# Presentation: 726711

## SENIOR MANAGERS TRAINING FOR USE WITH

- DOE O 450.1, *ENVIRONMENTAL PROTECTION PROGRAM*

## WHAT IS AN EMS?

- An EMS is a systematic and structured approach for addressing environmental consequences of an organization’s activities, products and services

**Notes:**
An EMS is part of DOE’s overall management system which includes an organizational structure, planning, responsibilities, practices and processes for addressing an organization’s environmental impacts.
The expectation is that through this systematic approach, environmental consequences will be identified at the earliest opportunity, and mitigated resulting in improved environmental compliance and protection in a  cost-effective manner.

## PURPOSE

- Provide Senior Managers with an overview of DOE O 450.1 requirements, including:
- an understanding of their DOE O 450.1 roles and responsibilities to ensure successful ISMS/EMS implementation
- guidance on how to implement EMS as part of Integrated Safety Management Systems (ISMS)

## WHY DO I HAVE TO HAVE AN EMS?

- To improve environmental performance:
- To meet the requirements of DOE O 450.1, *Environmental Protection Program, *and
- Executive Order 13148, *Greening the Government Through Leadership in Environmental Management*

**Notes:**
Having an EMS is a good business practice that should improve environmental  performance and help achieve mission goals.  Many high performing private sector companies have implemented EMSs.  A more in-depth discussion of EMS benefits is contained in subsequent slides.
It is the policy of the Federal Government to use environmental management systems to implement environmental protection activities and improve environmental performance.  E.O. 13148, Greening Government Through Environmental Management, requires appropriate Federal facilities to implement EMSs by December 31, 2005.  
In furtherance of this goal, the Department issued DOE O 450.1, Environmental Protection Program, in January, 2003, which requires EMS implementation at DOE sites.  EH-4 has also issued accompanying guidance documents which are available on our website.

## BENEFITS OF AN ISMS/EMS

- Achieve mission goals, reduce costs, improve business practices
- Improve environmental compliance performance
- Address stewardship and legacy management issues systematically
- Improve credibility with regulators and local community

**Notes:**
A successful ISMS/EMS will ensure that environmental concerns are considered as a part of the project planning and become part of the critical path to achieving mission goals.  This can help avoid environmental issues becoming last minute, costly surprises that can delay a project.
The ISMS/EMS creates a culture of environmental awareness at DOE sites which results in improved environmental compliance performance. Organizations with an ISMS/EMS have demonstrated improved environmental compliance performance.
Stewardship and legacy management have become a major mission for DOE.  The ISMS/EMS approach will help sites proactively identify and address concerns to implement and maintain sound stewardship practices.  The ISMS/EMS can help foster a smooth transition of sites from DOE Program Offices to the Office of Legacy Management by providing a common, understandable, reliable transition framework.
Regulatory agencies and local communities have recognized an EMS as evidence that a site is effectively managing its environmental liabilities. 
Regulatory agencies can reward sites with high-quality integrated management systems with relief from certain administrative requirements (e.g., EPA’s National Environmental  Performance Track Program.)

## HOW IS DOE’s EMS IMPLEMENTATION MONITORED?

- DOE’s progress toward implementation is reported to the White House Office of the Federal Environmental Executive (OFEE) on an annual basis by the Assistant Secretary for Environment, Safety and Health (EH-1), who also serves as DOE’s Agency Environmental Executive

## WHAT ARE  SENIOR MANAGERS’  RESPONSIBILITIES PURSUANT TO  DOE O 450.1?

- Senior managers must:
- Ensure that all sites under their purview have implemented ISMS/EMS by 12/31/05
- Request, through their annual Departmental budgetary process, the funding and resources needed to implement DOE O 450.1

**Notes:**
Additional responsibilities also include:

Ensure that the sites under their purview include site-specific goals in their ISMS/EMS that contribute to the accomplishment of DOE Pollution Prevention (P2) and Energy Efficiency (P2E2) goals.  (P2E2 goals are contained in a memorandum signed by the Secretary on November 12, 1999).
Ensure that sites under their purview develop and implement cost-effective P2 programs that use life-cycle assessment concepts and practices in determining program return-on-investment (ROI).
Evaluate, on an annual basis, P2 nominations from sites under their purview, select “best in class” nominees, and transmit the nominating information to the Office of Environment, Safety and Health (EH) for submittal to the White House “Closing the Circle Awards” program.
Ensure sites under their purview monitor progress toward meeting the P2 requirements of Order 450.1 and make such information available annually to EH.

## INTEGRATING EMS INTO ISMS

- DOE O 450.1 requires DOE elements to ensure that site ISMSs include an EMS
- An EMS is that part of ISMS which addresses the environmental consequences of an organization’s products, services and activities
- In those instances where ISMS is not required for a site, DOE elements must develop and implement a stand-alone EMS

**Notes:**
Integration of an EMS into an ISMS (ISMS/EMS) provides a unified framework for the management of resources, the control and attenuation of risks, and the establishment and achievement of the organization’s environmental and safety goals.  The ISMS/EMS should be viewed as an enhancement of ISMS that adds those EMS elements not previously included in the ISMS.

## EMS FRAMEWORKS

- Several EMS frameworks exist, including ISO 14001, which is the most popular
- DOE O 450.1 does not require DOE organizations to use ISO 14001 or any specific framework
- The ISO 14001 framework involves an independent third-party certification
- DOE O 450.1 allows for EMS self-certification by Program Offices

## IMPLEMENTATION OF ISMS/EMS AT CLOSURE SITES

- Closure sites are sites that have ceased operations or have identified near-term closure dates
- Closure sites are required to implement ISMS/EMS
- Closure sites can use a graded approach to supplement their existing ISMSs to meet the requirements of DOE O 450.1
- ISMS/EMSs at Closure sites can serve as the framework for their transition to the Office of Legacy Management and/or for long-term stewardship.

**Notes:**
Sites conducting closure activities may have most of the elements of an ISMS/EMS in place.  
Existing environmental documents such as National Environmental Policy Act (NEPA) Environmental Impact Statements (EIS), Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) documents or legal agreements with the Environmental Protection Agency (EPA) and/or state agencies can be used to meet the requirements of Order 450.1.
For example, significant environmental aspects and impacts may have been identified in the Remedial Investigation/Feasibility Study (RI/FS) process under CERCLA. CERCLA also has numerous procedural requirements which could be considered for the EMS.
Sites are encouraged to tailor (using a graded approach) their EMSs to the nature and extent of the environmental impacts.

## HOW CAN I ENSURE SUCCESSFUL IMPLEMENTATION OF EMS AS PART OF ISMS?

- Communicate your support the ISMS/EMS
- Provide oversight and training
- Engage stakeholders

## CONCLUSIONS

- ISMS/EMS provides an environmental protection program that ensures early detection of and systematic management of environmental problems
- Managers can integrate environmental considerations into everyday business processes and mission activities
- Effective ISMS/EMS implementation can create an organizational culture of superior environmental performance through increased environmental awareness and life cycle accountability for everyone working at DOE sites