An Environmental Management 


System (EMS) Primer for Ports:


Advancing Port 

Sustainability 

April 2007 

interim final draft 
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U.S. Environmental Protection Agency 

An Environmental Management System 

Primer for Ports: Advancing Port 

Sustainability 

April 25, 2007 

Prepared for: 

U.S. Environmental Protection Agency 

Office of Policy, Economics, and Innovation 

Sector Strategies Division 

Kathleen Bailey, Port Sector Liaison 

Tel 202-566-2953 

Bailey.Kathleen@epamail.epa.gov 

In partnership with: 

American Association of Port Authorities 

Prepared by: 

ICF International 

9300 Lee Highway 

Fairfax, VA 22031 

(703) 934-3000 

In cooperation with: 

Global Environment & Technology Foundation 
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An EMS Primer for Ports: Advancing Port Sustainability 

Table of Contents 

List of Acronyms............................................................................................................................................iii

Introduction ...................................................................................................................................................1

Overview of EMSs.........................................................................................................................................1

How an EMS Advances Port Sustainability ..................................................................................................3

Elements in Developing an EMS ..................................................................................................................4

Primer Layout................................................................................................................................................5

Element 1: Define Scope of EMS and Assign Responsibilities ....................................................................6

Element 2: Create Environmental Policy Statement.....................................................................................9

Element 3: Identify Relevant Legal and Other Requirements.....................................................................13

Element 4: Identify Environmental Aspects & Significant Environmental Aspects .....................................15

Element 5: Establish Objectives, Targets, and Action Plans ......................................................................19

Element 6: Develop Operational Controls...................................................................................................22

Element 7: Develop Emergency Preparedness and Response Program...................................................24

Element 8: Set Up a Training Program for Competence and Awareness ..................................................26

Element 9: Create a Communications Strategy..........................................................................................28

Element 10: Set Up Documentation for the EMS .......................................................................................30

Element 11: Monitor, Measure, Evaluate, and Record Performance .........................................................32

Element 12: Conduct Audits and Correct Problems ...................................................................................35

Element 13: Conduct Management Review................................................................................................36

Security Management Systems (SMSs) Based on the Plan-Do-Check-Act Model....................................37

Conclusion ..................................................................................................................................................39

Interim Final Draft, April 2007 i U.S. Environmental Protection Agency 
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An EMS Primer for Ports: Advancing Port Sustainability 

List of Acronyms 

AAPA American Association of Port Authorities 

BMP Best management practice 

C&M Construction & maintenance 

CAA Clean Air Act 

CEO Chief executive officer 

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act 

CFR Code of Federal Regulations 

CIF Continual Improvement Form 

CFT Cross-functional team 

COO Chief operating officer 

COOP Continuity of operations 

CWA Clean Water Act 

DVD Digital versatile disc or digital video disc 

EA Environmental aspect 

EBIT Earnings before interest & taxes 

EH&S Environmental, health, and safety 

EI Environmental impact 

EMP Environmental management plan 

EMR Environmental management representative 

EMS Environmental management system 

EO Executive order 

EPA U.S. Environmental Protection Agency 

EPCRA Emergency Planning & Community Right-to-Know Act 

EP&R Emergency preparedness and response 

FEMA Federal Emergency Management Agency 

FRP Federal Response Plan 

FSP Facility security plan 

GETF Global Environment & Technology Foundation 

GHG Greenhouse gas 

GRI Global Reporting Initiative 

ha hectare 

HMTA Hazardous Materials Transportation Act 

HNE Harbors, Navigation, and Environment [AAPA Sustainability Working Group] 

HVAC Heating, ventilating, and air conditioning 

ICP Integrated Contingency Plan 

ILO International Labour Organization 

ISO International Organization for Standardization 

ISPS International Ship and Port Security 

JRRF James River Reserve Fleet 

LEED Leadership in Energy and Environmental Design 

MARAD Maritime Administration 

MARSEC Maritime Security 

MFM Marine Facility Management 

MOA Memorandum of agreement 

MTSA Maritime Transportation Security Act 

NIT Norfolk International Terminals 

NOV Notice of violation 

NOx Nitrogen oxides 

NRAMP Natural resources assessment and implementation plan 

PAS Publicly available specification 

PDX Portland International Airport 

PM particulate matter 

RCRA Resource Conservation & Recovery Act 

Interim Final Draft, April 2007 iii U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

List of Acronyms 

SAFE Security and Accountability for Every [Port Act of 2006] 

SEA Significant environmental aspect 

SMS Security management system 

SOLAS Safety of Life at Sea 

SOP Standard operating procedure 

SPCC Spill Prevention, Control and Countermeasure 

3Es Economic, environmental, and social (equity) 

3Ps Profit/prosperity, planet, and people 

TSCA Toxic Substances Control Act 

USACE U.S. Army Corps of Engineers 

USGC U.S. Coast Guard 

VIT Virginia International Terminals 

V-REMS Virginia Regional Environmental Management System 

VPA Virginia Port Authority 

Interim Final Draft, April 2007 iv U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Introduction 

Waterborne commerce is increasing rapidly and presenting ports with challenges that could not have 

been imagined even two decades ago. By 2020, the total volume of cargo shipped by water is expected 

to be double that of 2001 volumes.1 At the same time, lifestyle changes have made the cruise industry the 

fastest growing segment of the travel industry – achieving more than 2,100 percent growth since 1970.2 

To accommodate increases in trade volume, increases in the size of cargo and cruise ships, and new 

security requirements, many U.S. ports are investing billions of dollars in infrastructure improvements 

such as deeper channels, larger cranes, and other facility and property enhancements. While many of 

these investments facilitate improvements in the operational efficiency of existing port operations, many 

ports also need to physically expand to meet business demands. Even the ports that have traditionally 

viewed themselves as environmental stewards of coastal resources are finding it challenging to balance 

economic, environmental, and social issues, i.e., to grow sustainably. 

To ensure that this growth is executed responsibly, many ports have proactively addressed their 

environmental and related socio-economic responsibilities through the development of Environmental 

Management Systems (EMSs). The purpose of this primer is to help ports develop EMSs and understand 

how an EMS can advance port sustainability. 

Overview of EMSs 

An EMS is a formal system for proactively managing the environmental footprint of a port. It incorporates 

environmental considerations and decision making into a port’s day-to-day operations and into its 

strategic planning. Additionally, an EMS provides a structured framework designed to achieve continual 

environmental improvement beyond regulatory compliance. An EMS can help ports to improve efficiency, 

reduce costs, and minimize negative impacts on human health and the environment. 

Over the last several years, the U.S. Environmental Protection 

Agency (EPA) has been involved in a wide range of voluntary 

activities to facilitate adoption of EMSs, including the Sector 

Strategies Program, which promotes the use of EMSs at ports as 

well as a dozen other economic sectors nationwide.3

 EPA also has 

EMSs at its own facilities and assists other government agencies in 

developing theirs.4 

While each EMS is unique to an organization’s culture and priority 

issues, most follow the Plan-Do-Check-Act model. This model 

establishes a framework to examine and prioritize the environmental 

aspects of an organization, then develop, implement, monitor, 

review, and revise environmental programs and procedures to 

1

 See www.aapa-ports.org/Industry/content.cfm?ItemNumber=1022&navItemNumber=901, accessed March 30, 

2007. 

2

 See www.cruising.org/press/sourcebook2006-midyear/profile_cruise_industry.cfm, accessed March 30, 2007. 

3

 See www.epa.gov/sectors/ports/index.html for information on port participation in EPA’s Sector Strategies 

Program. 

4

 On October 16, 2006, EPA restated its commitment to integrating and utilizing EMS at its own facilities 

nationwide; see “Commitment to the Integration and Utilization of Environmental Management Systems,” a copy of 

which is available at: www.peercenter.net/ewebeditpro/items/O73F9817.pdf, accessed March 30, 2007. For more 

information on EPA’s progress in implementing EMSs at its laboratories and offices nationwide, please visit: 

http://www.epa.gov/ems/epaown/index.htm. One way that EPA assists other federal agencies develop EMSs is by 

providing information through the Fedcenter website (http://www..fedcenter.gov), which helps federal agencies better 

address their environmental needs. 

Interim Final Draft, April 2007 1 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

continually promote sound day-to-day management and improvement. Many ports already have 

components of an EMS in place, such as written and unwritten procedures, best management practices 

(BMPs), and regulatory compliance programs. An EMS naturally leverages and builds upon existing good 

practices and the practical knowledge base of employees throughout the organization. 

U.S. ports with an EMS in place include: 

• Massachusetts Port Authority (Massport), Port of Boston;5 

• Port Authority of New York and New Jersey; 

• Port of Corpus Christi Authority, TX; “We see the EMS as a valuable tool to help us meet the • Port of Houston Authority, TX; environmental challenges facing our port.” — Ralph G. 

• Port of Los Angeles, CA; Appy, Ph.D., Director of Environmental Management, 

• Port of Portland, OR; Port of Los Angeles 

• Port of Seattle, WA; 

• Port of Vancouver, WA; and Source: EPA, AAPA, & GETF. Environmental 

Management Systems: Systematically Improving your • Virginia Port Authority. Performance: Ports Sector, September 2004. 

Domestic ports developing an EMS include: 

• Maryland Port Administration, Port of Baltimore; 

• Port Everglades, FL; 

• Port of Cleveland, OH; 

• Port of Everett, WA; 

• Port of Freeport, TX; 

• Port of Long Beach, CA; 

• Port of New Orleans, LA; and 

• Port of Oakland, CA. 

These and other ports worldwide have found Common Principles of Sustainability 

important benefits from developing EMSs: 

• Dealing transparently & systemically with risk, 

• Improved environmental awareness, uncertainty, & irreversibility 

compliance, and performance; • Ensuring appropriate valuation, appreciation, & 

• Reduced costs and improved operational restoration of nature 

efficiency through more efficient use of • Integration of environmental, social, human, & 

materials, operational streamlining, and economic goals in policies & activities 

strategic direction setting; • Equal opportunity & community participation 

• Reduced risk and liability, and improved • Conservation of biodiversity & ecological integrity 

• Ensuring inter-generational equity security and emergency response • Recognizing the global integration of localities 

capability; • A commitment to best practice

• Improved internal communication and • No net loss of human capital or natural capital 

cooperation, including those between port • The principle of continuous improvement 

authorities and terminal operators; and • The need for good governance 

• Enhanced credibility, public image, and 

public confidence, as ports monitor and Source: Hargroves, K. and M. Smith (Eds.) 2005. The 

report performance and position Natural Advantage of Nations: Business Opportunities, 

themselves as leaders in environmental Innovation and Governance in the 21st Century. 

protection and management. Earthscan/James&James. 

5

 Massport has also developed an EMS for its airport facilities. 

Interim Final Draft, April 2007 2 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

How an EMS Advances Port Sustainability 

In addition to environmental compliance requirements, ports continue to face daunting challenges in this 

time of significant growth. Among other realities, heightened community concern about port expansion 

plans, the magnitude of anticipated resource and capital investments, and rising costs of energy 

resources and management of waste byproducts have left many ports looking for an all-inclusive, 

systems-based, management approach to operations. Increasingly, ports are looking holistically at their 

overall business practices with a view toward “sustainability.” 

Since first introduced in the mid-1970s, the concept of 

sustainability as a business concern has evolved to 

equate to the “Triple Bottom Line” or “sustainability trinity,” 

i.e., an organization’s performance in three areas: 

• 3Es – Economic, Environmental, and social (Equity); 

or 

• 3Ps – Profit/Prosperity, Planet, and People.6 

The Global Reporting Initiative (GRI), for example, has 

developed a 3E framework for sustainability reporting that 

is now used by nearly 1,000 organizations from over 60 

countries.7

 Acknowledging lessons learned from the GRI 

efforts and other sustainability initiatives, the American 

Association of Port Authorities (AAPA) is also working to 

develop and implement a sustainability framework for its 

members. AAPA represents the 80+ largest public ports in 

the United States and is a partner in EPA’s Sector 

Strategies Program. 

A key tenet of sustainability is that it is not limited to environmental stewardship. Rather, sustainability 

focuses on understanding the interconnections among the economy, society, and environment, and the 

equitable distribution of resources and opportunities – both now and in the future. Sustainable ports look 

at their operations in an all-inclusive manner, enhancing their profitability while existing responsibly within 

the larger community. They are able to meet today’s global economic, environmental, and social needs 

without compromising the ability of future generations to meet theirs. 

Ports are beginning to define broader sustainability policies that extend beyond environment stewardship. 

The Port of New York and New Jersey has developed the following Triple Bottom Line statement: 

Success won't be measured by simple market-based metrics like cargo volume or market 

share alone. In fact, as it serves its maritime customers, the Port of New York and New 

Jersey must also meet a Triple Bottom Line. It must be: 1) an engine of regional 

prosperity; 2) secure and environmentally sustainable; and 3) financially self-sustaining. 

Those are key components of the region’s quality of life – and that is the benchmark of 

success for the bi-state Port.8 

6

 In its 1987 Report, Our Common Future, the United Nations-convened Brundtland Commission dealt with 

sustainable development, which it defined as "development that meets the needs of the present without 

compromising the ability of future generations to meet their own needs." See www.ringofpeace.org/ 

environment/brundtland.html for an easy-to-read version of the Brundtland Report; accessed April 2, 2007. 

7

 See http://www.globalreporting.org/ReportingFramework/ for additional information on GRI’s Reporting 

Framework. 

8

 Statement provided by Joseph Monaco, March 8, 2007, email to AAPA’s Harbors, Navigation, and 

Environment (HNE) Sustainability Working Group. 

Sustainable Ports Keep Things Moving 

Interim Final Draft, April 2007 3 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Other ports, including the Port of Oakland, also define sustainability in terms of the “3E trinity” of 

economic, environmental, and social equity. 

These and other examples suggest that ports worldwide are working toward and committed to 

sustainability, with promising potential and possibilities. 

Clearly, senior management support and leadership are crucial – both for an EMS and its environmental 

stewardship activities, and for broader sustainability principles and practices. The decision to implement 

an EMS entails a commitment of time and monetary resources. On average, it takes a year to set up an 

EMS, although individual systems can vary from three months to two years depending on project scope 

(i.e., its “fenceline”) and resources.9

 Senior management plays an active role in the EMS, continually 

assessing the organization’s progress toward its goals, looking for ways to improve management and 

performance, effectively allocating resources and personnel, and sustaining commitment to the system 

through annual reviews and revisions. Costs vary, but ports that have implemented an EMS have found 

they are able to recover their upfront costs quickly through early identification of pollution prevention 

initiatives, potential liabilities, and opportunities to reduce risks.10 

Elements in Developing an EMS 

Within the Plan-Do-Check-Act approach, there Port Sustainability is Worldwide 

are a number of elements that comprise an 

EMS. The most commonly used framework for “We are committed to sustainable development on port 

an EMS is the one developed by the land. Our EMS is central to all decision making regarding 

International Organization for Standardization environmental performance and sustainability. Simple 

for its ISO 14001 Standard. For ease of design solutions help create healthy buildings and 

presentation, several ISO elements have been promote a sustainable approach to development.” — Port 

combined in this primer, resulting in a set of 13 of Brisbane, Australia 

elements: Source: Port of Brisbane website, 

http://www.portbris.com.au/health/environment/ 

1. Define scope of EMS and assign environmental_management_systems 

responsibilities; 

2. Create environmental policy statement; 

3. Identify relevant legal and other 

requirements; 

4. Identify environmental aspects and significant environmental aspects; 

5. Establish objectives, targets, and action plans; 

6. Develop operational controls; 

7. Develop emergency preparedness and response program; 

8. Set up a training program for competence and awareness; 

9. Create a communications strategy; 

10. Set up documentation for the EMS; 

11. Monitor, measure, evaluate, and record performance; 

12. Conduct audits and correct problems; and 

13. Conduct management review. 

From Element 1, determining the scope of the effort, to Element 13, performing a management review, 

there are opportunities for ports to integrate broader sustainability concepts into their EMSs. Ports have 

9

 Conversation with EPA Sector Strategies Program staff, April 2, 2007. 

10 EPA, AAPA & GETF. Environmental Management Systems: Systematically Improving your Performance: 

Ports Sector, September 2004. Also see 1st Ports EMS/SMS Assistance Project, Final Report, May 2006, for 

information on average resource commitments over a 2-year project period at 11 ports. 

Interim Final Draft, April 2007 4 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

begun to plan and implement sustainable, “green port” policies that build on, but extend beyond, their 

environmental stewardship initiatives. In fact, it can be hard to distinguish between actions resulting from 

implementation of an EMS and actions taken to improve a port’s sustainability. It may be helpful to think 

of this range of activities on a continuum. 

Primer Layout 

Efforts by ports to improve their sustainability can be documented and captured within the Plan-DoCheck-Act EMS framework. To help ports understand EMS and sustainability, this primer provides the 

following information on each EMS element: 

• A brief overview of the element in the context of an EMS to provide ports with general EMS concepts; 

• One or more real life examples of how ports have implemented the element within their operations; 

and 

• A discussion of how each element can be extended to include facets of broader sustainability. 

Many of the examples in this primer come from the 1st Ports Environmental Management 

Systems/Security Management Systems Assistance Project (January 2004 – December 2005),11 

developed by AAPA in partnership with EPA’s Sector Strategies Program and the Global Environment & 

Technology Foundation (GETF). Through this project, nine ports and two federal maritime facilities 

worked together over two years to develop EMSs. In addition, the Port of Houston Authority, which had 

previously developed an EMS, applied the management systems approach to develop a Security 

Management System (SMS). Following the discussion of EMS elements, this primer provides an overview 

of how Houston and other ports are using the Plan-Do-Check-Act approach to address security issues 

through SMSs. 

A 2nd Ports EMS/SMS Assistance Project began in February 2006 with four of the seven participating 

ports developing EMSs and three using the management systems approach to develop SMSs. This 2nd 

round of EMS/SMS assistance will be completed by March 2008.12 

Additional examples of ports that are working on EMSs, SMSs, and broader sustainability programs come 

from AAPA members and from ports located outside the Americas. Information on AAPA’s EMS 

Assistance Projects and its Harbors, Navigation, and Environment Committee can be found at www.aapaports.org. To begin developing your port’s own customized EMS, refer to numerous online resources, 

including a list of Technical Assistance Providers, sample documents, and other EMS tools, by visiting 

www.epa.gov/ems and www.peercenter.net. For more information about the port-related activities of 

EPA’s Sector Strategies Program, visit www.epa.gov/sectors/ports. 

11 See Final Report, May 2006, at www.peercenter.net/ewebeditpro/items/O73F8587.pdf, accessed March 30, 

2007. Contacts at each of the participating ports are listed on p.1 of that publication. 

12 See press release on 2nd round participants at www.peercenter.net/ewebeditpro/items/O73F7760.pdf; 

accessed March 30, 2007. 

Interim Final Draft, April 2007 5 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Element 1: Define Scope of EMS and Assign Responsibilities 

A first step in EMS planning is to establish the “fenceline” by documenting the scope of 

port facilities and activities that the EMS will address. As shown in the accompanying 

graphic, there are facilities and activities over which a port has direct control. There are 

other facilities and activities that a port does not directly control but over which it has 

some influence (e.g., tenant operations). 

Finally, there are facilities and activities within a 

port’s zone of interest that could be brought 

into its zone of influence if the port is proactive (e.g., regional 

intermodal transportation planning). Most ports start with facilities 

and operations over which they have direct control; then, they 

later expand their EMS to address broader areas of influence. 

When defining the scope of its EMS, a port should also consider 

practical constraints and timing. 

EMS responsibilities should be assigned to individuals who can 

competently complete and fulfill their roles. At a minimum, you 

should describe responsibilities for Core EMS Team members, 

designate people for these roles, establish lines of authority, 

and create an organization chart for your EMS. Documentation 

and communication of roles, responsibilities, and authority 

throughout the port will facilitate effective EMS implementation 

and management. 

Resources are essential for implementation Typical EMS Core Team Members and control of an EMS. They include training, 

human resources, specialized skills, financial • Environmental Management Representative (EMR): 

resources, and technical and informational Project Manager &/or member of port’s top services. Port management must ensure the management 

availability of such resources to the EMS. • EMS Coordinator: Leads the Team, ensures support 

for the EMS, & makes sure all EMS tasks are 

Element 1 in the Field completed 

• Cross-Functional Team (CFT): Comprises members 

Ports have selected their EMS fenceline based who represent each major operation within the port & 

serve as an information resource; may include risk 

on many considerations. For example, the management, public affairs, operations, human Maritime Administration (MARAD) selected the resources, etc. James River Reserve Fleet (JRRF), a federal 

anchorage on the James River Fort Eustis 

Army Transportation Center in Newport News, VA, as the fenceline for its 1st EMS/SMS Assistance 

Project. MARAD believed that an EMS could enhance its credibility as a federal environmental steward 

on the James River. Over the last couple of years, National Defense Reserve Fleet ships at JRRF 

awaiting disposal and/or reefing had been under intense scrutiny by regulatory agencies, including the 

Virginia Department of Environmental Quality and the U.S. Coast Guard (USCG). A number of ships built 

in the 1950s, 1960s, and 1970s contained fuel and oil that could pose a threat to the James River 

ecosystem if an oil spill were to occur. JRRF was chosen as the EMS site because of its diverse 

environmental consequences, including its position as a tenant at Fort Eustis.13 

Ports across the country have developed EMS Core Teams that are right-sized for their situations, 

accessing staff from across operations and divisions within their fencelines.

14 

13 Example from the 1st Ports EMS/SMS Assistance Project Final Report, May 2006. 

14 Unless otherwise indicated, these examples are from the 1st Ports EMS/SMS Assistance Project Final Report, 

May 2006. 

Interim Final Draft, April 2007 6 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

• Port of Virginia: Because of its size, operational impact on the environment, and public presence, 

Norfolk International Terminals (NIT), one of four facilities comprising the port, was chosen as the 

facility for an EMS assistance project. This facility is owned by the Commonwealth of Virginia and 

operated by Virginia International Terminals (VIT), an operating affiliate of the Virginia Port Authority 

(VPA). The EMS Core Team included six staff: two members from VPA (Chief Engineer, and Director 

of Environmental Affairs as EMR) and four members from VIT (Director of Engineering and 

Maintenance, Facilities Maintenance Supervisor, Vehicle Maintenance Supervisor, and Crane and 

Straddle Carrier Supervisor). 

• Portland District, U.S. Army Corps of Engineers (USACE): The Corps’ Portland District selected the 

U.S. Government Moorings shipyard (which includes a number of maintenance facilities and offices 

for personnel who operate and maintain the ships), two hopper dredges (the ESSAYONS and 

YAQUINA), and associated survey and support vessels as the fenceline for its EMS assistance 

project. The EMS Core Team comprised 11 members: the Environmental Compliance Coordinator as 

EMR, as well as plant maintenance and dredge operations chiefs, four dredge captains, the shipyard 

superintendent, two senior port engineers, and the lead hydrographic survey technician. 

• Port of Los Angeles: The port selected the Construction and Maintenance (C&M) Division as the 

fenceline for its EMS assistance project. C&M provides maintenance services to all port-owned 

facilities and consists of offices, equipment storage, and shops for each craftspeople, including 

electricians, equipment operators, gardeners, painters, laborers, mechanics, machinists, plumbers, 

roofers, crane mechanics, pile drivers, and carpenters. The EMS Core Team included 25 C&M 

personnel, 4 representatives from the Environmental Management Division, 1 representative from 

Public Affairs, and 1 representative from Risk Management. 

• Port of Seattle: The Port of Seattle is currently piloting an EMS at its Fishermen’s Terminal. Wayne 

Grotheer, Director of Seaport Finance and Asset Management, noted, “We decided to pilot this 

program at Fishermen’s Terminal because it is a microcosm of the larger port. At Fishermen’s we 

have large and small moorage customers, retail, office and industrial tenants and open public access. 

If a more systematic and formalized approach to managing environmental issues works at 

Fisherman’s Terminal, the port may adopt a similar approach at other facilities.” Seattle established 

an EMS Core Team that includes a cross-section of staff members from its Harbor Services, Health & 

Safety, Risk Management, and Environmental Divisions.15 

Enhancements for Sustainability 

One way for a port to incorporate sustainability into its EMS is to widen the scope of the EMS to include 

more facilities and activities. Rather than focusing solely on its own operations, a port can include the 

environmental impacts of all entities over which the port exercises control or significant influence with 

regard to financial and operating policies and practices. 

• As part of its Green Port Policy,16 the Port of Long Beach is developing a tiered Sustainability 

Implementation Plan, which is taking a step-wise approach to defining the port boundary for the 

purposes of sustainability: 

o First, considering areas that are within the port’s direct control; 

o Then, extending to tenants; and 

o Finally, extending to the region in which the port is located. 

15 Intranet newsletter entitled “New Environmental Program Tests the Waters (And More) At Port Of Seattle’s 

Fishermen’s Terminal,” Port of Seattle, submitted by Wayne Grotheer to EPA’s Sector Strategies Program via email, 

May 10, 2006. 

16 See www.polb.com/environment/green_port_policy.asp, accessed March 28, 2007. 

Interim Final Draft, April 2007 7 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Long Beach has identified, institutionalized, and budgeted for a Sustainability Practice Manager to 

coordinate development and implementation of its Sustainability Implementation Plan. This 

management position cross-cuts port operations. 

• The Virginia Port Authority is participating in the Virginia Regional Environmental Management 

System (V-REMS), a partnership of over 50 federal, state, and local public and private organizations 

that collaborate to address regional community and environmental issues. Through the V-REMS 

partnership, participants leverage the collective knowledge and best practices of over 45 public and 

private organizations that are all working to improve their environmental performance and costefficiency. Accordingly, by serving as a crucial resource for information and collaborative 

opportunities, the V-REMS partnership helps its participants save time and money while they 

contribute to a cleaner regional environment.17 

17 See http://www.vrems.org/, accessed April 24, 2007. 

Interim Final Draft, April 2007 8 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Element 2: Create Environmental Policy Statement 

Once your port has its Core EMS Team trained and in place, the next step is to define, 

develop, and communicate your facility’s environmental policy. As your Team moves 

forward, the policy will: 

• Serve as the foundation for implementing and improving the EMS; 

• Provide a unifying vision of environmental commitments and principles that will 

guide the actions of employees and top management; and 

• Demonstrate your port’s proactive environmental performance commitments to your workforce, 

customers, and the public. 

Minimum Port Commitments in EMS Policy Statement Element 2 in the Field • Compliance with legal requirements & voluntary 

Many ports have developed environmental commitments 

policy statements to guide their EMS efforts. • Pollution prevention 

The following example comes from the Virginia • Continuous improvement in environmental 

performance, including non-regulated areas Port Authority’s participation in the 1st Ports • Communications with your community about the EMS/SMS Assistance Project;18 note its port’s environmental performance & the operation of 

references to commonwealth laws and the the EMS 

inclusive nature of its list of port stakeholders. 

The Virginia Port Authority and Virginia International Terminals, Inc., are committed to 

conducting Port operations and managing resources in an environmentally sensitive and 

sound manner, as prescribed by Article XI, Section 1 of the Constitution of Virginia. It is 

the intent of each organization to: 

1. Meet or exceed all applicable Federal, State, and Local environmental laws and 

regulations. 

2. Employ management systems and procedures specifically designed to prevent 

activities and conditions that pose a threat to human health, safety, and the 

environment through proactive environmental leadership and compliance. 

3. Integrate environmental costs, risks, and impacts into port project development and 

facility improvements and to continually evaluate and improve operational efficiency 

and practices to achieve our established environmental and business objectives. 

4. Promote pollution prevention and environmental awareness through communications 

with employees, customers, tenants, suppliers, contractors, other terminal users, 

regulatory agencies, neighboring communities and environmental organizations. 

The Virginia Port Authority and Virginia International Terminals, Inc., are committed to the 

spirit and intent of this policy and the laws and regulations, which give it foundation. 

REF: Constitution of Virginia, Effective July 1, 1971 with Amendments – January 1, 2005. 

Adopted 24 May 2005, Virginia Port Authority, Board of Commissioners 

Massport’s environmental policy is available on the Internet; it, too, addresses a broad set of stakeholders 

and also promotes sustainable design principles:

19 

Massachusetts Port Authority (Massport) is committed to operate all of its facilities in an 

environmentally sound and responsible manner. 

18 See Final Report, May 2006. 

19 See www.massport.com/business/pic/c_envmgmt.pdf, accessed March 28, 2007. 

Interim Final Draft, April 2007 9 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Massport will strive to minimize the impact of its operations on the environment through 

the continuous improvement of its environmental performance and the implementation of 

pollution prevention measures, both to the extent feasible and practicable in a manner 

that is consistent with Massport’s overall mission and goals. To successfully implement 

this policy Massport will develop and maintain management systems that will: 

• Ensure that the environmental management policy is available to staff, tenants, 

customers and the general public. 

• Ensure compliance with all applicable environmental laws and regulations. 

• Ensure that environmental considerations are included in business, financial, 

operational, and programmatic decisions, including feasible and practicable options 

for potentially exceeding compliance with applicable regulatory requirements. 

• Define and apply sustainable design principles in the planning, design, operation and 

decommissioning of its facilities. 

• Define and establish environmental objectives, targets and best management 

practices and monitor performance. 

• Provide training to and communication with staff and affected tenants regarding 

environmental goals, objectives and targets and their respective roles and 

responsibilities in fulfilling them. 

• Incorporate monitoring of Massport and Massport tenants’ environmental activities. 

• Include the preparation of an annual environmental performance report which will be 

made available to staff, tenants, customers and the general public. 

Enhancements for Sustainability 

One way ports have combined both environmental and social goals is to make policy information readily 

available in more than one language. To that end, the Port of Corpus Christi Authority has published its 

environmental policy statement in both English and Spanish, so it could be understood by its native 

Spanish-speaking employees and by the community.20 

Other ports are developing sustainability mission statements or value statements. For example, in 

January 2005 the Board of the Port of Long Beach adopted a Green Port Policy that serves as a guide for 

decision making and establishes a framework for environmentally friendly port operations. The policy’s 

five guiding principles are: 

• Protect the community from harmful environmental impacts of port operations; 

• Distinguish the port as a leader in environmental stewardship and compliance; 

• Promote sustainability; 

• Employ best available technology to avoid or reduce environmental impacts; and 

• Engage and educate the community.21 

Outside the U.S., the Port of Brisbane, Australia, has posted its environmental policy statement on the 

Internet.22 This statement addresses broader port sustainability, including economic resources and 

stakeholder involvement: 

20 To read the port’s environmental policy statement in Spanish, please refer to the 1st Ports EMS/SMS 

Assistance Project, Final Report, May 2006. 

21 See www.polb.com/environment/green_port_policy.asp, accessed March 28, 2007. 

22 See www.portbris.com/au, accessed March 30, 2007. 

Interim Final Draft, April 2007 10 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Our environmental policy is to develop and implement best-practice strategies and 

systems to minimize the environmental impacts of our operations and promote the 

development of a sustainable port. 

The Port of Brisbane Corporation is a commercial port operator whose corporate purpose 

is to be a world class facilitator of integrated solutions for the logistics and business 

development requirements of its customers. To achieve this its prime objectives are: 

• Adopting leading planning principles and management systems; 

• Working cooperatively to ensure a safe and secure port environment; 

• Providing world-class infrastructure; and 

• Behaving at all times in line with our corporate values. 

A successful port is an essential part of the economic resources of the national, regional 

and local communities. In operating as a successful port business, the Port of Brisbane 

Corporation is committed to ensuring that the activities of the Corporation are conducted 

in an ecologically sustainable manner with a high standard of environmental 

performance. This will be achieved while ensuring that the needs of the community and 

the values attached to natural and physical resources are taken into account in 

corporation planning and the way in which business is conducted. 

To achieve environmental performance consistent with this policy, the Port of Brisbane 

Corporation will employ the following principles: 

Planning 

• To include environmental considerations in the Corporation’s decision making. 

• To provide adequate resources for employees at all levels to fulfill their 

responsibilities as directed under this policy. 

• To implement procedures to enable activities to be carried out in an environmentally 

responsible way. 

• To set environmental objectives and targets for Corporation activities and to review 

these on an annual basis. 

• To conduct regular review of the Corporation’s environmental performance and act 

on the results. 

• To continuously improve the environmental performance of the Corporation. 

• To continuously improve the environmental management system of the Corporation. 

Practices 

• To meet environmental standards in the Corporation’s key activities. 

• To assess the environmental impacts of the Corporation’s activities. 

• To plan, design, operate and complete any operation in a manner that reduces 

environmental risks. 

• To monitor environmental compliance in a professional manner. 

• To abide by and comply with the Environmental Protection Act 1994 and all other 

applicable environmental laws, regulations, policies, standards and codes of practice. 

• To comply with the codes of practice of appropriate industry representative 

organizations. 

• To prevent pollution from Corporation activities 

People 

• To appoint staff and contractors on criteria which include that they have the 

appropriate skill and experience to carry out work in a way that is compatible with 

good environmental performance and this policy. 

• To train staff to have the appropriate skill and experience to ensure that operations 

are completed with the utmost respect for the environment. 

Interim Final Draft, April 2007 11 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

• To specify the need for all contractors to carry out their work in accordance with this 

Environmental Policy and to supervise such compliance. 

• To communicate with affected individuals, community and Government bodies about 

the Corporation’s activities as relevant. 

• To give due consideration for local culture and custom. 

The Port of Brisbane Corporation will hold employees and contractors accountable for 

their implementation of this Environmental Policy. 

This Policy will be reviewed annually. 

Jeff Coleman, Chief Executive Officer 

Interim Final Draft, April 2007 12 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Element 3: Identify Relevant Legal and Other Requirements 

Compliance with legal requirements is one of the main pillars upon which your 

environmental policy (Element 2) should be based, because the potential costs of noncompliance (e.g., possible damage to the environment, revenue loss, and impact on 

public image) can be very high. Therefore, your port should develop a procedure to 

identify, access, analyze, and communicate applicable legal and other requirements 

and ensure that these requirements are factored into the organization’s management 

efforts. In addition to federal 

regulations, be sure to check with your state Commonly Applicable Federal Environmental Laws 

and local authorities to determine other 

applicable requirements and permitting • Clean Air Act (CAA): Establishes ambient & source 

conditions. Other requirements might include emission standards & permit requirements for 

industry or trade group codes of practice, or conventional & hazardous air pollutants 

neighborhood or community association • Clean Water Act (CWA): Establishes ambient & 

point source effluent standards & permit requirements. Because legal and other requirements for water pollutants; also includes storm requirements change over time, your process water management requirements 

should ensure that you are working with up-to- • Comprehensive Environmental Response, date information. Compensation, and Liability Act (CERCLA, or 

Superfund): Establishes a program for cleaning up 

Element 3 in the Field contaminated waste sites, establishes liability for 

cleanup costs, & provides reporting requirements for 

Many ports are controlled by cities and releases of hazardous substances 

• Emergency Planning & Community Right-to- localities – for example, the City of Houston, Know Act (EPCRA): Establishes a program (the the Harris County Commissioners Court, the “Toxic Release Inventory”) to inform the public about 

Harris County Mayors and Councils releases of hazardous & toxic chemicals 

Association, and the City of Pasadena govern • Hazardous Materials Transportation Act (HMTA): 

the Port of Houston Authority; the City of Long Establishes standards for the safe transport of 

Beach has control over the Port of Long hazardous materials 

Beach. Additionally, some states, such as • Resource Conservation & Recovery Act (RCRA): 

Massachusetts and Maryland, require their Establishes regulations & permit requirements for 

agencies to have EMSs. Thus, Massport/Port hazardous waste management; creates standards for 

of Boston was one of the first agencies to underground storage tanks that hold oil or hazardous 

substances develop and implement an EMS; the Maryland 

Port Administration/Port of Baltimore is • Toxic Substances Control Act (TSCA): Regulates 

currently participating in the 2nd Ports the use, development, manufacture, distribution & 

disposal of chemicals 

EMS/SMS Assistance Project. 

Enhancements for Sustainability 

Many states, cities, and localities have issued sustainability statements or have construction requirements 

that may impact port development. 

• Oregon has issued several Executive Orders (EOs) regarding sustainability for the 21st century, 

including its most recent EO 06-02.

23 Oregon ports, including the Port of Portland and USACEPortland District, operate with full awareness of these state-level EOs. The state also established 

Toxics Use and Hazardous Waste Reduction Program requirements; USACE-Portland District’s EMS 

facilitated compliance with these newly mandated requirements.24

23 See www.oregon.gov/ODOT/SUS/Sustainability_Mandates.shtml, accessed March 28, 2007, for additional 

information on Oregon’s sustainability mandates. 

24 From 1st Ports EMS/SMS Assistance Project, Final Report, May 2006. 

Interim Final Draft, April 2007 13 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

• Sustainable Seattle is a non-profit organization dedicated to enhancing the long term quality of life in 

the Seattle/King County area. Senior staff at the Port of Seattle serve on Sustainable Seattle’s Board 

of Directors and Advisory Council.25 

• In 2006, the Baltimore City Green Building Task Force recommended that Baltimore establish green 

building standards for city-funded construction and offer incentives to private developers of 

commercial buildings to build to green building standards.26 Although these recommended standards 

would not directly apply to the Port of Baltimore, the growing interest of the community in green 

buildings could easily manifest itself in calls for the port to adhere to similar standards. 

Over time, the federal government has also issued a number of EOs to “green” the government’s 

operations. Most recently, EO 13423 of January 24, 2007, Strengthening Federal Environmental, Energy, 

and Transportation Management, sets goals for the federal government in the areas of energy efficiency, 

acquisition, renewable energy, toxics reductions, recycling, renewable energy, sustainable buildings, 

electronics stewardship, fleets, and water conservation. In addition, this EO requires more widespread 

use of EMS as the framework in which to manage and continually improve these sustainable practices. 

These and other EOs27 impact port facilities managed by federal agencies, such as MARAD, USACE, and 

USCG operations. For example, USACE began integrating EMS into its civil works operating facilities in 

response to EO 13148.28 Portland District’s Channels and Harbors Project was selected, along with 11 

other Corps projects, to be among the first to begin implementing an EMS.29 MARAD was also proactive 

in setting its Strategic Plan and vision of implementing EMS at facilities under EO 13148.30 

To the extent that a port extends its EMS to look at links between environmental and security, labor, or 

social equity issues, additional requirements may apply. For example, the Maritime Transportation 

Security Act of 2002 (MTSA) defines a "transportation security incident" as a "security incident resulting in 

significant loss of life, environmental damage, transportation system disruption, or economic disruption in 

a particular area." MTSA, USCG Regulations 33 CFR Part 105 (regarding USCG’s jurisdiction and 

responsibilities for security planning and execution in and round U.S. waterways), and the general 

provisions of Chapter XI-2 of the International Convention for the Safety of Life at Sea (SOLAS) and the 

International Ship and Port Security Code (ISPS Code) address security considerations at ports. 

25 See www.sustainableseattle.org for additional information on Seattle Seattle’s mission, vision, and history, as 

well as its staff, Board of Directors, and Advisory Council members; accessed March 28, 2007. 

26 Baltimore City Green Building Task Force, Report on Sustainable Building Guidelines and Standards for 

Public and Private Construction and Renovation Projects, April 2006, 

http://www.ci.baltimore.md.us/government/planning/images/GreenBuilding.pdf , accessed April 20, 2007. 

27 EO disposition tables are found at www.archives.gov/federal-register/executive-orders/disposition.html, 

accessed March 28, 2007. 

28 EO 13148, Greening the Government through Leadership in Environmental Management, available at: 

http://www.epa.gov/EMS/position/eo13148.htm. 

29 From 1st Ports EMS/SMS Assistance Project, Final Report, May 2006. 

30 From 1st Ports EMS/SMS Assistance Project, Final Report, May 2006. 

Interim Final Draft, April 2007 14 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Element 4: Identify Environmental Aspects & Significant 

Environmental Aspects 

In Element 1 you defined the scope of your port’s EMS (including entities over which 

the port exercises control/significant influence), in Element 2 you wrote your port’s 

environmental policy (including commitments for continual improvement and prevention 

of pollution and waste), and in Element 3 you made sure to identify all relevant legal 

and other requirements – at the federal, regional, state, and local levels. In Element 4, 

you use all that information as guideposts to (1) identify environmental aspects (EAs) 

of operations that fall within the scope of the port’s EMS; (2) list their actual or potential 

environmental impacts (EIs), quantified to the extent possible; and (3) determine the subset of aspects 

that have significant impacts. 

• EAs are characteristics of a facility’s activities, products, or services that either impact the 

environment or could potentially impact the environment. These impacts could occur during normal, 

abnormal, accidental, or emergency situations. 

• Air emissions from a tug boat are an example of Categories Commonly Used to Determine 

an EA, with the impact being degradation of air Significance of EAs 

quality. Similarly, spills from chemical storage • Regulatory concerns 

facilities are also an EA, with the impact being • Pollution 

degradation of air or water quality. Such EAs • Risk, including: effects of chemicals & materials 

may also be significant environmental on workers, impacts on the surrounding

aspects (SEAs) due to legal requirements, port community, and impacts on the environment, 

goals or policies, community concerns, potential safety, and noise 

release to the environment, pollution prevention • Natural resource use 

potential, or other rationale. Once selected, 

SEAs form the basis for the rest of the EMS. 

Element 4 in the Field 

Many ports have catalogued their EAs (e.g., by diagramming their inputs, outputs, or processes), 

determined associated EIs, developed and applied significance determination methods using a variety of 

ranking criteria, and selected SEAs on which to target their EMS. Prioritizing their EAs has helped port 

management focus on controlling those aspects that have the greatest current or potential negative 

impact on human health and the environment. For example, many U.S. ports are in counties that are in 

non-compliance with air quality standards for ozone and particulate matter (PM). For those ports, and 

others that want to be proactive, diesel emissions from both ships and landside sources are likely an 

SEA. 

Common aspects and impacts within typical marine transportation fencelines (e.g., marine terminals and 

maintenance shops) address not only air quality, but also impacts on land and water quality from ships 

and shore-side operations. Typical activities within the fenceline may include electrical repair, building 

maintenance, painting, boat building/repair, truck and fleet maintenance, fueling operations, waste 

disposal, recycling, snow removal, wharf repair, plumbing, pavement repair, equipment maintenance, 

roofing, landscape maintenance, property renovation, and storm water management. 

Interim Final Draft, April 2007 15 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

For example, after selecting its wellhead protection area as its fence line, key operations and 

maintenance staff at the Port of Vancouver brainstormed activities that occur within this area and ranked 

those individual activities according to the following factors to determine the level of perceived impact: 

• Human health; 

• Natural resources; 

• Frequency; 

• Volume; 

• Toxicity; 

Following this ranking the port selected the 

following SEAs: 

• Proximity of existing contamination to 

wellhead area; 

• Illegal dumping within wellhead area; 

• Tenant chemical use; 

• Proximity of rail tracks (and potential for 

spills and leaks); 

• Chlorine transportation, storage, and 

changing tanks; 

• Public perception; 

• Costs; 

• Probability; and 

• Legal requirements. 

“Our port’s EMS is helping us identify and prioritize 

environmental issues, especially those with the greatest 

impact. It is also helping us document procedures and stay 

on top of every regulation out there.” — Gary P. LaGrange, 

President & CEO, Port of New Orleans 

Source: EPA, AAPA, & GETF. Environmental Management 

Systems: Systematically Improving Your Performance: Ports 

Sector, September 2004. 

• Installation of backflow prevention devices; and 

• Drinking water operational procedures. 

Massport, which operates the Port of Boston as well as major airports, bridges, and commercial areas, 

identified the following activities that could impact the environment and were deemed to be significant or 

occur at all Massport facilities: 

• Vehicle/equipment maintenance; • Building maintenance; 

• Administrative activities; • Civil/site construction; 

• Landscaping; • Deicing; and 

• Snow removal; • Oil/water separator maintenance. 

• Pavement maintenance; 

Massport then identified the following environmental aspects of those activities: 

• Fluids; • Runoff and wastewater; 

• Parts; • Concrete; 

• Electricity; • Noise; 

• Water; • Fuel for HVAC; 

• Hazardous and solid waste disposal; • Miscellaneous materials; 

• Paper and office supplies/equipment; • Topsoil/fill; 

• Pesticides/herbicides; • Construction debris; 

• Fuel for vehicles; • Dust; 

• Salt/sand runoff; • Contaminated soil; 

• Vehicle emissions; • Chemical deicer and runoff from deicer; and 

• Snow melter water discharge, • Stormwater discharge.31 

• Sedimentation, 

31 From 1st Ports EMS/SMS Assistant Project, Final Report,. May 2006. 

Interim Final Draft, April 2007 16 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Massport then identified the following potential environmental impacts: 

• Resources for maintenance fluids and parts; • Resources for paper and office supplies; and 

• Resources for electricity; • Pesticide/herbicide disposal.32 

• Water use; 

• Land for hazardous and solid waste disposal; 

Some examples of environmental aspects and impacts the Port of Brisbane, Australia, identified in its 

audit of all work sites and activities include the following:33 

Environmental Aspect Environmental Impact 

Hosing down the deck of a vessel resulting in the 

discharge of sediments, oils and greases into the 

waterway 

Contamination of the waterway through increased turbidity 

and contaminants 

Spills of fuels and oils from parked vehicles entering the 

waterway or paved areas through stormwater flows 

Contamination of the soil, groundwater, and surface 

waters 

Purchase of materials and equipment without due 

consideration for environmental sustainability (i.e., 

excessive packaging, hazardous waste by-products, 

excessive noise generation) 

Depletion and inappropriate use of natural resources 

Enhancements for Sustainability 

Environmental aspects and their indicators may cover universally accepted performance related to inputs 

(e.g., materials, energy, water) and outputs (e.g., emissions, effluents, and waste), as well as 

performance related to biodiversity, environmental compliance, environmental expenditures, transport, 

and the impacts of products or services. 

For example, the Gijón Port Authority, Spain, participated in a 2006 research study assessing the port’s 

“ecological footprint” as a macroindicator of sustainability.34 Until that time, this macroindicator had been 

applied to cities, regions, or countries, but not entities such as ports. Ecological footprints account for the 

consumption of natural resources by converting them into hectares (ha) of “nature” or consumed 

productive land. Parameters analyzed included consumption of energy, fuel, material, paper, wood, 

water, built land, and green areas, and residues generated by the port. The results showed a net 

ecological footprint of 3,279.84 ha, comprising primarily construction works and electricity usage. Studies 

of this kind may enable ports to design sustainable development plans to reduce consumption as well as 

develop green services and create “natural capital,” as the scope of impact is better understood. 

The Port of Portland developed and implemented a natural resources assessment and management plan 

(NRAMP), a management and planning tool that provides port staff with a single source of all natural 

resource data (including inventories and maps) about port and surrounding properties. In addition, 

NRAMP contains modeling, alternatives analysis, monitoring, and adaptive management features that 

allow port staff to evaluate the potential effects of management actions on the resources.35 

32 Massachusetts Port Authority Sustainability Plan, October 2004; www.mass.gov/envir/Sustainable/ 

pdf/massport_sustainability_plan.pdf, accessed March 28, 2007. 

33 See www.portbris.com/au, accessed March 30, 2007. 

34 See abstract on second to last link on the following web page: www.pubsindex.trb.org/document/view/ 

multi.asp?pub=1&recordlist=792675%7C, accessed March 30, 2007. 

35 See AAPA award to this port at www.aapa-ports.org/Programs/content.cfm?ItemNumber= 

748&navItemNumber=696; accessed April 2, 2007. 

Interim Final Draft, April 2007 17 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Other broader aspects of sustainability may 

also already be captured through an EMS. For 

example, social aspects, such as occupational 

health and safety, training and education, 

security practices, community 

relations/involvement, and compliance, may be 

addressed within an EMS (e.g., through 

Element 2, Environmental Policy Statement, or 

through subsequent elements). 

Under the Global Reporting Initiative Framework,

Sustainability Common Denominators Include the 

Following Economic & Social Aspects or Indicators:

Economic: 

• Flow of capital among different stakeholders 

• Main economic impacts of the organization 

throughout society (e.g., economic performance, 

market presence, indirect economic impacts) 

Social: Labor Practices & Decent Work 

• Employment 

• Labor/management relations 

• Occupational health & safety 

• Training & education 

• Diversity & equal opportunity 

Social: Human Rights 

• Investment & procurement practices 

• Non-discrimination 

• Freedom of association & collective bargaining 

• Complaints & grievance practices 

• Security practices 

Social: Society 

• Community 

• Corruption 

• Public policy 

• Anti-competitive behavior 

• Compliance 

Social: Product Responsibility 

• Customer health & safety 

• Customer privacy 

• Compliance 

Source: Global Reporting Initiative website, 

http://www.globalreporting.org/ReportingFramework/G3O 

nline/PerformanceIndicators/, accessed April 20, 2007. 

Interim Final Draft, April 2007 18 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Element 5: Establish Objectives, Targets, and Action Plans 

Once you have identified your SEAs, you are also ready to set environmental objectives 

and targets. Objectives and targets help your port continuously improve its 

environmental performance. An environmental objective is an overall environmental 

goal arising from your port’s environmental policy statement (Element 2). Environmental 

targets are detailed performance requirements that are based on an environmental 

objective and are quantified whenever practicable. While all SEAs need operational 

controls, not all need objectives and targets. In setting objectives and targets, the port 

should consider its environmental policy commitments to 

prevent non-compliance, prevent pollution at its source, In Setting Objectives & Targets, Keep Your 

minimize cross-media pollutant transfers, and Environmental Policy Commitments in Mind 

continuously improve its environmental performance. While Also Considering the Following 

Factors: 

Action plans document SEAs, operational controls, • SEAs

objectives, and targets. Action plans, also known as • Legal and other requirements 

Environmental Management Plans (EMPs) or • Statewide environmental initiatives 

Implementation Plans, translate your policy • External trends & influences 

commitments into concrete actions – they form the • Stakeholder concerns/views 

bridge between concept and application. EMPs should • Business/operational needs & financial 

define: (1) the responsibilities for achieving the concerns 

objectives (i.e., who will do it?); (2) the means for • Organizational considerations 

achieving objectives (i.e., how will they do it?); and (3) • Technological options 

the timeframe for achieving the objectives (i.e., when?). • Port’s ability to control, track, & measure 

Keep in mind that EMPs should be dynamic. For • Cost to track & measure 

example, consider modifying your programs when • Progress reporting 

objectives and targets are modified or added; relevant

legal requirements are introduced or changed; 

substantial progress in achieving your objectives and targets has been made (or has not been made); 

your services, processes, or facilities change; or other issues arise.

Considerations for Developing Objectives and Targets 

Environmental 

Policy 

Significant 

Environmental 

Aspects 

Legal/Other 

Requirements 

Views of 

Interested 

Parties 

Objectives 

& Targets 

Technological 

Options 

Financial 

Considerations 

Operational 

Considerations 

Other 

Organizational 

Considerations 

Environmental 

Management 

Program(s) 

Potential for 

Pollution 

Prevention 

Interim Final Draft, April 2007 19 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Element 5 in the Field 

Targeting their SEAs and considering other factors, ports have developed general objectives (e.g., 

minimize impacts to air quality, minimize impacts to water resources, reduce waste generation and 

hazardous materials use, minimize impacts and seek opportunities to enhance natural resource, reduce 

energy consumption, purchase energy from sustainable sources) as well as detailed, specific targets. 

Three examples are provided below from the 1st Ports EMS/SMS Assistance Project. 

The Port of New York and New Jersey selected public berthing areas, maintenance facilities, and 

dredging operations as its fenceline; identified 10 SEAs within the fenceline; developed operational 

controls for all 10 (see Element 6); and set objectives and targets for 3: 

1. Reduce water loss at the Public Berthing facilities in NY and NJ in volume and cost by 20% by 

December 2006. Due to the nature of the water distribution system configuration at NJ Marine 

Terminal, the scope of this effort was expanded to cover the entire NJ facility. 

2. Reduce solid waste from fender system repairs at the public berthing facilities in NY and NJ by 25% 

by May 2007 by specifying the use of more structurally resilient material and recycling old fenders. 

3. Reduce NOx emissions from dredging operations for the Harbor Deepening Project to a net zero on 

an annual basis starting June 2005 and ending by December 2014. 

The Port of Portland, which selected two facilities for its fenceline – Marine Facility Management (MFM) 

and Portland International Airport (PDX) General Maintenance – established the following objectives and 

targets for 2004/2005 maintenance operations: 

1. Objective: Minimize Impacts to Air Quality. Targets: Reduce idling/transaction time by 50% at PDX 

parking toll plaza by June 2005; take five actions by June 2005 to reduce diesel particulate 

emissions; and identify air quality improvements through energy source changes for PDX gate & 

ground service equipment by completing preliminary engineering & economic evaluations by June 

2005. 

2. Objective: Minimize Impacts to Water Resources. Targets: Complete water efficiency evaluations for 

three port water systems by June 2005; and reduce the amount of treated timber chocks at T6 

container yard by 20% by June 2005. 

3. Objective: Reduce Waste Generation and Hazardous Materials Use. Targets: Assess environmental 

and safety impacts of chemical products used at Aviation and Marine maintenance facilities and 

eliminate or substitute at least six products at PDX by June 2005 and another six at MFM by March 

2006. 

4. Objective: Minimize Impacts and Seek Opportunities to Enhance Natural Resources. Targets: 

Organize a weekend event for Port staff to clean up Port-owned shorelines by June 2005. 

5. Objective: Reduce Energy Consumption. Targets: Evaluate new technology to determine financial 

and technical viability and of the Eco-start motor energy controller [placeholder target until evaluation 

is completed]; and conduct three building energy audits at port facilities and implement viable projects 

by June 2005. 

6. Objective: Purchase Electric Energy from Sustainable Sources. Targets: Purchase 3% of PDX’s, 5% 

of Marine’s, and 5% of the Port Building’s electric power from sustainable wind-generated sources in 

2004/2005. 

The Port of Virginia identified 45 SEAs and then chose to address its remote fueling operations, 

corrective and preventive maintenance processes, container/strad wash area operations, and the 

facilities’ lighting replacement program at Norfolk International Terminals (its fenceline) as follows: 

1. Objective: Reduce potential for fuel spills from remote fueling operations. Target: Upgrade remote 

fueling equipment and implement procedures with the target of reducing spill frequency by 10%. 

2. Objective: Reduce use of energy inefficient F-40 lamps and magnetic ballasts in office areas. Target: 

Replace 75% of all F-40 light fixtures with T-8 fixtures by 2007. 

3. Objective: Establish methods to decrease the waste products from performing corrective and 

preventive maintenance and to ensure these by-products are properly disposed of or recycled. 

Interim Final Draft, April 2007 20 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Target: Benchmark the amount of recyclable waste and develop goals that will increase recycling 

efforts by June 2006. 

4. Objective: Reduce the zinc level in waste water from container and straddle carrier wash down 

operations. Target: Reduce the monthly sampled zinc levels in the waste water stream by 25% from 

calendar year 2005 average level at the Container and Straddle Carrier Wash Area by December 

2006. 

Enhancements for Sustainability 

In developing its Green Port Policy, the Port of Long Beach conducted a gap analysis to document what it 

was doing as well as what more it needed to do, and then used that information to set objectives and 

targets. The resulting Green Port Policy includes six basic program elements (four specific environmental 

elements as well as broader social and overarching sustainability elements), each with an overall goal: 

• Wildlife – Protect, maintain or restore aquatic ecosystems and marine habitats; 

• Air – Reduce harmful air emissions from Port activities; 

• Water – Improve the quality of Long Beach Harbor waters; 

• Soils/Sediments – Remove, treat, or render suitable for beneficial reuse contaminated soils and 

sediments in the Harbor District; 

• Community Engagement – Interact with and educate the community regarding Port operations and 

environmental programs; and 

• Sustainability – Implement sustainable practices in design and construction, operations, and 

administrative practices throughout the Port. 

In addition to overall principles and the goals for each component, the policy includes metrics (scientific 

measurements of the port’s environmental progress), and a commitment to regular reporting. The port 

has been developing metrics for various elements; those that have been developed are presented in 

periodic updates as well as the 2005 Green Port Annual report.36 Note that the port has not developed 

numerical goals or metrics for either community engagement or sustainability; rather, progress on those 

two elements is reported as it occurs. 

Massport has also developed Sustainable Design goals that address: 

• Asset Management – Increase value and revenue generating potential of projects, demonstrating to 

developers/investors that port is a competent partner; 

• Environmental Benefits/Permitting Strategy – Reduced impacts and permitting time; 

• Citizenship – Positive community impact by demonstrating that port is actively reducing 

environmental impacts; and 

• Design Excellence – Innovative, aesthetic and responsible design.37 

In 2006, Massport achieved LEED Certification for the world’s first LEED-certified airport terminal, Boston 

Logan International Airport’s Terminal A.38 The Leadership in Energy and Environmental Design Green 

Building Rating SystemTM is the nationally accepted benchmark for the design, construction, and 

operation of high performance green buildings. 

36 See www.polb.com/about/publications/green_port_annual.asp, accessed March 28, 2007. 

37 Why Build Green? ACI-NA Environmental Affairs Committee Meeting, May 15, 2005; www.acina.org/docs/41%20SAN%2005%20Catherine%20Wetherell%20Massport%20LEED.pdf; accessed March 28, 2007. 

38 See www.massport.com/about/press_news_taleed.html, accessed March 28, 2007. 

Interim Final Draft, April 2007 21 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Element 6: Develop Operational Controls 

Operational controls are 

documented procedures, 

work instructions, BMPs, 

posted placards, and action 

plans that ensure that 

operations and activities 

(such as wastewater 

discharge monitoring, waste management, and 

environmental performance improvement) are 

carried out effectively. At least one operational 

control should be in place for each SEA 

identified in Element 4 to ensure compliance 

with legal requirements and company policies 

or to achieve improvement objectives. 

Element 6 in the Field 

Ports may already document most of the 

operational controls needed at the facility, so it 

is likely you would not have to start from 

scratch. Ports that have implemented EMSs 

have documented operational controls to 

address compliance assurance and 

environmental improvement objectives. The 

following examples are from the 1st Ports 

EMS/SMS Assistance Project. 

• The Port of Los Angeles, for example, 

developed operational controls as part of 

its EMS, establishing standard operating 

procedures (SOPs) for SEAs. 

Sample Activity Areas & 

Operational Controls for a Port 

Water quality management: 

• Connect floor drains to sanitary sewer or dead-end 

sump. 

• Provide adequate space for storage of chemicals and 

waste products. 

• Provide oil/water separators on floor drains. 

• Pave fueling areas with concrete rather than asphalt. 

• Design fueling areas to prevent the run-on of storm 

water and the runoff of spills. 

• Use sand filters to capture spills and runoff of paint 

stripping operations. 

• Ensure adequate secondary containment for 

catastrophic failures of bulk liquid storage facilities. 

Air quality management: 

• Install and maintain vapor recovery systems for 

fueling operations and for storage and handling of 

bulk liquids. 

• Install dust suppression mechanisms for dry bulk 

storage and handling activities. 

• Provide paint booths to contain overspray and treat 

air emissions when painting equipment. 

• Cover painting/stripping area. 

• Minimize the quantity of soil exposed at one time 

during construction activities. 

Source: AAPA. Environmental Management Handbook. 

September 1998. http://www.aapaports.org/Issues/content.cfm?ItemNumber=989. 

Documenting these operational controls promoted “buy-in” from all employees into the EMS, 

ownership from employees of the significant activities, transfer of institutional knowledge from longtime staff to new employees, and assurance that all shifts conduct the activities under SOPs. 

• The Port of Vancouver also saved operator institutional knowledge by clearly documenting through its 

EMS procedures for drinking water system operation and compliance management. Formalizing 

previously informal processes ensures that institutional knowledge of long-time port employees is 

captured. 

There are a number of ways that ports can ensure that operational controls are implemented by those 

with whom the port does business. 

• The Port of Houston Authority is putting environmental performance expectations for air emissions in 

construction contracts and in tariffs with stevedores. The port also has documented “roll down” 

clauses in its contracts; if tenants, vendors, or contractors cause a notice of violation (NOV), they may 

be fined or fired by the port. 

• The Port of Seattle has a memorandum of agreement (MOA) with the cruise industry, which is now 

using low-sulfur fuel and shore-side electric power for cruise ship auxiliary power needs at dock. 

• The Ports of Los Angeles and Long Beach have supplemented the requirements in their tenant 

leases. While it is common practice for ports to articulate in their leases that their tenants must 

Interim Final Draft, April 2007 22 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

comply with applicable environmental laws “Morale is high. When we presented the EMS initiative to 

and regulations, these two ports have used our maintenance and facility personnel, we stressed that 

additional “green lease” language with the suits are not coming down and telling you what to do. 

some of their marine terminal tenants. We all work side-by-side, and when we start identifying 

These ports are in a position to do this procedures, everyone is involved in the process.” — Rick 

because of the scarcity of highly desirable Larrabee, Director, Port Commerce Department, Port 

land available for marine terminals in the Authority of New York & New Jersey

country’s busiest import market, and 

because of severe air pollution and Source: EPA, AAPA & GETF. Environmental 

Management Systems: Systematically Improving your extreme pressure from regulators and Performance: Ports Sector, September 2004. other stakeholders to reduce the human 

health risk of port-related operations.39 The 

lease agreement signed by the Port of Los Angeles and P&O Nedlloyd in January 2006 requires that 

the following operational controls be used: 

o Switch to low sulfur (1.5% or less) fuel in main and auxiliary engines of container ships when 40 

nautical miles of the port; 

o Reduce vessel speed when within 40 nautical miles of the port; 

o Outfit ships for Alternative Marine Power (AMP), i.e., ship to shore-side power – 30% by the end 

of the 2nd year, 70% by the end of the 3rd year; 

o Use alternative fuel, e.g., liquefied natural gas (LNG), in yard tractors; 

o Use emulsified fuel and Diesel Oxidations Catalysts (DOC) on older yard equipment, where 

feasible; 

o Use on/near dock rail; 

o Use non-ozone depleting compounds in refrigerated containers; and 

o Use housekeeping/maintenance procedures that limit water use and minimize discharges.40 

Enhancements for Sustainability 

Operational controls extend to other sustainability measures, including community relations. For example, 

reporting a release or oil spill to the federal, state, or local government (see Element 7) entails following 

documented procedures. A port may also develop BMPs to convey such information to the public as well 

as crisis communication plans to address media inquiries (see Element 9).41 

39 For further information, see the San Pedro Bay Port Clean Air Action Plan, the most comprehensive strategy 

to cut air pollution and reduce health risks ever produced for a global seaport complex; 

www.portoflosangeles.org/environment_air.htm. 

40 Port of Los Angeles press release entitled, Port of Los Angeles Harbor Commissioners Certify Environmental 

Impact Report with Landmark Environmental Measures, dated January 19, 2006, 

http://www.portoflosangeles.org/Press/REL_BHC%20Approves%20206-209%20EIR.pdf, accessed April 25, 2007. 

41 See www.aapa-ports.org/search/browseResults.cfm?MetaDataID=27 for several presentations on 

communications and the media; AAPA’s 2006 seminars. The Port Manatee Crisis Communications Plan is also 

provided as a best practice manual on AAPA’s web site; see www.aapa-ports.org/Issues/ 

IssueDetail.cfm?itemnumber=1146. Both sites accessed March 28, 2007. 

Interim Final Draft, April 2007 23 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Element 7: Develop Emergency Preparedness and Response 

Program 

Despite a port’s best efforts, accidents and other emergency situations may occur. 

Effective preparation and response can reduce injuries, prevent or minimize 

environmental impacts, protect employees, and neighbors, reduce asset loss, and 

minimize downtown. An effective emergency preparedness and response program 

(EP&R) should include provisions for (1) assessing the potential for accidents and 

emergences; (2) preventing incidents and their associated EIs; (3) responding to 

incidents through emergency plans and procedures; (4) testing of emergency plans and 

procedures periodically; and (5) mitigating impacts associated with accidents and emergencies. Like 

Element 6, Operational Controls, this is another area where you should not have to start from scratch, 

since several environmental, health & safety (EH&S) regulatory programs require emergency plans 

and/or procedures, for example: 

• Clean Air Act Amendments: Risk Management Program; 

• Clean Water Act: Spill Prevention, Control and Countermeasure Plan (SPCC) and Storm Water 

Pollution Prevention Plans; 

• Emergency Planning and Community Right-to-Know Act: Community Right-to-Know Reporting and 

Coordination with Local and State Emergency Response Committees; 

• Oil Pollution Act: Facility Response Plan (portions of port not subject to USCG contingency plan 

requirements) and SPCC; 

• Resource Conservation and Recovery Act: Contingency Plan (for large quantity generators) and 

Preparedness and Prevention Plans (for large quantity and small quantity generators); and 

• USCG: Facility Response Plan (FRP). 

The Occupational Safety and Health Act also requires Process Safety Management controls. 

Element 7 in the Field 

Some ports address these numerous EH&S requirements through Integrated Contingency Plans (ICPs), 

which combine the requirements of numerous regulatory programs into one plan. The federal government 

has issued guidance for such a plan, known as the “One Plan.” To access information on the One Plan, 

use the following website link to EPA – http://yosemite.epa.gov/oswer/ceppoweb.nsf/content/sta-loc.htm – 

and scroll down to the section entitled: "The National Response Team's Integrated Contingency Plan 

Guidance (One Plan)." 

Enhancements for Sustainability 

Following up on enhancements noted in Element 3, Legal Requirements, and FRP requirements noted 

above, ports should be in compliance with new USCG security regulations, which are in place to protect 

commerce, port assets, and personnel. The federal government is also funding other port security and 

supply chain pilot programs. For example, the Ports of Seattle and Tacoma, the Port Authority of New 

York and New Jersey, and the Ports of Los Angeles and Long Beach are leaders in Operation Safe 

Commerce, a federal program designed to create the knowledge base required for international 

standards for containerized shipping. 

Regarding lessons learned in recovering economically from natural disasters, including keeping the 

community informed:42 

42 See www.aapa-ports.org/search/browseResults.cfm?MetaDataID=27 for several presentations on lessons 

learned regarding emergency management, disaster recovery, and security; AAPA’s 2006 seminars; accessed March 

27, 2007. 

Interim Final Draft, April 2007 24 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

• Ports have developed business Continuity of Operations (COOP) plans – advance procedures that 

allow critical business functions to continue during a disaster.43 

• Following Hurricane Katrina, however, the Port of New Orleans noted its comprehensive Hurricane 

Preparedness Plan simply could not envision the extent of the storm’s aftermath, which affected 

96,000 square miles – an area larger than the British Isles.44 The plan, for example, provided for (1) 

preparation and clean up, but not how to provide housing for employees; (2) communications network 

based on cell phones, but no provisions for 300 cell towers being destroyed; and (3) short evacuation, 

but not for extended evacuation of 90 days or more. Following Katrina port staff improvised by: 

o Establishing two headquarters: an operational headquarters in New Orleans staffed by key 

personnel led by President & CEO Gary LaGrange, as well as an administrative headquarters in 

Atlanta led by COO Dave Wagner – eventually moved to Ponchatoula, LA, courtesy of Port 

Manchac; 

o Establishing lines of communication with key senior staff; 

o Remotely accessing main frame computers; and 

o Arranged housing through MARAD. 

The port summarized its lessons learned as follows: 

o Chain of Command – Know where staff are, provide for multi-tasking; 

o Communications – Establish guidelines for worst case scenarios; 

o Lines of Responsibility – Back up chains for major catastrophes; 

o Housing – Establish temporary quarters; 

o FEMA – As a partner rather than a leader; and 

o Media Relations – Be accessible, be positive, and lead the way. 

• Shortly after the devastating hurricanes of 2005, AAPA convened a working group that sponsored five 

workshops over six months to collect member experiences with emergency planning and disaster 

recovery. With the information gathered from these workshops, AAPA has developed an emergency 

preparedness and COOP planning manual for its members.45 

43 See, for example, “Business Continuity Port Operations,” Cosmo Perrone, Director of Security, Port of Long 

Beach, presentation at 2006 AAPA Emergency Preparation and Response Seminar, www.aapa.files.cmsplus.com/SeminarPresentations/06%5FEmergency%5FPerrone.pdf, accessed March 28, 2007. 

44 “Crisis Management and How Hurricane Katrina Changed the Dynamics”, J. Robert Jumonville, Sr., Director 

of Cruise and Tourism, Port of New Orleans, presentation at AAPA 2006 Cruise Seminar, www.aapa.files.cmsplus.com/SeminarPresentations/06%5FCruise%5FJumonville.pdf, accessed March 28, 2007. 

45 AAPA, Emergency Preparedness and Continuity of Operations Planning Manual for Best Practices, 

http://www.aapa-ports.org/Issues/IssueDetail.cfm?itemnumber=1161; accessed March 27, 2007. 

Interim Final Draft, April 2007 25 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Element 8: Set Up a Training Program for Competence and 

Awareness 

Each person and function within a port can play a role in environmental management. 

Employees, tenants, and managers should be aware of the environmental policy, the 

SEAs and related procedures that apply to their work, key EMS roles and 

responsibilities, and the importance of meeting EMS requirements. Employees also 

should understand what might happen if they don’t meet EMS requirements, such as 

spills, releases, and fines or other penalties. 

All employees will require environmental Examples of Areas Where Training is Needed 

awareness training that covers an introduction to 

EMSs, the port’s environmental policy, SEAs and • Legal and other requirements 

environmental goals. Employees whose jobs are • Ability to recognize new problems 

associated with SEAs will also require appropriate • Technical skills needed to solve problems 

task-specific training and support to be competent • Procedures to implement operational controls 

in their work. Training is just one element of • Any new procedures or needs related to SEAs 

establishing competence, which is typically based on • Awareness of the port’s environmental policy, 

a combination of education, training, and experience. EMS, and objectives 

Element 8 in the Field 

Improved environmental awareness on the part of employees, as well as tenants and other contractors, is 

a benefit of EMS programs. Unless otherwise noted, the following examples are from 1st Port EMS/SMS 

Assistance Project. 

• The Port of Los Angeles conducted EMS General 

Awareness training sessions, which increased 

communication of environmental issues and, in turn, 

broadened port-wide awareness of issues within the 

fenceline. Its EMS Internal Auditor training also reinforced 

the concept that the results of internal audits drive the 

continual improvement of an EMS and, as a result, 

improve environmental performance. 

• The Port of Houston conducts environmental training for its 

tenants twice per year. These sessions started out as 

awareness training, but as the knowledge level of the 

tenants has increased, the training has become more 

detailed and now focuses on changes or potential changes 

the port will arrange training on those topics.46 

• The Port of Corpus Christi conducts extensive environmental training for its employees and places 

posters and brochures in areas where employees will see them. The port has customized its training 

by type of employee and has also developed wallet-sized cards that list significant aspects for each 

job (e.g., painting crew, welding crew, mechanic).47 

46 Phone conversation with Aston A. Hinds, Environmental Affairs Manager, Port of Houston Authority, April 20, 

2007. 

47 Phone conversation with Sarah Kowalski, Environmental Compliance Manager, Port of Corpus Christi 

Authority, April 20, 2007. 

to applicable regulations. If the port’s tenant audit program identifies any widespread weaknesses, 

Interim Final Draft, April 2007 26 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

• Under its voluntary Green Ports Tenant Environmental Awareness Program, the Port Authority of 

New York and New Jersey developed and presented an environmental awareness program for the 

port’s Seaport tenant community. This program, free of charge to tenants, presented a 

comprehensive review of environmental aspects affecting tenant business operations including legal 

regulatory requirements, BMPs, pollution prevention, “green” design and construction, permitting 

requirements, and grants and financial incentives.

48 

Enhancements for Sustainability 

Ports are beginning to look more broadly at sustainability training. For example, the Port of Long Beach 

has developed a sustainability training DVD for employees at the port. Ports may include LEED 

certification in their sustainability training. As previously noted in Element 5, Massport is actively pursuing 

LEED certification for many of its green building efforts. 

AAPA itself has already started providing training on sustainability for its members. For example, a 

session on port sustainability was offered at the June 2006 meeting of AAPA’s Harbors, Navigation, and 

Environment Committee.49 

48 See AAPA award to the port at www.aapaports.org/Programs/content.cfm?ItemNumber=748&navItemNumber=696; accessed April 2, 2007. 

49 The presentations from this session can be downloaded from the AAPA website. Please visit: 

http://www.aapa-ports.org/Programs/PastDetail.cfm?itemnumber=954. 

Interim Final Draft, April 2007 27 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Element 9: Create a Communications Strategy 

An EMS should define the process for proactive, two-way, internal and external 

communication. 

Internal communication should provide information about environmental requirements 

and voluntary commitments to all employees, on-site service providers, and contractors 

whose work could affect your ability to meet those requirements and commitments. 

External communication should provide information on your environmental programs and 

accomplishments to other stakeholders and include a way to provide feedback. Stakeholders include 

anyone who has a stake in your facility’s environmental performance. 

You may appoint a community liaison to Internal Stakeholders Include: Employees, manage external communications concerning shareholders, customers, suppliers, investors & insurers, EAs at your facility, for example, responding to trading partners, etc. 

inquiries from interested parties and regulatory 

agencies; sending current copies of the External Stakeholders Include: Neighbors, community

environmental policy to interested parties, and organizations, environmental groups, other external 

responding to media inquiries. companies, the media, the general public, etc. 

Element 9 in the Field 

Through communications programs, ports are able to convey their EMS policy, objectives, targets, and 

progress to date. EMS improves cross-functional communications and cooperation. The following 

examples are from the 1st Ports Ems/SMS Assistance Project: 

• EMS Core Team meetings at the Port of Los Angeles and Port of Portland, for example, created a 

forum where employees from different divisions could come together to discuss specific 

environmental topics. Use of these forums increased the ports’ communications on environmental 

issues and, in turn, broadened awareness of port-wide issues throughout the fenceline. 

• Creation of the EMS at Los Angeles also “Because a residential area abuts our port, outreach to 

included a Continual Improvement Form the surrounding community is a priority. At Massport, we 

(CIF) that was widely distributed throughout strive to be good corporate citizens as well as good 

the facility and continues to be available for neighbors. Informing the local community about various 

all employees. This form has acted as a Massport programs and initiatives at our facilities helps 

communications tool for employees to us to accomplish this. Our efforts to implement more 

identify and record environmental concerns sound environmental policies, such as those outlined in 

as they are observed, and for management the EMS, are certainly appreciated and in this case 

to respond to issues identified. applauded.” — Michael A. Leone, Port Director, Massport 

Source: EPA, AAPA & GETF. Environmental • The Port of Vancouver increased staff, Management Systems: Systematically Improving your 

tenant, and contractor awareness of Performance: Ports Sector, September 2004. 

potential impacts to its wellhead protection 

area (its fenceline) by preparing voluntary 

drinking water quality confidence reports for tenants and other water users, installing wellhead 

signage, and creating an Automotive Hazardous Waste Disposal Flyer for tenants. 

Enhancements for Sustainability 

Some ports are expanding their community relations as part of their ongoing EMS programs. 

• Massport’s approach to sustainability includes a goal of developing an EMS for each facility. These 

EMS projects are showing Massport’s leadership and corporate citizenship by going beyond 1-way 

Interim Final Draft, April 2007 28 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

public relations to 2-way dialogues. “By 

pledging our commitment to public service 

leadership, we accept Massport’s obligation 

to serve multiple stakeholders, each of 

whom should be considered in the 

development of our policies and our day-today decision-making. We acknowledge that 

only through open communication and with 

an open mind, weighing equally all sides of 

an issue, can we find resolutions that will 

benefit the greater public good.”50 

• Other ports, such as the Port of Long 

Beach, are looking at a tiered approach to 

sustainability communications – first looking 

within their organization (i.e., at their 

employees, over whom they have direct 

control (see discussion of scope in Element 

1)), and then developing a strategy to 

involve tenants and the broader community. 

• The Port of Brisbane, Australia, developed a 

Community Consultative Committee, which 

comprises representatives from 

What Communities Sometimes Fear

Or Don’t Like About Ports

• Air & water pollution, & potential health effects 

• Road congestion 

• Destruction of wetlands, habitat 

• Land contamination, including brownfields 

• Noise during construction & operation 

• Night lighting & glare 

• Dust 

• Visual impacts (e.g., “ugly” cranes, bright lights) 

• Competition with recreational uses of water/land 

• Disturbance of cultural resources 

What Communities Want From Ports 

(Besides Jobs & Goods) 

• A say in decisions that affect their lives 

• A transparent decision-making process, especially 

for new projects 

• Monitoring & reporting on environmental issues, 

e.g., ambient air & water quality monitoring 

• Objectives/targets for continuous improvement in 

environmental performance 

conservation, business, and community groups with an interest in the port’s activities and its impact 

on neighboring communities. This committee provides a link to stakeholders and local communities 

through which the port raises awareness about its activities, development, and plans for the future. 

The committee meets quarterly.51 

As part of their external communication strategy to engage the community in decisions that affect them, 

ports can become attuned to operational improvements that, while seemingly minor, make a large, 

positive difference to the surrounding community. 

• To minimize noise pollution, some ports have been able to reduce the backup alert beeper on trucks 

and equipment to a level that ensures safety while also reducing decibels. 

• To reduce their visual impacts, ports have painted their cranes blue or gray so they blend better in 

with the sky and water; others have purchased cranes that can partially retract when not in use. 

• Fremantle Ports-Western Australia funded the planting of 4,805 trees over three years in the Lake 

Chinocup catchment area in the Great Southern. Not only are these trees visually pleasing, but also 

they offset the greenhouse gases emitted by the port’s vehicle fleet.52 

50 Massport Sustainability Plan, October 2004, www.mass.gov/envir/Sustainable/pdf/ 

massport_sustainability_plan.pdf, accessed March 28, 2007. 

51 See www.portbris.com.au/community, accessed March 30, 2007. 

52 See www.fremantleports.com.au/environmentsafety/index.asp, accessed March 30, 2007. 

Interim Final Draft, April 2007 29 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Element 10: Set Up Documentation for the EMS 

Documentation is a requirement of an EMS, but it should not be the main emphasis. 

Limit your documentation efforts to the minimum necessary. EMS documentation is 

different than EMS records. EMS documentation describes what you do and how you 

do it, while EMS records demonstrate that you are doing what the documentation said 

you would do. 

Some sort of EMS Manual, either electronic or hard copy, can be your EMS 

documentation and should: 

• Describe the core elements of your EMS Documentation Should Be Available for All EMS 

and how the elements interact; and Components, Including: 

• Provide direction to related documentation. 

• Environmental policy 

Element 10 in the Field • Organization chart or lists/tables of key 

responsibilities 

Record keeping and document management • Description of how the port satisfies the EMS 

improve port scheduling, tracking, and funding requirements 

projections, and establish a systematic record • System-level procedures (e.g., procedures for 

corrective & preventive action) for tracking environmental initiatives and • Activity- or process-specific operational controls 

developments. As noted in the 1st EMS/SMS (e.g., SOPs, work instructions) Assistance Project Final Report: • Other EMS-related documents (e.g., emergency 

preparedness & response plans, training plans) 

• Through its documented system, the 

Portland District-USACE has been able to Records You Might Maintain Include: 

share EMS information with other projects 

and USACE leadership. • Legal, regulatory, and other code requirements 

• Results of EA identification 

• The Port of Corpus Christi Authority’s EMS • Reports of progress towards meeting objectives & 

targets program has changed the way the Port • Permits, licenses, & other approvals 

manages its environmental affairs. • Job descriptions & performance evaluations 

Employees have seen the many benefits of • Training records 

the EMS program, including documented • EMS audits and regulatory compliance audit reports 

procedures, and are extending the • Reports of identified nonconformities, corrective 

consistent approach of the EMS program action plans, & corrective action tracking data 

beyond the EMS fenceline. • Hazardous materials spill/other incident reports 

• Communications with customers, suppliers, 

As part of the Ports EMS Assistance Project, contractors, & other external parties 

GETF conducted a neutral analysis of “off the • Results of management reviews 

shelf” software products specifically designed to • Sampling & monitoring data 

support an organization's development, • Maintenance records 

implementation, and subsequent management • Equipment calibration records 

of its EMS. Ports and other EMS implementers 

often seek such tools to efficiently manage EMS implementation and maintenance tasks, such as project 

scheduling and management, training and training records, documentation management, and internal 

auditing and corrective/preventative actions. The results of this 2004 assessment may be found at 

www.peercenter.net/ewebeditpro/items/O73F4044.pdf. 

53 EMS software packages can offer the following 

benefits to users: better communication between environmental and project staff at multiple installations; 

easy access to routine environmental and EMS documents and records; access to regulations and other 

requirements; enhanced management of permits, reporting, and compliance; database query, reporting, 

53 “EMS Software Comparison”, March 15, 2004, updated April 21, 2004, & June 23, 2004, accessed March 28, 

2007. 

Interim Final Draft, April 2007 30 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

and updating; document repositories; enhanced project management; e-mail based notification systems 

with escalation functions; calendar and EMS milestone and progress functions; EMS report generation 

tools; and information access security controls. 

Enhancements for Sustainability 

Strong documentation and records management should be part of any port’s BMPs. Documenting 

broader stewardship efforts in the areas of social responsibility and economic prosperity may require new 

procedures. Clearly, EMS tracking systems are optimized if they integrate with other management 

systems, such as a port’s financial tracking software. 

The recent San Pedro Bay Ports Clean Air Action Plan, approved November 20, 2006, by the Port of 

Long Beach and the Port of Los Angeles, sets a precedent for documentation.54 San Pedro Bay is 

currently in non-attainment with federal air quality standards, and without a comprehensive strategy would 

never reach attainment given projected growth in container freight through these two ports. The plan sets 

specific goals and targets, with documentation systems and report backs to stakeholders on all elements 

of plan implementation. Specific activities include: 

• A truck replacement program to phase out all “dirty” diesel trucks from the ports in five years, 

replaced with a new generation of clean or retrofitted vehicles and driven by people who earn at least 

the prevailing wage; 

• Aggressive milestones with measurable goals for air quality improvements; 

• Recommendations to eliminate emissions of ultra-fine particulates; 

• A technology advancement program to reduce greenhouse gases (GHG); and 

• A public participation process with environmental organizations and the business communities. 

54 For further information, see the San Pedro Bay Port Clean Air Action Plan, the most comprehensive strategy 

to cut air pollution and reduce health risks ever produced for a global seaport complex, visit: 

www.portoflosangeles.org/environment_air.htm. 

Interim Final Draft, April 2007 31 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Element 11: Monitor, Measure, Evaluate, and Record Performance 

Building on Element 4 where 

you identified SEAs, your port 

needs to know what it is 

monitoring and measuring and 

to have established a solid 

baseline against which to gauge process. Monitoring and measurement helps you to 

manage your port better by allowing you to measure environmental performance, 

analyze root causes of problems, and assess compliance with legal requirements. This element means 

that your port: 

• Monitors operations and activities that can have significant environmental impacts and/or compliance 

consequences; 

• Tracks performance (including your progress in achieving your goals); 

• Measures and reports on continuous improvement in environmental performance via the EMS; 

• Calibrates and maintains monitoring equipment; and 

• Periodically evaluates compliance with applicable laws and regulations through internal audits. 

Element 11 in the Field 

Ports that have implemented EMSs have Typical Performance Indicators 

reported substantial benefits through systematic 

monitoring and measurement programs. Management: 

• Training 

• Resource allocation Earlier in this primer, Element 5 provided • Purchasing objectives and targets for the Port of New York • Funding and New Jersey, including activities around Operational: 

water loss and reduced NOx emission. Adoption • Inputs (quantity of materials processed versus 

of an EMS generated the following quantifiable recycled, or energy or water used, etc.) 

benefits at the port: • Operation & maintenance 

• Emergency events & non-routing operations 

• In 2005, repaired several water leaks that • Outputs (e.g., waste, emission, noise, heat, light) 

reduced the average daily water loss by • Service provide by activity 

640,000 gallons and saved approximately Management/operations: 

$655,000 in cost at NJ Marine Terminals. • Safety (e.g., frequency of injuries, seriousness of 

These actions resulted in saving and injuries) 

conserving 134 million gallons of water • Customer delivery (e.g., complaints, targets met) 

• Production costs during 2005 and will contribute to 

substantial water savings for years to come. • Sales & price 

• Environment (e.g., Notices of Violations) 

• Human resources (e.g., training days/employee, • Signed an agreement with New York City turnover rates)

Department of Transportation to retrofit the • Financial performance (e.g., earnings before 

Staten Island Ferry Fleet and executed interest & taxes (EBIT), working capital) 

contracts in the Marine Vessel Engine 

Replacement Program that will achieve substantial air quality improvement. Reduction of NOx 

emissions resulting from these programs could exceed 400 tons per year and exceed that required to 

meet the General Conformity Requirements for the Harbor Deepening project. 

Other measurable benefits identified by ports that participated in the 1st Ports EMS/SMS Assistance 

Project include the following highlights:55 

55 1st Ports EMS/SMS Assistance Project, Final Report, May 2006. 

“What gets measured is what gets done. “ 

Tom Peters 

Interim Final Draft, April 2007 32 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

• Port of Virginia – Cargo handling equipment purchasing program reduced air emissions by 30% over 

3 year period; received AAPA award; 

• Port of Portland – Reduced vehicle idling at parking gates by 79%; purchased 5% of marine electric 

power from sustainable, wind-generating energy sources; and 

• Port of Corpus Christi Authority – Through its port-wide recycling program, saved $29K and diverted 

143K pounds of waste materials from entering the local landfill; received local environmental 

conservation and stewardship award. 

Ports have also conducted inventories to estimate emissions from mobile sources such as oceangoing 

vessels, harbor craft, cargo-handling equipment, locomotives, and on-highway vehicles.56 An inventory 

provides the baseline from which to create and implement emission mitigation strategies and track 

performance over time. Not all of the ports that have conducted these inventories have an EMS. 

However, the ports that do have EMSs in place will be able to systematically use the emissions data to 

develop, implement, and monitor emissions reduction strategies. 

Enhancements for Sustainability 

Environmental performance indicators are “Port Everglades operates in a sensitive environment flexible enough to address indicators of broader and in an area that is very dependent on tourist-related 

sustainability. dollars. We have to be environmentally proactive. Our 

EMS is formalizing our practices and establishing an 

• With regard to economic indicators, for operating philosophy that will sustain itself.” — Ken 

example, sustainability looks not only at Krauter, Port Director, Port Everglades 

financial performance but also the port’s 

contribution to the sustainability of the larger Source: EPA, AAPA & GETF. Environmental 

economic system (e.g., regional economy). Management Systems: Systematically Improving your 

Performance: Ports Sector, September 2004. Ports are major economic drivers in their 

localities; many are accustomed to tracking 

their market presence and both direct and indirect regional economic impacts. 

• Paying more attention to community concerns is a key attribute of a sustainable port. Through public 

outreach and communications efforts, ports also focus on their impacts on the communities in which 

they operate and involve citizens in decisions that affect them. The Ports Corporation of Queensland, 

Australia, for example, produces an annual Sustainability Report, which highlights its commitment to 

a sustainability framework covering environmental, social, and economic performance.57 

• Paying more attention to community concerns is a key attribute of a sustainable port. Through public 

outreach and communications efforts, ports also focus on their impacts on the communities in which 

they operate and involve citizens in decisions that affect them. The Ports Corporation of Queensland, 

Australia, for example, produces an annual Sustainability Report, which highlights its commitment to 

a sustainability framework covering environmental, social, and economic performance.58 Similarly, the 

Port of Houston Authority publishes an annual Environmental Report that presents data on the port’s 

performance in meeting its environmental objectives and targets.59 

56 In January 2006, EPA’s Sector Strategies Program released a guide on current methodologies and best 

practices for preparing port emission inventories. To see the guide, visit: the EPA Sector Strategies website at: 

http://www.epa.gov/sectors/ports/bp_portemissionsfinal.pdf. 

57 See www.pcq.com.au/downloads/2005_PCQ%20Sustainability_WEB3.pdf, accessed March 30, 2007. 

58 See www.pcq.com.au/downloads/2005_PCQ%20Sustainability_WEB3.pdf, accessed March 30, 2007. 

59 To see the Port of Houston Authority’s most recent Environmental Reports, please visit: 

http://www.portofhouston.com/publicrelations/environment.html. 

Interim Final Draft, April 2007 33 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

• Through training, emergency preparedness and response, and other EMS elements, ports may 

already track a number of potential social indicators associated with labor practices. 

Interim Final Draft, April 2007 34 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Element 12: Conduct Audits and Correct Problems 

being followed. 

Internal auditing is a well-defined 

process that ensures: 

• Problems are identified and 

investigated; 

• Root causes are identified; 

• Corrective and preventive actions are assigned 

and implemented; and 

• Actions are tracked and their effectiveness is 

verified. 

Audits are pivotal to maintaining a viable system in 

the face of accidents, emergencies, changing rules, 

staff turnover, etc. By identifying and reporting EMS 

nonconformities and deficiencies to your 

management, you are able to: 

• Maintain management’s focus on the 

environment; 

• Reassess, refine, and improve the EMS and its 

Through measurement or other activities under Element 11, or through internal audits, 

you can assess whether your EMS is adequate and verify that your EMS plans are 

Audit Procedures Typically Describe: 

• Audit planning 

• Audit scope 

• Audit frequency 

• Audit methods 

• Key responsibilities for the audits 

• Reporting mechanisms for the audits 

• Recordkeeping for the audit results 

EMS Problems Typically Include: 

• Poor communication 

• Faulty or missing procedures 

• Equipment malfunction or lack of maintenance 

• Lack of training 

• Lack of understanding of requirements 

• Failure to enforce rules 

• Corrective actions that fail to address root 

causes of problems 

performance, including anticipation and prevention of future problems; 

• Ensure the cost effectiveness of the system. 

Element 12 in the Field 

Many ports have developed internal auditing 

programs as part of their EMSs. EMS Internal 

Auditor Training at the Port of Los Angeles, for 

example, had the added benefit of reinforcing the 

concept that the results of internal audits drive the 

continual improvement of the EMS and, as a result, 

improve environmental performance. 

Ports such as the Port of New York and New Jersey 

have used the results of internal audits to improve 

the effectiveness of their EMS and enhance 

conformity with ISO 14001 Standard. Several ports 

have achieved ISO 14001 certification, including the 

Falcon Terminal at Massport’s Port of Boston, and 

the Barbours Cut Terminal and central maintenance 

areas at the Port of Houston Authority. Ports 

worldwide are also meeting this international 

ISO 14001 Certification 

An organization can receive certification that its 

EMS complies with the requirements of the ISO 

14001 standard by undergoing an audit from a 

qualified, independent third party. When deciding 

whether to have an independent audit of your 

system, a port should consider whether: 

• It is a contractual, regulatory, or market 

requirement; 

• It meets customer preferences; 

• It is part of a risk management program; or 

• It will motivate your staff by setting a clear goal 

for the development of the EMS. 

Source: International Standards Organization, 

http://www.iso.org/iso/en/ISOOnline.frontpage, 

accessed April 24, 2007. 

standard, including the Port of Altamira, Mexico, and the Port of Halifax, Canada. In order to receive ISO 

certification, organizations must pass audit by an independent third party. 

Enhancements for Sustainability 

Auditing for broader sustainability measures is an extension of EMS auditing. Ports already conduct or 

come under financial audits, for example, in compliance with federal, state, and local requirements. 

Interim Final Draft, April 2007 35 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Element 13: Conduct Management Review 

Management reviews are critical to continual improvement and ensure the EMS will 

continue to meet your port’s needs over time. A management review answers the 

question, “Is the system working?” (i.e., is it suitable, adequate, and effective, given the 

port’s needs?). 

Your port’s top management should review and evaluate your EMS at defined intervals, 

such as quarterly. While the scope of the review should be comprehensive, not all 

elements need to be reviewed at once. Review of the policy, goals, and procedures should be carried out 

by the level of management that defines them. The management review should include: 

• Results from assessment, including internal audits, and status of preventive and corrective actions; 

• Progress in meeting objectives and targets; 

• The continuing suitability of the EMS in relation to changing conditions and information; and 

• Concerns of relevant interested parties; 

• Follow-up actions from previous management reviews; and 

• Recommendations for improvement. 

Management involvement ensures that the EMS is integrated not only in the port’s day-to-day operations 

but also into its strategic planning process. 

Element 13 in the Field 

Ports involve their top management in “One of the greatest benefits of having an EMS comes from periodic reviews of EMS projects. The Port of the confidence that it provides. We know we are managing New York and New Jersey, for example, our environmental responsibility and lessening the potential 

established a Management Review Team of environmental problems.” — John P. LaRue, Executive 

comprising nine members who represent top Director, Port of Corpus Christi Authority 

level management: the Directors of Port

Commerce Department and the Office of Source: EPA, AAPA & GETF. Environmental Management 

Environmental Policy, Programs & Systems: Systematically Improving your Performance: 

Compliance, Assistant Port Commerce Ports Sector, September 2004. 

Directors for Operations and Port Planning & 

Development, Managers for Strategic Support Initiatives, Strategic Analysis and Industry Relations, 

Regional Programs, and Administration; and the Chief Environmental Engineer. Management reviews 

demonstrate full commitment to EMS implementation and may assist a port in going on to achieve ISO 

14001 certification for its EMS. 

Enhancements for Sustainability 

Reviewing systems for broader sustainability is an extension of EMS reviews. Such continuous 

improvement evaluations allow a port to improve its day-to-day operations, activities, and services to 

achieve all desired objectives and targets. These reviews can also dove-tail with a port’s strategic 

planning. Once a port has established this Plan-Do-Check-Act systems approach, its management and 

employees are more apt to think more holistically and “outside the box” about solutions to business 

challenges, e.g., using solar or wind as sources of energy for the port and to sell back to the grid; using 

porous pavement instead of installing a storm water management system. 

Interim Final Draft, April 2007 36 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Security Management Systems (SMSs) Based on the Plan-Do-CheckAct Model 

The Port of Houston Authority, having previously implemented an ISO 14001-certified EMS, successfully 

tested the use of the Plan-Do-Check-Act framework for managing security risks and vulnerabilities as part 

of the 1st Ports EMS/SMS Assistance Project. Similar in general structure to an EMS, an SMS helps ports 

identify vulnerabilities, establish action plans, 

and ensure continuous monitoring and 

measuring – all done in coordination with a 

port’s strategic objectives and legal 

requirements. The following highlights 

demonstrate how EMS elements can be 

modified to reflect SMS realities. 

• Plan – Element 1: With regard to scope, 

the SMS fenceline may be set as all 

entities over which the port exercises 

control or significant influence with 

regard to operating policies and practices. 

Thus, in setting boundaries for its SMS, 

Houston selected its Barbours Cut 

Container and Cruise terminals as its SMS 

fenceline, because these facilities were 

managed by the port’s Police/Security 

Force and were within the port’s direct 

operational control. 

• Plan – Element 5: Ports have already 

incorporated security objectives and 

targets into their action plans. Houston’s 

SMS program allowed its police 

department to analyze security risk and 

“The requirements and demands of port security literally 

have changed overnight. Using a systems approach 

allows us to manage the rapidly changing security 

regulations and deadlines. Today, the approach is helping 

the Port of Houston identify and prioritize vulnerabilities 

and risks so that we can make security better, faster.” — 

James T. Edmonds, Chairman, Port of Houston Authority 

Source: EPA, AAPA & GETF. Environmental 

Management Systems: Systematically Improving your 

Performance: Ports Sector, September 2004. 

“We developed a security management system based on 

ISO 14001: 2004. The Plan-Do-Check-Act model has 

already verified that we are in compliance with security 

requirements, and provided us with organizational 

structure and responsibility for more efficient use of 

resources. It has also provided an ongoing process to 

monitor and measure key security parameters, and 

guided us to reallocate resources to highest security 

priorities.” — Russell Whitmarsh, Chief of Police, Port of 

Houston Authority 

Source: “U.S. Ports Set Sail for ISO/PAS 28000,” ISO 

Focus, July/August 2006, http://www.peercenter.net/ 

ewebeditpro/items/O73F9006.pdf. 

other significant vulnerabilities for establishing program goals. By establishing these goals, the port 

maintained a method for monitoring and tracking successful implementation and completion of 

security projects. 

Security Risk Area Significant Vulnerability Objective Target 

Key control Access control Develop a key control 

system at container & 

cruise terminal 

50 percent by June 2006 

Vessel stores Vessel stores & bunkers Develop a vessel stores 

communications program 

100 percent complete by 

June 2006 

Cargo handling Cargo handling Establish an exit process 

for cargo handling 

100 percent complete by 

June 2006 

Security equipment 

maintenance 

Security equipment 

maintenance 

Develop a quality control 

program for security 

equipment maintenance 

50 percent complete by 

December 2005 

SMS program 

development 

SMS implementation Implement SMS program 

for container & cruise 

terminals 

100 percent complete by 

June 2006 

• Do – Element 6: Operational controls extend to security. The Security and Accountability for Every 

(SAFE) Port Act of 2006, for example, includes port safety measures that require 100 percent of 

Interim Final Draft, April 2007 37 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

imported containers to be scanned for radiation, which will entail the deployment of appropriate 

monitoring devices, as well as the creation of standards for operating procedures. 

• Do – Element 7: Re. emergency preparedness and response and SMS implementation, the ISO 

PAS 28000:2005 standard, Specification for Security Management Systems for the Supply Chain, 

specifies the requirements for a security management system, including those aspects critical to 

security assurance of the supply chain. These aspects include, but are not limited to, financing, 

manufacturing, information management and the facilities for packing, storing and transferring goods 

between modes of transport and locations. Security management is linked to many other aspects of 

business management. These other aspects should be considered directly, where and when they 

have an impact on security management, including transporting these goods along the supply chain. 

• Do – Element 8: As part of its SMS, the police department at the port developed a comprehensive 

tiered training program, which was used as a tool to communicate roles and responsibilities, 

regulatory requirements, and appropriate response actions pertaining to current U.S. Coast Guard 

Maritime Security (MARSEC) conditions. Using a tiered approach allowed the department to 

communicate the SMS program to both internal and external stakeholders – expanding into social 

performance indicators of community involvement. 

o Tier I Competence Training is provided to personnel with police/security duties and discusses the 

Facility Security Plans (FSPs) in detail, including MARSEC level response actions. 

o Tier II Tenant Security Officers are select tenants that are not incorporated within an FSP. This 

training is provided to ensure the tenant security representative is aware of the federal regulatory 

requirements and the port’s programs and policies. 

o Tier III General Awareness Training is provided to all Port of Houston Authority employees, 

contractors, visitors, and vendors. This course provides a general overview of security practices 

and general MARSEC level awareness. 

• Do – Element 10: To meet the confidentiality requirements pertaining to the law enforcement 

documents and records, the police department at the port created a document management 

structure. This written procedure describes the SMS document control/approval process for 

monitoring newly developed forms, records, and reports. 

• Check-Act – Element 12: Auditing for security considerations is an extension of EMS auditing. For its 

SMS, for example, the police department at the Port of Houston Authority developed an internal 

compliance auditing program to ensure regulatory compliance. The department’s internal auditing 

team consists of employees from the port’s environmental affairs, engineering, risk management, 

operations, marine, and port police departments. This diverse team worked together in creating 

auditing protocols, including a written audit plan, a schedule, a questionnaire, a report and corrective 

action processes. Additionally, the SMS core team worked together in creating a training program. 

The internal audit was conducted in July 2005, as a preparation exercise for the external USCG audit. 

As a result of this audit, Houston successfully completed the external audit and subsequently 

received noteworthy remarks regarding this proactive management practice. 

Additional ports are now developing SMS as part of the 2nd Port EMS/SMS Assistance Project, including 

the Port of Corpus Christi Authority, the Port of Long Beach, the Port of Portland, and the Port of New 

York and New Jersey. Results from these efforts will be available in early 2008. 

Interim Final Draft, April 2007 38 U.S. Environmental Protection Agency 
An EMS Primer for Ports: Advancing Port Sustainability 

Conclusion 

Organizations around the world, both public 

and private, are facing increasing scrutiny 

regarding their environmental “footprints”. 

EMSs allow organizations such as ports to 

systematically and continuously identify, 

measure, and manage the environmental 

impacts of their activities. Regulatory 

compliance is the foundation of an EMS, not 

the end goal. EMSs help organizations go 

beyond compliance to become better 

neighbors and to make their operations 

more sustainable. 

Many business partners in marine 

transportation are recognizing the value of 

adopting EMSs. Freight carriers such as 

Atlantic Container Line, American Presidents 

Line, Hanjin Shipping Company, HapagLloyd Container Line, K Line Matson 

Navigation, Mitsui O.S.K Lines, and NYK 

Group and cruise lines such as Holland 

America and Royal Caribbean have received 

ISO 14001 certification for EMSs covering 

their ships and/or facilities. There is also a 

very long list of shippers with ISO 14001 

certification. 

It is critical for ports to work with their 

business partners and other stakeholders to 

find sustainable solutions to increasingly 

complex challenges like climate change, 

energy, and land use, i.e., to meet today’s 

economic, environmental, and social needs 

without compromising the ability of future 

generations to meet theirs. 

'We must realize we are no longer unconnected. Our 

success — all of us in an integrated global supply and 

demand chain — depends on the success of the whole. The 

success of the entire world economy and the well-being of all 

of the world's people depend on our ability to succeed as 

sustainable businesses at this critical juncture in our 

industry's history.” — Chang Kuo-Cheng, Chairman, 

Evergreen Marine Corporation 

Source: “Evergreen Chairman Urges Cooperation,” Traffic 

World, March 6, 2006. 

Steering Toward Sustainable Port Communities 

Interim Final Draft, April 2007 39 U.S. Environmental Protection Agency 
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U.S. Environmental Protection Agency 

National Center for Environmental Innovation 

April 2007