

## Determining the Significant Aspects

- Environment International Ltd.

*Designing Your EMS:  A USDA Workshop*

## Definition

- A ***significant environmental aspect ***is an environmental aspect that has or can have a significant environmental impact.
- Significance could be tied to:
- Environmental concerns
- Natural resource concerns
- Regulatory or legal exposure
- Business or mission concerns
- Concerns of interested parties

## EMS Requirements

- ISO 14001 uses “significant” aspects and impacts as the basis for developing objectives and preparing programs
- The facility determines which aspects and impacts are “significant”
- The EMS must address all significant aspects

##  Significance Considerations

- Size, severity and duration of environmental impact
- Ease of improvement
- Regulatory or Executive Order requirement
- Cost
- Mission impact
- Community impact
- Sustainability

## Exercise: Determining significant Aspects

- Potential factors
- severity
- probability/frequency
- risk (environmental/
- 	health/financial)
- Mission impact

- external concerns
- ability to control/
- 	improve
- duration
- regulatory concern

- Use reproducible methodology; e.g., rank using a formula containing factors the organization considers important

## Ranking Aspects to Determine Those That Should Be Managed Under My Location’s EMS

_**Severity**_
- 5   Catastrophic
- 4   High
- 3   Moderate
- 2   Low
- 1   Slight
- 0   Positive Impact

_**Regulatory Importance**_
- 5	     Current violation
- 4	     Non-compliance, past 3 yrs
- 3	     Non-compliance, past 5 yrs
- 2     In compliance
- 1     Below regulatory cut-off
- 0     Unregulated

## Example of Rating Scheme

- Significance **=**
**(Severity + RI + Prob)******Ease of ******	******	******	******	******	******	******   Improvement***
- **For few aspects or small locations the team can

## Setting Objectives and Targets

- Environment International Ltd.
- June 2005

*Designing Your EMS:  A USDA Workshop*

## Definitions

- An EMS ***objective*** is an overall goal arising from the environmental policy statement  set by the organization.
- An EMS ***target ***is a detailed measurable performance requirement related to the objective.

## Organizations Shall Consider:

- Legal and other requirements
- Significant environmental aspects
- Technological options
- Financial, operational and business requirements
- Views of interested parties

## Examples

- Objective:	Reduce energy consumption by 30% by the year 2010 based on a 2004 calendar year baseline.
- Target:	Immediately implement policy of turning off computers when not in use.
- 	Replace all lighting with energy efficient bulbs/fixtures by Dec 2005.
- 	Install motion detectors on light switches by June 2006.

## Examples

- Objective:	Reduce transportation congestion by 20% by December 2006.
- Targets:  	Increase the number of employee-days of mass transit use by 50% by the year 2006 based on a 2004 calendar year baseline.
- 	Purchase 25 bicycles for use within the facility by December 2005.

## Setting Objectives and Targets

- Start with Planning data
- Options for identifying objectives:
- Goal setting workshop
- EMS Coordinator recommendations
- EMS Team recommendations
- Management Priorities

## Exercise: Setting Objectives & Targets

| Aspect | Impact | Indicator 
(measure) | Objective | Target |
| --- | --- | --- | --- | --- |
| Fossil fuel consumption | Use of non-renewable resource | Gas bills, electric car purchases | Purchase electric cars | Lower bills, # cars bought |

## Linking Objectives to Programs

- Environment International Ltd.
- March 22-23, 2005

*Designing Your EMS:  A USDA Workshop*

## Definition

- An ***environmental management program*** is a formal set of procedures or activities designed to assign responsibility for and measure performance in achieving its environmental objectives and targets.
- Includes the means and timeframe by which the objectives and targets will be achieved.

## Environmental Management Programs

- An environmental management program should define:
- responsibilities
- resources
- objectives
- documentation
- schedules
- Should be effectively aligned with existing management system elements

**Notes:**
Consistent with Budget and Planning
		Resource Allocation Systems
		Information and Support Systems
		Organizational Accountability Structure
		Reward and Appraisal Systems
		Measuring and Monitoring Systems
		Communication and Reporting Systems

## EMS Document Structure

- Policy
- Aspects Register
- Objectives and Targets

- Environmental Management Plans
-       Training Needs Surveys
-         Organizational Charts

- Standard Operating Procedures
-          Training Records
-  Hazardous Waste Manifests
-           Energy Bills

- EMS

- Environmental
- Management
- Programs

- Day-to-Day
- Operations

## Linking Objectives to Programs

- Start with EMS objectives
- Match programs to objectives
- Review current programs for non-conformance
- Correct non-conformance in programs
- Initiate new programs for objectives without existing programs

## Summary of the EMS Planning Process

- Environment International Ltd.

*Designing Your EMS:  A USDA Workshop*

## ISO 14001 Components

**Environmental**
**Policy**

**Continual Improvement**

**Planning**

**Implementation &**
**Control**

**Checking & Corrective Action**

**Management**
**Review**

**Notes:**
This slide shows the components arranged to reflect the EMS cycle and the notion that the cycle supports the continual improvement concept that is the backbone of an effective EMS 

the next few slides will describe the various components

## EMS Planning Steps

**Identify EMS Team**

**Identify/Write/Modify Environmental Policy**

**Identify Current Programs and Perform Gap Analysis**

**Identify Aspects and Impacts**

**Prioritize/ Determine Significance**

**Develop Objectives and Targets**

**Create Program to Achieve Objectives and Targets**

**Define Fenceline**

## Where you should be at the end of the planning process:

- Prepared a policy statement
- Put together an EMS team
- Defined your fenceline
- Conducted a gap analysis
- Created an aspects register
- Reviewed legal requirements
- Determined the significant impacts
- Set objectives and targets
- Created environmental management programs

## EMS Implementation and Operation

- Environment International Ltd.
- June 2005

*Designing Your EMS:  A USDA Workshop*

## EMS Implementation

- Translate all your planning into action
- Where performance is improved
- Next step is to roll out:
- training
- procedures
- documentation
- new job assignments

## ISO 14001 Elements

- Implementation and operation involves
- Structure and Responsibility
- Training, Awareness & Competence
- Communication
- EMS Documentation
- Document Control
- Operational Control
- Emergency Preparedness and Response

## Structure & Responsibility

-    ISO 14001 requires
- facilities to define, document, and communicate organizational roles and responsibilities in an EMS, including an EMS management representative
- management to provide appropriate human, physical and financial resources to implement and maintain the EMS

**Notes:**
OMB Circular A-11 reinforces the requirement to budget for implementation of the EMS

Organizations encouraged, under ISO14004, to show costs and benefits of environmentally related activities.

## Incorporate EMS into Organizational Structure

- Revise organizational charts to reflect EMS
- Modify position descriptions to include EMS responsibilities
- Measure EMS performance in performance reviews
- Reassign personnel to EMS if necessary
- Allocate training and financial resources to EMS

## EMS Roles & Responsibilities

- EMS Coordinator
- EMS Team
- Senior manager
- Line managers
- Personnel specialists
- Information management staff

- Functional experts
- Engineers
- Contracting officials
- Purchasing officials
- Energy managers
- Technical experts
- NEPA
- Contractors, concessionaires

**Notes:**
The knowledge and skills necessary to achieve environmental objectives should be identified.  These should be considered in personnel selection,  recruitment, training, development of skills and ongoing education.  (ISO14004)

Motivation to continually improve can be enhanced when employees are recognized for achieving environmental objectives and targets and encouraged to make suggestions that can lead to improved environmental performance.  (ISO14004)

## EMS Coordinator

- Management representative with defined roles and responsibilities:
- ensuring EMS requirements are met
- report on performance of the EMS to top management for review and as a basis for improvement

## Performance Reviews

- Require accountability for appropriate personnel
- Measure individual performance as it contributes to EMS objectives
- Include EMS in EMS Coordinator’s and EMS Team’s reviews (HRD )

**Notes:**
Operational managers should be responsible and accountable for effective implementation of EMS and environmental performance.
Employees at all levels should be accountable, within the scope of their responsibilities, for environmental performance in support of the overall environmental management system.

## Resource Allocation

- Personnel
- Physical resources
- Equipment
- Training
- Financial resources (HWC)

- Management must provide sufficient resources to implement the EMS including:

## Training Steps

- Determine audiences for general and specific training
- Identify trainer
- Develop and implement training schedule
- Keep accurate and complete records

*Training is essential to an effective EMS!*

## ISO 14001 Training Requirements

- EMS Awareness level in addition to functional areas
- Personnel performing tasks that can cause significant environmental impacts shall be competent based on education, training, and/or experience. (USTs, WWTRs)

**Notes:**
Management shall provide resources essential to the implementation and control of the environmental management system.  Resources include human resources and specialized skills, technology and financial resources.

## ISO 14001 Training Requirements (cont.)

- Significant environmental aspects of work activities
- Roles and responsibilities in EMS
- Emergency preparedness and response
- Potential consequences of departure from specified operating procedures (SOPs)

**ISO 14001 Training Requirements (cont.)**

## Audience and Needs

**EMS Coordinator-** thorough knowledge of EMS framework
**EMS Team-** working knowledge of EMS framework
**Senior managers-** knowledge of purpose and management role in EMS
**Employees with significant aspects–** role in EMS and responsibilities
**All employees-** basic environmental and EMS awareness

## Training Timeline

- General EMS Training (Dec 2005):
- First group - EMS coordinator, EMS team
- Second group - Facility manager, senior managers
- Third group - All employees
- Specific Training on SOPs:
- Supervisors and responsible employees

## Training Records

- Legible, identifiable and readily retrievable
- Protected against damage, deterioration or loss
- Retained and available to verify conformance
- Current system is acceptable

## CommunicationWhy is it important?

- Convey management commitment to EMS
- Raise awareness of organization’s environmental policies, objectives, targets and programs
- Generate suggestions for improvement
- Address concerns and questions
- Inform interested parties about the EMS and environmental performance
- Address emergency planning and other relevant issues

## Internal Communication

- “Vertical” communication within the organization
- Senior manager to/from line managers
- Line managers to/from staff
- EMS team to/from senior manager, line managers, staff
- “Horizontal” communication
- Between offices
- Within an office or shop

**Notes:**
Results from EMS monitoring, audit and management review should be communicated to those within the organization who are responsible for performance.

## External Communication

- The organization must
- Review, document and respond to relevant external communication
- ARS communicates through several channels, both regulatory and research, NEPA

## Examples of External Communication

- Public Involvement
- Earth Day
- Open Houses
- Web Sites
- Traditional Media
- Newspapers
- TV and radio

- Regulatory submissions
- Facility newsletters
- EPCRA reporting
- NEPA scoping, public involvement
- Citizens’ advisory committees

**Notes:**
Two way communication is encouraged!

Communications should be understandable and adequately explained – Plain English
Information should be verifiable.
Organization should present an accurate picture of its performance.
Information should be presented in a consistent form (for example in similar units of measurement for easy comparison)

## EMS Documentation

- Describes main elements of EMS
- Provides directions to related documents
- Supports employee awareness
- Facilitates implementation and evaluation of the system and environmental performance

## Examples of EMS documents

- Policy statement
- Information on significant aspects
- Procedures
- Process information
- Organizational charts
- Internal and external standards
- Site emergency plans
- Records

## Document Control

- Documents can be located by people who need them (ADM or CDSO)
- All documents are reviewed, revised and approved for adequacy
- Current versions are identified/available
- Documents of external origin important for the EMS are identified as such
- Obsolete versions are promptly eliminated

## EMS Requirements for Operational Controls

- Establish and maintain procedures for activities associated with significant aspects
- Most facilities have existing operational controls (Facility, lab protocols)
- Stipulate operating criteria in procedures
- Communicate procedures to appropriate parties (suppliers, contractors, etc.)

**Notes:**
Communicate relevant procedures and requirements to suppliers and contractors

## Examples of Operational Controls

- Standard Operating Procedures
- Contract language
- Labeling of materials
- Signage
- Log books
- Check lists

- Measuring equipment
- Energy meters
- Tank volume meters
- Overflow devices and check valves
- Air flow indicators
- Preventive maintenance

## Emergency Preparedness / Response – EMS Requirements

- Establish and maintain procedures to identify and respond to accidents and emergencies
- (Safety, OEP plans)
- Address potential environmental effects
- Review and revise procedures as necessary after accidents (accident investigation)
- Conduct periodic tests of procedures (drills)
*Most federal facilities have mature programs in place*

## Checking

**Environment International Ltd.**
**Seattle, WA**
***(206) 525-3362  ******•  www.eiltd.net***

*Designing Your EMS:  A USDA Workshop*

## Checking 

- Conduct periodic monitoring of environmental performance
- Identify root causes of findings and conduct corrective and preventive actions
- Maintain environmental records
- Conduct periodic EMS audit

## Checking

- 	Procedures shall be established for monitoring the EMS and correcting deviations.  Requirements for procedures cover:
- Monitoring and measurement
- Evaluation of compliance
- Nonconformance and corrective and preventive action
- Control of records
- EMS audits

## Monitoring and Measurement

- Develop procedures to regularly monitor and measure key operations and activities with significant environmental impacts
- Record information tracking performance, relevant operational controls and conformance with  the organization’s objectives and targets
- Calibrate and maintain monitoring equipment and retain associated records

## Evaluation of Compliance

- Establish procedures to periodically evaluate compliance with relevant environmental legal and other requirements
- Keep records of the results

## Nonconformance and Corrective and Preventive Actions

- Establish and maintain procedures for
- handling and investigating nonconformance
- taking action to mitigate impacts
- initiating and completing appropriate corrective and preventive actions

## Nonconformance and Corrective and Preventive Actions (cont.)

- Record any changes resulting from  corrective actions
- Review the effectiveness of actions taken

## Reasons for a Nonconformance

- Implementation differs from documentation
- System is not working
- Requirement is not addressed

## Records

**Records – a special type of document**
- Provide verification of things that have happened
- Individual records are not updated (new records are created)

**Notes:**
Slide to be used during brainstorming session to make an electronic statement???

## Records

- Procedures must be maintained for the identification, storage, protection, retrieval, retention and disposal of environmental records.
- Records must be maintained to demonstrate conformance to EMS requirements and the results achieved.

## Records

- Properly maintained records will be
- legible
- identifiable
- traceable to the activity, services or product involved

## Scope of Records

- Legal compliance
- Process monitoring
- Environmental aspects and their impacts
- Environmental training
- Inspection, calibration and maintenance activity

**Records should cover:**

- Continued...

## Scope of Records (cont.)

- Details of non-conformance: incidents, complaints and follow-up action
- Tests for emergency preparedness
- Environmental performance information
- Pertinent supplier and contractor information
- Environmental audits and management reviews
- Environmental meetings

**Scope of Records (cont.)**

## EMS Audits

**Environment International Ltd.**
**Seattle, WA**
***(206) 525-3362  ******•  www.eiltd.net***

*Designing Your EMS:  A USDA Workshop*

## Management Review

**Environment International Ltd.**
**March 22-23, 2005**

*Designing Your EMS:  A USDA Workshop*

## Management Review

- Conduct periodic senior management review of EMS
- Revise parts of the EMS as needed

## Continual Improvement

*Management must regularly review the EMS and audit results to ensure sustained improvement in environmental performance and compliance with changing regulations.*
*An organization must be committed to continual improvement of environmental performance so that its EMS continues to be effective and environmental aspects are always factored into business decisions.*

## Post - Test

- Any questions about:
- EMS Checking and Corrective Action
- EMS Auditing
- Management Review
- Other