Second Edition

Environmental Management Systems:

An Implementation Guide for

Small and Medium-Sized Organizations

NSF International

Ann Arbor, Michigan

January 2001

Continual

Improvement

Environmental

Policy

Planning

Implementation Checking /

Corrective Action

Management

Review
© 2001 NSF i

Second Edition

Environmental Management Systems:

An Implementation Guide for Small and Medium-Sized Organizations

Written by:

Philip J. Stapleton, Principal

Margaret A. Glover, Principal

Glover-Stapleton Associates, Inc.

3 Bunkers Court

Grasonville, MD 21638

410-827-7232

and

S. Petie Davis, Project Manager

NSF ISR

789 N. Dixboro Road

Ann Arbor, MI 48158

1-888-NSF-9000

Copyright © NSF 2001

All rights reserved

This work has been copyrighted by NSF to preserve all rights under U.S. Copyright law and

Copyright laws of Foreign Nations. It is not the intent of NSF to limit by this Copyright the fair

use of these materials. Fair use shall not include the preparation of derivative works.

Published by NSF International: E-mail: information@nsf-isr.org Web: www.nsf-isr.org
© 2001 NSF i

Acknowledgments

When the first edition of this Guide was published in November 1996, the use of environmental

management systems (EMS) was a relatively new, but rapidly expanding phenomenon. Considerable

experience in EMS design and implementation has been gained since the first edition of this Guide was

published. The authors’ primary goal in preparing this second edition of the Guide was to take

advantage of the many new developments in the EMS field as well as the insights and experiences of

many organizations that have implemented EMS over the past few years.

The second edition was prepared by NSF International with funding through a cooperative agreement

with the U.S. Environmental Protection Agency’s Office of Wastewater Management; Office of

Enforcement and Compliance Assistance; Office of Pesticides, Prevention and Toxic Substances; and

Office of Policy Economics – Innovation.

In preparing the second edition, the authors solicited input from a variety of organizations that used the

Guide in EMS planning and implementation activities. Feedback from the user community was very

helpful in framing the changes that are reflected in this second edition. In particular, the authors would

like to thank the following individuals for sharing experiences and insights on their use of the first edition

of the Guide.

• Sue Mills, Champion International,

• Charles Tellas, Milan Screw Products, Inc.,

• Ronda Moore, Zexel Corporation

• Susan Briggs, Brookhaven National Laboratory

NSF International also would like to acknowledge the following individuals for their many contributions

to the first edition of this Guide:

• Jeffrey R. Adrian, The John Roberts Company

• Lemuel D. Amen, Washtenaw County Department of Environment & Infrastructure Services

• Stephen P. Ashkin, Rochester Midland

• Christine A. Branson, Industrial Technology Institute

• Ken Burzelius, Midwest Assistance Programs, LeSueur County

• Marci Carter, Iowa Waste Reduction Center, University of Northern Iowa

• John Dombrowski, U. S. Environmental Protection Agency (Office of Compliance)

• David Fiedler, Michigan Department of Environmental Quality (Environmental Assistance Div.)

• Wendy Miller, U. S. Environmental Protection Agency (Office of Compliance)

• Charles Tellas, Milan Screw Products, Inc.

• Bryant Winterholer, K. J. Quinn & Co., Inc.

Finally, the authors of this Guide would like to thank Jim Horne of the U. S. Environmental Protection

Agency (Office of Wastewater Management) for his significant contributions to the development of this

Guide.
© 2001 NSF ii

Second Edition

Environmental Management Systems:

An Implementation Guide for Small and Medium-Sized Organizations

CONTENTS

Introduction to Second Edition .........................................................................................................1

Section 1: Why Your Organization Should Have an EMS.........................................................4

Section 2: Key EMS Concepts..........................................................................................................8

Section 3: READY! (Initial EMS Planning)..................................................................................10

Section 4: SET! (Key Elements of an EMS) ...............................................................................14

Environmental Policy..................................................................................................................16

Identifying Environmental Aspects...........................................................................................20

Legal and Other Requirements................................................................................................25

Objectives and Targets..............................................................................................................28

Environmental Management Program(s)................................................................................32

Structure and Responsibility.....................................................................................................35

Training, Awareness and Competency...................................................................................39

Communications .........................................................................................................................43

EMS Documentation..................................................................................................................47

Document Control.......................................................................................................................50

Operational Control....................................................................................................................53

Emergency Preparedness and Response..............................................................................57

Monitoring and Measurement...................................................................................................60

Nonconformance and Corrective / Preventive Action...........................................................65

Records........................................................................................................................................69

EMS Auditing...............................................................................................................................71

Management Review.................................................................................................................75

Section 5 : GO! (Roadmap for EMS Development) ..................................................................78

Creating Your EMS: Step by Step...........................................................................................80

Appendix A: TOOL KIT.....................................................................................................................88

Sample Environmental Policies .............................................................................................89

Environmental Impact Identification and Evaluation: Techniques and Data Sources...96

Sample Procedure: Instructions for Environmental Aspects Identification Form...........98
© 2001 NSF iii

Sample Procedure: Instructions for Environmental Aspects Identification Form.........103

Environmental Aspects Identification....................................................................................106

Sample Environmental Aspect Evaluation and Scoring Tools........................................108

Resources for Tracking Environmental Laws and Regulations .......................................111

Sample Process Tool: Setting Objectives & Targets........................................................113

Sample Procedure: Setting Objectives & Targets.............................................................117

Sample Tools: Environmental Management Program........................................................120

Sample Responsibility Matrix.................................................................................................123

Sample Environmental Training Log.....................................................................................125

Sample Procedure: Communications with External Parties.............................................127

Sample Document Index.........................................................................................................130

Outline of Sample EMS Manual and Other EMS Documents.........................................132

Sample Records Management Form (supplied courtesy of..............................................134

General Oil Company) .............................................................................................................134

Sample Procedure: Corrective and Preventive Action.....................................................136

(includes tracking log)..............................................................................................................136

Sample Environmental Records Organizer..........................................................................141

Sample Procedure: EMS Audits ...........................................................................................143

Sample EMS Audit Forms.......................................................................................................149

Sample EMS Audit Questions ................................................................................................152

Sample Procedure: Management Review...........................................................................157

Appendix B: EPA’s Performance Track and Other Government EMS Initiatives..........159

Appendix C: Information on Process Mapping and Design for Environment................169

Appendix D: Registration of Environmental Management Systems.................................178

Appendix E: Integration of Environmental Management Systems and Quality

Management Systems......................................................................................................................182

Appendix F: Additional Sources of Information and Contacts ..........................................186

Glossary of Acronyms.....................................................................................................................195

Bibliography .......................................................................................................................................196
© 2001 NSF 1

Introduction to Second Edition

The first edition of this Guide was published in November 1996. Like its predecessor, this second

edition is designed to explain environmental management system (EMS) concepts and to support and

facilitate the development of EMS among small and medium-sized organizations. Implementation of an

EMS is a voluntary approach to improving environmental performance. Over the past several years,

many public and private sector organizations have implemented EMS and their numbers grow daily.

These organizations report a number of important EMS benefits, as described in this Guide.

Many changes were made in this edition of the Guide to improve its usefulness and to reflect EMS

experience gained over the last four years The changes were based on feedback solicited from

selected users of the first edition of the Guide, lessons learned and implementation examples from the

NSF/EPA projects, the Multi-State Working Group, Guide users, and Technical Committee 207-Small

and Medium-Sized Enterprise efforts. In particular, the authors have provided additional information on

certain EMS elements that many organizations have found to be particularly challenging – including

environmental aspects, communications and operational controls, among others. Sections 3 through 5

have been reconfigured into a new “Ready-Set-Go” format. The new Section 5 (GO!) has been added

to provide a “roadmap” or logical sequence for implementing the key elements of an EMS. In addition,

pollution prevention success stories and examples of EMS implementation practices from public sector

and service based-organizations have been added to help demonstrate the value of EMS.

This Guide is designed primarily for use by EMS implementers — the people in a small or mediumsized organization that lead the EMS development effort. The heart of the Guide is found in Section 4,

“Key Elements of an EMS.” For each of the key EMS elements, this section describes the importance of

the element, how to get started on implementation, and other key suggestions. In this edition,

worksheets have been added to help users “capture their learning” as they progress from one EMS

element to the next. Readers of the Guide can use these worksheets to summarize and evaluate their

existing management processes, to initiate needed improvements and to help maintain implementation

momentum.

The Guide continues to use the ISO 14001 standard as one important EMS model. ISO 14001,

published in November 1996, is the most widely accepted international standard for EMS. EPA, as part

of its effort to promote the use of EMS’s that can help organizations improve environmental performance

(including compliance) and make greater use of pollution prevention approaches, is implementing

several EMS initiatives that might be useful to some organizations. These include the National

Environmental Performance Track, the EMS Initiative for Local Governments and the Design for

Environment EMS Guide. Information on the National Environmental Performance Track program and

other Federal and state-level EMS initiatives can be found in Appendix B and other relevant sections of

this Guide.

While this Guide is intended primarily for organizations outside the Federal government, some Federal

agencies are developing EMS’s at their facilities. These agencies may wish to use this Guide to support

their EMS efforts.

This Guide is not intended for use by registrars (or others) for registration purposes, nor is it intended to

provide specific interpretations of the ISO 14001 Standard.
© 2001 NSF 2

How this Guide is Organized

Section 1:

Why Your Organization

Should Have an EMS

Describes the many benefits of an EMS and how such a system can

help your organization to compete and prosper in today’s global

marketplace.

Section 2:

Key EMS Concepts

Summarizes overall management systems concepts. This section

explains what a management system is and what must be in place for

a successful EMS.

Section 3:

Initial EMS Planning

Describes the initial process for planning an EMS and recommends

some steps in the overall EMS planning effort.

Section 4:

Key Elements

of an EMS

Provides detailed guidance on how each element of your EMS could

be designed and implemented. Discusses each of the key elements of

an EMS and suggests how to put them in place.

Section 5:

Roadmap for

EMS Development

Describes a sequence of events or “roadmap” for implementing the

key elements of an EMS and explains why the implementation of

certain elements might precede others.

Appendices Describe sources of EMS information and related EPA and state

programs. Also describe the process for registering an EMS and

selecting and working with a registrar. The Tool Kit (Appendix A)

provides sample EMS policies, procedures and other tools that your

organization can tailor to fit its EMS needs. The sample procedures

are adapted from actual EMS procedures used by organizations that

have implemented EMS.

Use of Icons

A variety of icons are used in this Guide to highlight key concepts and suggestions for the reader. The

most frequently used icons include:

The light bulb is used to highlight EMS examples and experiences from various

organizations.

The hand is used to point out hints for implementing EMS elements.

The key is used to indicate keys to successful EMS implementation, as identified by

various organizations.

+
© 2001 NSF 3

The speech balloon is used to indicate quotes from representatives of organizations that

have implemented an EMS, as well as definitions from various sources (such as ISO

14001).

The Tool Box icon is used to highlight references to useful examples and other tools

that are found in Appendix A (the Tool Kit).

The Links icon is used to summarize critical linkages among EMS elements.
© 2001 NSF 4

Sec. 1

Section 1: Why Your Organization Should Have an EMS

A systematic approach to achieve your environmental and other organizational goals

“We view the

establishment of an

EMS as a process

that forces us to

better organize our

priorities and

projects and to

identify problems

and exposures

before they occur.”

- K.J. Quinn & Co.,

a small specialty

chemical company

Does your organization need an EMS? Well, ask

yourself the following questions:

• Is your organization required to comply with

environmental laws and regulations?

• Are you looking for ways to improve your

environmental performance?

• Is the state of your organization’s environmental

affairs a significant liability?

• Does a lack of time or resources prevent your

organization from managing its environmental

obligations effectively?

• Is the relationship between your organization’s

environmental goals and other goals unclear?

If you answered YES to one or more of the above

questions, an EMS can help your organization —

and so will this Guide!

As one of your organization’s leaders, you probably

know that interest in environmental protection and

sustainable development is growing each year. You

might hear about these issues from customers, the

public or others. Like many, your organization may

be increasingly challenged to demonstrate its

commitment to the environment. Implementing an

EMS can help you meet this challenge in several

important ways.

First, an effective EMS makes good sense, whether

your organization is in the public or private sector.

By helping to identify the causes of environmental

problems and then eliminate them, an EMS can help

you save money. Think of it this way:

v Is it better to make a product (or provide a

service) right the first time or to fix it later?

v Is it cheaper to prevent a spill in the first place or

to clean it up afterwards?

v Is it more cost-effective to prevent pollution or to

manage it after it has been generated?

Key EMS Benefits

 ̨ improved

environmental

performance

 ̨ reduced liability

 ̨ competitive advantage

 ̨ improved compliance

 ̨ reduced costs

 ̨ fewer accidents

 ̨ employee involvement

 ̨ improved public image

 ̨ enhanced customer

trust

 ̨ more favorable credit

terms

 ̨ meet customer

requirements
© 2001 NSF 5

Sec. 1

“We found that an

EMS could improve

employee retention,

new hire selection,

working conditions,

and the perceptions

of our customers,

suppliers, lenders,

neighbors, and

regulators.”

- Milan Screw Products,

a 32-person manufacturer

of precision fittings

Second, an EMS can be an investment in longterm viability of your organization. An EMS can

help you to be more effective in achieving

environmental goals. And, by helping businesses to

keep existing customers and attract new ones, an

EMS adds value.

Here’s some good news: Much of what you need for

an EMS may already be in place! The management

system framework described in this Guide includes

many elements that are common to managing many

organizational processes, such as quality, health &

safety, finance, or human resources. As you review

this Guide, you will probably find that your

organization has many EMS processes in place,

even though they may have been designed for other

purposes. Integrating environmental management

with other key organizational processes can improve

financial, quality and environmental performance.

The key to effective environmental management is

the use of a systematic approach to planning,

controlling, measuring and improving an

organization’s environmental performance.

Potentially significant environmental improvements

(and cost savings) can be achieved by assessing and

improving your organization’s management

processes. Many environmental “problems” can be

solved without installing expensive pollution control

equipment.

Of course, there is some work involved in planning,

implementing and maintaining an EMS. But many

organizations have found that the development of an

EMS can be a vehicle for positive change. Many

organizations have seen that the benefits of an EMS

far outweigh the potential costs. And while these

EMS concepts certainly apply to the private sector, a

number of public sector organizations (including

municipalities) have found that they can benefit from

an EMS.

In the Total Quality Management (TQM) world, they

say that “quality is free” — as long as you are willing

to make the investments that will let you reap the

rewards. The same holds true for environmental

management.

Want to know more about EMS costs and benefits?

Then read on ...

Some reasons that

municipalities have

implemented an EMS:

 ̨ Improved compliance

performance

 ̨ Enhanced

management

confidence

 ̨ Increased efficiency

 ̨ Public image concerns

 ̨ Growth management

 ̨ Desire to be seen as

leaders and innovators
© 2001 NSF 6

Sec. 1

EPA encourages the use

of EMS that improve

compliance, pollution

prevention and other

forms of environmental

performance. The

Agency is assessing how

EMS can be used to

strengthen environmental

programs and policies.

Steve Daut, Council Trustee

Village of Chelsea, Michigan

Frequently Asked Questions about EMS

1. We already have a compliance program – why do

we need an EMS?

An EMS can help you to comply with regulations more

consistently and effectively. It also can help you identify

and capitalize on environmental opportunities that go

beyond compliance.

2. How big does an organization need to be to

successfully implement an EMS?

EMS have been implemented by organizations ranging in

size from a couple of dozen employees to many thousands

of employees. The elements of an EMS (as described in

this Guide) are flexible by design to accommodate a wide

range of organizational types and sizes.

3. Will an EMS help us to prevent pollution?

A commitment to preventing pollution is a cornerstone of an

effective EMS and should be reflected in an organization’s

policy, objectives and other EMS elements. Examples

throughout this Guide show how organizations have used

an EMS to prevent pollution.

4. To implement an EMS, do we have to start from

scratch?

Much of what you have in place now for environmental

management probably can be incorporated into the EMS.

There is no need to “start over”.

5. How will an EMS affect my existing compliance

obligations?

An EMS will not result in more or less stringent legal

compliance obligations. But an EMS should improve your

efforts to comply with legal obligations, and, in some cases,

may lead to more flexible compliance requirements. (See

discussion of Performance Track in Appendix B.)

6. Do we need to be in 100% compliance in order to

have an EMS?

No. The concept of continual improvement assumes that

no organization is perfect. While an EMS should help your

organization to improve compliance and other measures of

performance, this does not mean that problems will never

occur. However, an effective EMS should help you find and

fix these problems and prevent their recurrence.

“We needed a system to

manage things that

came up in a consistent

way. Our area is growing

and an EMS will help us

handle development

issues such as

controlling soil erosion

and preserving the

natural features of the

area. An EMS is a way to

control environmental

problems in a rapidly

growing community.”
© 2001 NSF 7

Sec. 1

EMS Costs and Benefits

POTENTIAL COSTS

Internal

• Staff (manager) time

• Other employee time

(Note: Internal labor costs represent the

bulk of the EMS resources expended

by most organizations)

External

• Potential consulting assistance

• Outside training of personnel

POTENTIAL BENEFITS

• Improved environmental performance

• Enhanced compliance

• Prevention of pollution/resource conservation

• New customers / markets

• Increased efficiency / reduced costs

• Enhanced employee morale

• Enhanced image with public, regulators, lenders,

investors

• Employee awareness of environmental issues and

responsibilities

If your organization already has or is

considering a quality management system

(based on ISO 9001, for example), you will

find significant synergy between what you

need for quality management and for

environmental management (see below).

Some Common Aspects of Quality and Environmental Management Systems

QMS

• Quality Policy

• Adequate Resources

• Responsibilities and Authorities

• Training

• System Documentation

• Process Controls

• Document Control

• System Audits

• Management Review

EMS

• Environmental Policy

• Adequate Resources

• Responsibilities and Authorities

• Training

• System Documentation

• Operational Controls

• Document Control

• System Audits

• Management Review

One final note: Small and medium-sized

organizations often have certain advantages

over larger organizations in ensuring effective

environmental management. In smaller

organizations, lines of communication are

generally shorter, organizational structures are

less complex, people often perform multiple

functions, processes are generally well

understood, and access to management is

simpler. These can be real advantages for

effective environmental management.

Are you interested in learning more about how

an EMS can help your organization? If so, let’s

look at some key management systems concepts

and how they are applied in the environmental

area.
© 2001 NSF 8

Sec. 2

Section 2: Key EMS Concepts

The focus on quality principles

An EMS is:

A continual cycle of planning,

implementing, reviewing and

improving the processes and

actions that an organization

undertakes to meet its

environmental obligations.

An effective EMS doesn’t just

happen. An effective EMS

needs ongoing and visible

management support

Top management" is the

person or group with

executive responsibility for the

organization”

You have probably heard of Total Quality Management

(TQM). Your organization may apply TQM principles to

some of its operations and activities.

An effective EMS is built on TQM concepts. To improve

environmental management, your organization needs to

focus not only on what things happen but also on why

they happen. Over time, the systematic identification

and correction of system deficiencies leads to better

environmental (and overall organizational) performance.

Most EMS models (including the ISO 14001 standard,

which is described later) are built on the “Plan, Do,

Check, Act” model introduced by Shewart and Deming.

This model endorses the concept of continual

improvement.

Plan

Do

Check

Act

In the EMS model described in this Guide, the “Plan, Do,

Check, Act” steps have been expanded into seventeen

elements that are linked together. These EMS

elements and their linkages are discussed in Section 4.

Some of the keys to a successful EMS include:

Top Management Commitment

Applying TQM principles to the environmental area and

providing adequate resources are the job of top

management. To initiate and sustain the EMS effort,

top management must communicate to all employees

the importance of :

• making the environment an organizational priority

(thinking of effective environmental management as

fundamental to the organization’s survival)

• integrating environmental management

throughout the organization

(thinking about the environment as part of

product/service and process development and

delivery, among other activities)

Figure 1

Continual

Improvement:

Enhancing your EMS

to better your overall

environmental

performance
© 2001 NSF 9

Sec. 2

• looking at problems as opportunities

(identifying problems, determining root causes and

preventing problem recurrence)

Focus on Continual Improvement

No organization is perfect. The concept of continual

improvement recognizes that problems will occur. A

committed organization learns from its mistakes and

prevents similar problems from recurring.

Flexibility

An effective EMS must be dynamic to allow your

organization to adapt to a quickly changing

environment. For this reason, you should keep your

EMS flexible and simple. This also helps make your

EMS understandable for the people who must

implement it — your organization’s managers and

other employees.

Some organizations have

found that an effective EMS

allows them to design pollution

and other environmental

impacts out of their products,

services and operations. This

can save money and reduce

liability.

Employee involvement is

crucial. An effective

implementation team is

pivotal to the success of

many organizations.

An EMS should integrate

environmental

management into day-today operations as well as

strategic decisions. It can

make the environment the

responsibiity of every

employee.

Compatibility with Organizational Culture

The EMS approach and an organization’s culture

should be compatible. For some organizations, this

involves a choice: (1) tailoring the EMS to the culture,

or (2) changing the culture to be compatible with the

EMS approach. Bear in mind that changing an

organization’s culture can be a long-term process.

Keeping this compatibility issue in mind will help you

ensure that the EMS meets your organization’s

needs.

Employee Awareness and Involvement

As you design and implement an EMS, roadblocks

may be encountered. Some people may view an

EMS as bureaucracy or extra expense. There also

may be resistance to change or fear of new

responsibilities. To overcome potential roadblocks,

make sure that everyone understands why the

organization needs an effective EMS, what their role

is and how an EMS will help to control environmental

impacts in a cost-effective manner. Employee

involvement helps to demonstrate the organization’s

commitment to the environment and helps to ensure

that the EMS is realistic, practical and adds value.

Building or improving an EMS (with the help of this

Guide) provides an opportunity to assess how your

organization manages environmental obligations and

to find better (and more cost-effective) solutions.

While you will probably identify some areas where

your current EMS can be improved, this does not

mean that you should change things that are working

well! By reviewing what your organization does and

how well it works, you can ensure that your EMS will

be viable and effective, both now and in the future.

Don’t get discouraged if your system has some bugs

at first — the focus is on continual improvement!

Flexible & Simple =

Adaptable &

Understandable
© 2001 NSF 10

Sec. 3

Section 3: READY! (Initial EMS Planning)

Putting the theory of EMS into practice

Milan Screw Products found

that the use of a crossfunctional team (the

environmental task group)

was the key to progress in

evaluating and implementing

their EMS. Participation of

line managers and

employees is essential in

successfully implementing

an EMS.

Appendix F has

information on EMS

resources

K.J.Quinn & Company found

that it could perform an initial

assessment of its

environmental programs in

20-25 hours

Preliminary Review Tools:

See the “NSF ISO 14001

Self Assessment Tool”

(at www.nsf-isr.org) or

“Incorporating Design for

Environment into your Gap

Analysis”

(at www.epa.gov/dfe)

Building an EMS might sound like an overwhelming task

for a smaller organization, but it need not be. Since time

and other resources are limited in any organization, it is

important that you use resources wisely. One way to do

this is by preparing and following a simple, effective plan.

Fortunately, you can build on the experiences of other

organizations that have already implemented an EMS.

Examples are provided throughout this Guide.

Figure 2 illustrates the initial steps in the EMS planning

process. The importance of careful planning cannot be

overemphasized. Taking the time to figure out what you

need to do, how you will do it, and who must be involved

will pay big dividends down the road.

Experience shows that using a team approach to

planning and building an EMS is an excellent way to

promote commitment and ensure that your objectives,

procedures and other system elements are realistic,

achievable, and cost-effective. Ideas for using a team

and involving employees are discussed in this section.

A few hints to keep in mind as you build your EMS:

• Help is available — don’t hesitate to use it.

(See Appendix F for information on resources.)

• Pace yourself. Move quickly enough that employees

stay interested and engaged, but not so fast that

those involved are overloaded or that the effort

becomes superficial.

• Don’t re-invent the wheel -- existing management

practices should help you to meet EMS requirements.

• Consultants can help you evaluate your EMS and

suggest approaches used successfully elsewhere.

Explore ways to hold consulting costs down. You

may be able to join forces with other organizations to

hire a consultant or sponsor a training course.

Some Thoughts on Using Consultants

• Assess your own in-house resources first.

• Ensure both parties understand the scope

of work.

• Get references and check them. Look for

consultants with experience in small

organizations and your specific industry.

• Use consultants to gain insights on approaches

used by other organizations.

• An EMS developed by consultants “in isolation”

will not work. Your own people need to be

involved in the EMS development process.
© 2001 NSF 11

Sec. 3

FIGURE 2: INITIAL EMS PLANNING STEPS

READY!

Define Organization’s Goals

Build

Implementation

Team

Secure

Management

Commitment

Conduct

Preliminary

Review

Initiate

Employee

Involvement

Select

EMS

Champion

Develop

Project

Plan,

Schedule

Secure

Resources,

Assistance

Monitor &

Communicate

Progress

Hold

Kick-off

Meeting
© 2001 NSF 12

Sec. 3

Laying the Groundwork for an EMS: Key Steps

A first step in EMS planning is to decide why you are

pursuing the development of an EMS. Are you

trying to improve your environmental performance (for

example, compliance with regulations or prevent

pollution)? Are you trying to promote involvement

throughout the organization? Write your goals down

and refer back to them frequently as you move

forward. As you design and implement the EMS, ask:

How is this task going to help us achieve our goals?

This also is a good time to define the project scope or

“fenceline” (i.e., what is the “organization” that the

EMS will cover? One location? Multiple locations?

Should we “pilot” the EMS at one location then

implement the system at other locations later?).

One of the most critical steps in the planning process is

gaining top management’s commitment to support

EMS development and implementation. Management

must first understand the benefits of an EMS and what

it will take to put an EMS in place. Explain the

strengths and limitations of your current approach and

how those limitations can affect the organization’s

financial and other performance. Management also

has a role in ensuring that the goals for the EMS (see

above) are clear and consistent with other

organizational goals. Management’s commitment

should be communicated across the organization.

Not all small- or medium-sized organizations have the

luxury of choosing among multiple candidates, but your

choice of project champion is critical. The champion

should have the necessary authority, an understanding

of the organization, and project management skills.

The champion should be a “systems thinker” (ISO

9000 experience can be a plus, but is not necessary),

should have the time to commit to the EMS-building

process and must have top management support.

A team with representatives from key management

functions (such as engineering, finance, human

resources, production and/or service) can identify and

assess issues, opportunities, and existing processes.

Consider including contractors, suppliers or other

external parties as part of the project team, where

appropriate. The team will need to meet regularly,

especially in the early stages of the project. A crossfunctional team can help to ensure that procedures are

practical and effective and can build commitment to

and “ownership” of the EMS.

Once the team has been selected, hold a kick-off

meeting to discuss the organization’s objectives in

implementing an EMS, the steps that need to be taken

initially, and the roles of team members, among other

topics. If possible, get top management to describe its

commitment to the EMS at this meeting. The kick-off

Define

Organization's

Goals for EMS

Secure Top

Management

Commitment

Select

EMS

Champion

Build

Implementation

Team

Hold

Kick-Off

Meeting

more...
© 2001 NSF 13

Sec. 3

Creating Your Own EMS (cont’d.)

meeting also is a good opportunity to provide some

EMS training for team members. Follow-up this

meeting with a communication to all employees.

The next step is for the team to conduct a preliminary

review of your current compliance and other

environmental programs/systems and to compare

these against the criteria for your EMS (such as ISO

14001). Evaluate your organization’s structure,

procedures, policies, environmental impacts, training

programs and other factors. Determine which parts of

your current EMS are in good shape and which need

additional work. See the “NSF ISO 14001 SelfAssessment Tool” (www.nsf-isr.org) or “Incorporating

Design for the Environment into Your Gap Analysis”

(www.epa.gov/dfe) for gap analysis tools.

Based on the results of the preliminary review, prepare

a project plan and budget. The plan should describe

in detail what key actions are needed, who will be

responsible, what resources are needed, and when the

work will be completed. Keep the plan flexible, but set

some stretch goals. Think about how you will maintain

project focus and momentum over time. Look for

potential “early successes” that can help to build

momentum and reinforce the benefits of the EMS.

The plan and budget should be reviewed and

approved by top management. In some cases, there

may be outside funding or other types of

assistance that you can use (from a trade association,

a state technical assistance office, etc.). See

Appendix F for more ideas on possible sources of help.

Employees are a great source of knowledge on

environmental and health & safety issues related to

their work areas as well as on the effectiveness of

current processes and procedures. They can help the

project team in drafting procedures. Ownership of the

EMS will be greatly enhanced by meaningful employee

involvement in the EMS development process.

As you build the EMS, be sure to regularly monitor

your progress against the project plan and

communicate this progress within the organization.

Be sure to communicate the accomplishments that

have been made and describe what happens next.

Build on small successes. Be sure to keep top

management informed and engaged, especially if

additional resources might be required.

Advertise your successes to

keep management and

employees aware of your

EMS efforts. Document

benefits, no matter how

small they may seem at the

time. As this list grows, so

will EMS support.

Conduct

Preliminary

Review

Prepare

Budget and

Schedule

Involve

Employees

Monitor and

Communicate

Progress

Secure

Resources,

Assistance
Do

Check

Act

 Plan

© 2001 NSF 14

Sec. 4

Section 4: SET! (Key Elements of an EMS)

What does an EMS consist of? How are the elements linked together?

As mentioned earlier, your EMS should be built on the “Plan, Do, Check, Act” model to ensure that

environmental matters are systematically identified, controlled, and monitored. Using this approach

will help to ensure that performance of your EMS improves over time and that you meet your goals for

implementing an EMS in the first place.

This section describes seventeen EMS elements that are common to most EMS models. This section

also notes the key linkages among these elements. While there are several good EMS models

available, this Guide generally uses the ISO 14001 Standard as a starting point for describing EMS

elements. This has been done for several reasons:

• ISO 14001 is a widely accepted international standard for EMS that focuses on

continual improvement;

• Companies may be asked to demonstrate conformance with ISO 14001 as a

condition of doing business in some markets; and

• The Standard is consistent with the key elements found in many EMS models,

including the European Union’s Eco-Management and Audit Scheme, EPA’s

Performance Track and the Code of Environmental Management Principles for

Federal Agencies, among others.

Figure 3: EMS Model

Planning

• Environmental Aspects

• Legal & Other Requirements

• Objectives & Targets

• Environmental Management

Program

Implementation

• Structure & Responsibility

• Training, Awareness, Competence

• Communication

• EMS Documentation

• Document Control

• Operational Control

• Emergency Preparedness /

Response

Start

Environmental

Policy

Checking /

Corrective Action

• Monitoring & Measurement

• Nonconformance & Corrective &

Preventive Action

• Records

• EMS Audits

Continual

Improvement!

Management

Review
Do

Check

Act

 Plan

© 2001 NSF 15

Sec. 4

Key Elements of an EMS: A Snapshot

• Environmental policy — Develop a statement of your organization’s commitment to the

environment. Use this policy as a framework for planning and action.

• Environmental aspects — Identify environmental attributes of your products, activities

and services. Determine those that could have significant impacts on the

environment.

• Legal and other requirements — Identify and ensure access to relevant laws and

regulations, as well as other requirements to which your organization adheres.

• Objectives and targets — Establish environmental goals for your organization, in line

with your policy, environmental impacts, the views of interested parties and other

factors.

• Environmental management program — Plan actions necessary to achieve your

objectives and targets.

• Structure and responsibility — Establish roles and responsibilities for environmental

management and provide appropriate resources.

• Training, awareness and competence — Ensure that your employees are trained and

capable of carrying out their environmental responsibilities.

• Communication — Establish processes for internal and external communications on

environmental management issues.

• EMS documentation — Maintain information on your EMS and related documents.

• Document control — Ensure effective management of procedures and other system

documents.

• Operational control — Identify, plan and manage your operations and activities in line

with your policy, objectives and targets.

• Emergency preparedness and response — Identify potential emergencies and develop

procedures for preventing and responding to them.

• Monitoring and measurement — Monitor key activities and track performance.

Conduct periodic assessments of compliance with legal requirements.

• Nonconformance and corrective and preventive action — Identify and correct problems

and prevent their recurrence.

• Records — Maintain and manage records of EMS performance.

• EMS audit — Periodically verify that your EMS is operating as intended.

• Management review — Periodically review your EMS with an eye to continual

improvement.
Do

Check

Act

 Plan

© 2001 NSF 16

Sec. 4

Environmental Policy

Communicating your environmental vision

Sample environmental

policies are provided in the

Tool Kit (see Appendix A).

An environmental policy is top management’s

declaration of its commitment to the environment. This

policy should serve as the foundation for your EMS

and provide a unifying vision of environmental concern

by the entire organization. Given its importance, your

policy should be more than just flowery prose.

Since it serves as the framework for setting

environmental objectives and targets, the policy should

be brought to life in your plans and deeds. Everyone

in the organization should understand the policy and

what is expected of them in order to achieve the

organization’s objectives and targets.

Your policy should reflect three key commitments (see

box), including a commitment to continual

improvement. While this does not mean that you must

improve in all areas at once, the policy should drive your

organization’s efforts to continually improve

environmental management (and the improved

performance that results from these efforts).

+

ISO 14001

Hints:

• Your organization probably has some type of

environmental policy now, even if it’s not written

down. For example, your organization probably is

committed to complying with the law and avoiding

major environmental problems, at a minimum.

Document existing commitments and goals as a

starting point.

• The policy should relate to your products and

services, as well as supporting activities. Consider

the results of your preliminary review (see Section

3) and your analysis of the environmental aspects

of your products, services and activities before

finalizing the policy. These two steps can provide

insight as to how your organization interacts with the

environment and how well it is meeting its

challenges. For example, information obtained

during the preliminary review might help you define

specific policy commitments.

• Keep your policy simple and understandable. Ask

yourself: What are we trying to achieve? How can we

best communicate this to the rest of the organization?

One test to use: Could our employees describe the

intent of our policy in twenty words or less?

Key Policy Commitments:

 ̨ Continual improvement

 ̨ Pollution prevention

 ̨ Compliance with

relevant laws and

regulations

Continual Improvement:

"Process of enhancing the

environmental management

system to achieve

improvements in overall

environmental performance

in line with the organization's

environmental policy."
Do

Check

Act

 Plan

© 2001 NSF 17

Sec. 4

I

M

P

R

O

V

E

M

E

N

T

Environmental

Policy

C

O

M

P

L

I

A

N

C

E

P

R

E

V

E

N

T

I

O

N

Figure 4:

Three Pillars of an

Environmental Policy

• Environmental Aspects

• Objectives & Targets

• Training & Awareness

• Communication

• Management Review

• The environmental policy should be explicit enough

to be audited. If you choose to use phrases such as

“We are committed to excellence and leadership in

protecting the environment”, consider how you would

demonstrate that such a commitment is being met.

• The environmental policy can be a stand-alone

document or it can be integrated with your health &

safety, quality, or other organizational policies.

• Consider who should be involved in developing the

policy and the best process for writing it. Input from a

range of people within your organization should

increase commitment and ownership.

• Make sure that your employees understand the

policy. Options for communicating your policy

internally include posting it around work sites (e.g., in

lunchrooms), using paycheck stuffers, incorporating

the policy into training classes and materials, and

referring to the policy at staff or all-hands meetings.

Test awareness and understanding from time to time

by asking employees what the policy means to them

and how it affects their work.

• The policy also should be communicated externally.

Some options for external communications include

placing the policy on business cards, in newspaper

advertisements and in annual reports, among other

options. You might choose to communicate the policy

proactively or in response to external requests (or

both). This decision should be factored into your

overall strategy for external communication (see later

discussion under “Communications”).

• Consider how you would demonstrate that you are

living by the commitments laid out in the policy. This

is a good test of whether or not the policy is a “living

document”.

For EPA’s Performance Track program, an organization’s policy must

include:

• compliance with legal requirements and voluntary commitments;

• pollution prevention (see Figure 5);

• continuous improvement in environmental performance, including

areas not subject to regulation, and

• sharing information on environmental performance and their operation

of the EMS with the community.

For more information see Appendix B.
Do

Check

Act

 Plan

© 2001 NSF 18

Sec. 4

Commitments to Compliance with Legal Requirements and Pollution Prevention

Compliance with legal requirements is a critical consideration in EMS development and

implementation. EMS implementation requires an organization, among other things, to:

• develop and communicate an environmental policy that includes a commitment to compliance;

• develop and implement a procedure to identify, analyze and have access to environmental

laws and regulations;

• set objectives and targets in line with its environmental policy, which includes a commitment to

compliance;

• establish management programs to achieve its objectives;

• train employees and communicate relevant EMS requirements to them;

• establish and implement operational control procedures;

• establish and implement a procedure for periodically evaluating compliance; and

• establish and implement a procedure to carry out corrective and preventive actions.

While the requirements noted above relate directly to an organization’s management of legal

requirements, each of the seventeen EMS elements described in this Guide can contribute to

enhanced compliance (including communication, documentation and document control, records

management, EMS audits, and management review). An EMS that includes the elements described

in this Guide will help your organization improve or maintain its compliance performance and facilitate

the establishment of objectives and targets that go “beyond compliance.”

Figure 5

EMS design and implementation also

should take into account the Pollution

Prevention (P2) hierarchy. In

evaluating P2 opportunities,

organizations should start at the top of

the pyramid (i.e., source reduction)

and work their way down as needed to

define the most appropriate methods

for preventing pollution. Examples

and best practices of P2 in operation

are provided throughout this Guide.

Prevention of Pollution Hierarchy

Source Reduction

In-Process Recycling

Other Recycling

Treatment & 

Recovery

Control 

Mechanisms
Do

Check

Act

 Plan

© 2001 NSF 19

Sec. 4

Capture the Learning: Environmental Policy Worksheet

Do we have an existing policy?

If yes, how was the policy developed?

When was the policy last reviewed?

Does the policy reflect the three key

commitments (commitments to

compliance, prevention of pollution and

continual improvement?)

What other commitments does or

should our policy contain?

How does our policy take into account

the environmental attributes of our

products, activities and services?

How would we demonstrate

conformance to our policy?

How is the policy communicated to

our employees? Do our employees

understand the critical elements of our

policy? How do we know?

What feedback have we received on

the policy (from employees, contractors

or other interested parties)?

What happens when we receive

feedback on the policy?

How do we make our policy available

to external parties? Is this process

effective?

Our next step on environmental

policy is to ...
Do

Check

Act

 Plan

© 2001 NSF 20

Sec. 4

Identifying Environmental Aspects

How an organization interfaces with the environment

Environmental Aspect:

“Element of an

organization’s

activities, products, or

services that can

interact with the

environment.”

ISO 14001

Environmental Impact :

“Any change to the 

environment, whether 

adverse or beneficial, 

wholly or partially 

resulting from an 

organization’s activities, 

products, or services.”

To plan for and control its environmental impacts, an

organization must know what these impacts are. But

knowing what the impacts are is only part of the challenge

— you also should know where these impacts come

from. Stated another way, how does your organization

(i.e., your products, services and activities) interact with the

environment?

If your organization has undertaken pollution prevention

projects, you are probably familiar with this concept — that

is, you must know how and where a waste is generated in

order to minimize or eliminate it. And like pollution

prevention, the identification and management of

environmental aspects can (1) have positive impacts on the

bottom line and (2) provide significant environmental

improvements.

So, an EMS should include a procedure to identify and

assess environmental aspects that the organization:

• can control, and

• over which it can have an influence.

Your organization is not expected to manage issues

outside its sphere of influence or control. For example,

while your organization probably has control over how

much electricity it buys from a supplier, it likely does not

control or influence the way in which that electricity is

generated. Similarly, if your organization manufactures a

product that is subsequently incorporated into another

product (for example, a bumper that becomes part of an

automobile), your organization does not control the

environmental aspects of that “finished” product (the

automobile). Thus, your focus should be on the

environmental aspects of your products or services.

The relationship between aspects and impacts is often one

of cause and effect. The term “aspects” (see definition

above) is neutral, so keep in mind that your environmental

aspects can be either positive (such as making a product

out of recycled materials) or negative (such as discharging

toxic materials to a stream). Aspects may result from past

activities, such as spills.

Once you have identified the environmental aspects of your

products, activities, and services, you should determine

which aspects could have significant impacts on the

environment. Aspects that have one or more significant

impact should be considered significant environmental

aspects. These significant aspects should be considered

when you establish environmental objectives, define

operational controls and consider other actions, as

discussed later.

Define

environmental

aspects

Decide if under

your control and

influence

Identify related

impacts

Decide if the

impacts are

significant

environmental
Do

Check

Act

 Plan

© 2001 NSF 21

Sec. 4

+

Milan Screw Products set up

an internal task group to

identify environmental

aspects. As part of this

process, external

stakeholders were identified

and interviewed to

understand their

environmental concerns.

These stakeholder concerns

were added to the list of

environmental aspects.

A multi-step process can be used to make this evaluation.

Keep the resulting information up-to-date, so that potential

aspects of new products, services, and activities are

factored into your objectives and controls.

Hints:

• In identifying aspects and impacts, look beyond

activities covered by laws and regulations. But

because many of your aspects/impacts may be

addressed by legal requirements, your compliance

program might yield some valuable information. Permits,

audit reports, and monitoring records can be useful

inputs. Beyond regulated aspects, consider land,

energy, and natural resource use, for example.

• Once you have identified environmental aspects and

related significant impacts, use this information in setting

your objectives and targets. This does not mean that

you need to address all of your impacts at once.

There may be good reasons (such as cost, availability of

technology or scientific uncertainty) for addressing some

impacts now while deferring action on others. Keep in

mind that managing environmental aspects can have

positive impacts on the organization.

• Remember to look at services as well as products.

While the need to examine on-site operations might be

obvious, you also should consider the potential impacts

of what you might do “off-site” (such as servicing

equipment at customer sites). Similarly, the

environmental aspects of the products, vendors, and

contractors you use may be less obvious, but should still

be considered.

• Identifying significant environmental aspects is one of

the most critical steps in EMS implementation. It can be

one of the most challenging – as well as one of the

most rewarding. Decisions you make in this step can

affect many other system elements (such as, setting

objectives and targets, establishing operational controls

and defining monitoring needs). Careful planning of this

activity will pay dividends in later steps.

Getting Started

• To understand your environmental aspects, it helps to

understand the processes by which you generate

products and services. Flow charting your major

processes can help you understand the process inputs

and outputs as well as how materials are used. A sample

flow chart is provided in the Tool Kit (see Appendix C).

You might also want to consider the views of interested

parties (e.g., neighbors, civic groups, regulators, etc.) in

this process. Some organizations have found external

parties to be a good resource in identifying environmental

aspects.

US Postal Service Assesses

Its Environmental Aspects

The US Postal Service examined

environmental aspects related to the

vehicles it operates, the chemicals it

uses to maintain equipment, the solid

wastes it generates, and the products

(stamps) that it sells.

 “Products” are tangible

results of a process that

transforms inputs into outputs

(for example, cars or

computers). “Services” also

result from processes, but are

intangible in that you cannot

“hold” them (such as dry

cleaning or equipment

maintenance at a customer

site). “Activities” may relate

directly or indirectly to the

provision of products or

services to customers (such

as purchasing or product

design).
Do

Check

Act

 Plan

© 2001 NSF 22

Sec. 4

Use visual tools. As a

starting point, some

organizations prepare

maps of their site and

building(s), along with

surrounding land uses.

The implementation

team uses these maps

to “audit” the site and

identify potential

environmental aspects.

• Objectives & Targets

• Training & Awareness

• Communications

• Operational Controls

• Monitoring & Measurement

• You can use many sources of information to help you

identify and assess your environmental aspects. For

starters, look at your permits, the regulations that apply

to your operations, EPCRA reports, Material Safety

Data Sheets and monitoring records. Trade

associations, regulatory agencies, customers and

suppliers also might provide useful information to

support the assessment

• Your team should define the criteria that will be used to

determine significance. Such criteria often include the

types of impact; the magnitude, frequency and duration

of the impact; regulatory status, and other factors.

Consider the questions on the following page for

identifying and characterizing aspects and impacts.

• Various approaches exist for evaluating environmental

aspects and impacts. Select one that can be readily

adapted for your use and that makes sense for your

organization. Examples of approaches for evaluating

environmental aspects and impacts can be found in the

Tool Kit (see Appendix A).

• Once you’ve found a process that works for your

organization, describe the process in the form of a

written procedure. A sample procedure for performing

the assessment is provided in the Tool Kit.

• You can start out with a simple process for identifying

aspects and impacts, then refine the process in the

future as needed. You also can identify and consider

more obvious environmental impacts or “low hanging

fruit” first, then enhance the assessment process to

consider more complex environmental impacts later. As

with any element of the EMS, there is virtue in

considering how your process for identifying aspects

and impacts might be improved over time. Ask yourself:

Is there additional information we should consider in this

process? Do we have the right people involved? Are

we using the results in a meaningful way?

• Use the worksheet at the end of this section to capture

some of your ideas. Using this worksheet will give you

a “jump start” on implementing this EMS element.

In evaluating your

environmental

aspects and impacts,

consider both normal

and abnormal (such

as start-up and

shutdown) operating

conditions.
Do

Check

Act

 Plan

© 2001 NSF 23

Sec. 4

Identifying Aspects and Impacts: Some Questions to Consider:

Identifying Aspects

q Which operations and activities interface with

the environment in a way that could result (or

has resulted) in environmental impacts?

q What materials, energy sources and other

resources do we use in our work?

q Do we have emissions to the air, water or

land?

q Do we generate wastes, scrap or off-spec

materials? If so, does the treatment of

disposal of these materials have potential

environmental impacts?

q Which characteristics or attributes of our

products or services could result in impact the

environment (through their intended use, endof-life management, etc.)?

q Does our land or infrastructure (e.g.,

buildings) interact with the environment?

q Which activities (for example, chemical

storage) might lead to accidental releases?

Evaluating Impacts

q Are the impacts actual or potential?

q Are the impacts beneficial or damaging to the

environment?

q What is the magnitude or degree of these

impacts?

q What is the frequency or likelihood of these

impacts?

q What is the duration and geographic area of

these impacts?

q Which parts of the environment might be

affected (e.g., air, water, land, flora, fauna)?

q Is the impact regulated in some manner?

q Have our interested parties expressed

concerns about these impacts?

The Link Between Aspects and Impacts (some examples from a real company)

Aspects Potential Impacts

Emissions of volatile organic

compounds

Increase in ground level ozone

Discharges to stream Degradation of aquatic habitat and drinking

water supply

Spills and leaks Soil and groundwater contamination

Electricity use Air pollution, global warming

Use of recycled paper Conservation of natural resources

Some Potential Environmental Aspect Categories:

• Air Emissions

• Solid and Hazardous Wastes

• Contamination of Land

• Local Issues

(e.g. noise, odor, dust, traffic, etc.)

• Water Discharges

• Energy Use

• Raw Material and Resource Use

(water, energy, etc.)

• Hazardous Material Storage and Handling
Do

Check

Act

 Plan

© 2001 NSF 24

Sec. 4

Capture the Learning: Environmental Aspects Worksheet

Do we have an existing process for

identifying aspects and/or impacts?

If yes, does that process need to be

revised? In what way?

Who needs to be involved in this

process within our organization?

Should any outside parties be

involved?

When is the best time for us to

implement this process? Can it be

linked to an existing organizational

process (such as our budget, annual

planning or auditing cycles?)

What are some obvious

environmental aspects of our:

F Operations and activities?

F Products?

F Services?

What sources of information can we

use to identify environmental aspects?

What sources of information can be

used to determine the environmental

impacts of these aspects?

What significance criteria might make

sense for our organization?

How will we keep this information upto-date?

Our next step on environmental

aspects is to ...
Do

Check

Act

 Plan

© 2001 NSF 25

Sec. 4

Legal and Other Requirements

Setting the legal framework for your EMS

Legal requirements include:

 • Federal requirements

 • State and local requirements

• Standards in locations where

you sell products/services

• Permit conditions

Other requirements might

include ( for example):

 • Company-specific codes

 • International Chamber of

Commerce (ICC) Charter

for Sustainable

Development

 • American Chemistry

Council’s (ACC)

Responsible Care

 • American Petroleum

Institute’s Strategies for

Today’s Environmental

Partnership (API STEP)

 • Other industry codes or

programs to which your

organization voluntarily

subscribes.

In order to comply with laws and regulations that apply to

your organization, you must first know what the rules

are and how they affect what you do. As discussed

earlier, compliance with legal requirements is one of the

“three pillars” upon which your environmental policy

should be based. The potential costs of non-compliance

(possible damage to the environment, revenue loss and

impact on public image, for example) can be very high.

Thus, an effective EMS should includes processes to:

• identify and communicate applicable legal and

other requirements, and;

• ensure that these requirements are factored into the

organization’s management efforts.

New or revised legal requirements might require

modification of your environmental objectives or other

EMS elements. By anticipating new requirements and

making changes to your operations, you might avoid

some future compliance obligations and their costs.

Getting Started

Your EMS should include a procedure for identifying,

having access to and analyzing applicable legal and

other requirements. “Other requirements” might include

industry codes of practice or similar requirements to

which your organization might subscribe.

Identifying applicable regulations, interpreting them, and

determining their impacts on your operations can be a

time-consuming task. Fortunately, there are many

methods for obtaining information about applicable laws

or regulations. These methods include:

• commercial services (with updates offered on-line, on

CD-ROM or in paper form);

• regulatory agencies (federal, state and local);

• trade groups / associations;

• the Internet (see USEPA web site at www.epa.gov);

• public libraries;

• seminars and courses;

• newsletters / magazines;

• consultants and attorneys; and

• customers, vendors and other companies.

Small business assistance programs exist in every state.

Under the Clean Air Amendments of 1990, each state

environmental regulatory agency has established

KEY STEPS

 ̨ Identify

Requirements

 ̨ Analyze Impacts

 ̨ Communicate

 ̨ Act
Do

Check

Act

 Plan

© 2001 NSF 26

Sec. 4

For more information on EMS

and compliance, see “Improving

Environmental Performance and

Compliance: Ten Elements of

Effective Environmental

Management Systems” (see

Appendix F for details)

• Environmental Policy

• Objectives & Targets

• Training & Awareness

• Communication

• Operational Controls

See Appendix A for information

on resources for tracking

environmental laws and

regulations.

technical and compliance assistance programs to help

companies comply with air quality rules. In some cases,

these programs have expanded into other environmental

“media”, such as water and waste management. In

addition, National Compliance Assistance Centers can

provide compliance assistance for certain industry

sectors (see Appendix F for more information).

Once applicable requirements have been identified and

analyzed for potential impacts, communicate these

requirements (and plans for complying with them) to

employees, on-site contractors and others, as needed.

Communicating “other applicable requirements” (as well

as their impacts on the organization) is an important but

often overlooked step. Keep in mind that different people

may have different information needs.

As with many EMS elements, this is not a “one time”

activity. Since legal and other requirements change

over time, your process should ensure that you are

working with up-to-date information.

Resources to identify and track environmental laws and

regulations are described in the Tool Kit (Appendix A).

Commonly Applicable Federal Environmental Laws in the US

Clean Air Act (CAA)

[40 CFR Parts 50-99]

Establishes ambient and source emission standards and permit

requirements for conventional and hazardous air pollutants.

Clean Water Act (CWA)

[40 CFR Parts 100-145, 220-232, 410-471]

Establishes ambient and point source effluent standards and

permit requirements for water pollutants, including sources that

discharge directly to a waterbody or to a public sewer system.

Federal Insecticide, Fungicide and

Rodenticide Act (FIFRA)

[40 CFR Parts 150-189]

Establishes a program for Federal review of, registration and

control of pesticides.

Resource Conservation and Recovery

Act (RCRA)

[40 CFR Parts 240-299]

Establishes regulations and permit requirements for hazardous

waste management. Also, creates standards for underground

storage tanks that hold oil or hazardous substances.

Toxic Substances Control Act (TSCA)

[40 CFR Parts 700-799]

Regulates the use, development, manufacture, distribution and

disposal of chemicals. Certain chemicals (such as PCB’s) are

subject to specific management standards.

Comprehensive Environmental

Response, Compensation and Liability

Act (CERCLA, also known as “Superfund”)

[40 CFR Parts 300-311]

Establishes a program for cleaning up contaminated waste sites

and establishes liability for clean-up costs. Also, provides

reporting requirements for releases of hazardous substances

Emergency Planning and Community

Right-To-Know Act (EPCRA)

[40 CFR Parts 350-374]

Establishes a program (also known as the “Toxic Release

Inventory”) to inform the public about releases of hazardous and

toxic chemicals. Reporting requirements apply to companies that

use, process or store specific chemicals over specified quantities.

Hazardous Materials Transportation Act

(HMTA) [49 CFR Parts 100-180]

Establishes standards for the safe transportation of hazardous

materials.
Do

Check

Act

 Plan

© 2001 NSF 27

Sec. 4

Capture the Learning: Legal & Other Requirements Worksheet

Do we have an existing process for

identifying applicable legal and other

requirements?

If yes, does that process need to be

revised? In what way?

Who needs to be involved in this

process within our organization? What

should their responsibilities be?

What sources of information do we

use to identify applicable legal and

other requirements?

Are these sources adequate and

effective? How often do we review

these sources for possible changes?

How do we ensure that we have

access to legal and other

requirements? (List any methods

used, such as on-site library, use of

web sites, commercial services, etc.)

How do we communicate information

on legal and other requirements to

people within the organization who

need such information?

Who is responsible for analyzing new

or modified legal requirements to

determine how we might be affected?

How will we keep information on legal

and other requirements up-to-date?

Our next step on legal and other

requirements is to ...
Do

Check

Act

 Plan

© 2001 NSF 28

Sec. 4

Objectives and Targets

Establishing goals for environmental management

ISO 14001

Objectives and targets help an organization translate

purpose into action. These environmental goals

should be factored into your strategic plans. This can

facilitate the integration of environmental

management with your organization’s other

management processes.

You determine what objectives and targets are

appropriate for your organization. These goals can

be applied organization-wide or to individual units,

departments or functions -- depending on where the

implementing actions will be needed.

In setting objectives, keep in mind your

environmental policy, including its three “pillars.”

You should also consider your significant

environmental aspects, applicable legal and other

requirements, the views of interested parties, your

technological options, and financial, operational,

and other organizational considerations.

There are no “standard” environmental objectives that

make sense for all organizations. Your objectives and

targets should reflect what your organization does,

how well it is performing and what it wants to achieve.

Policy

Environmental

Aspects

Legal / Other

Requirements

Views of

Interested Parties

Objectives

and

Targets

Technology Finance Operations Other

Business

Environmental

Program

Environmental Target:

"Detailed performance

requirement, quantified

where practicable,

applicable to the

organization or parts

thereof, that arises from

the environmental

objectives and that

needs to be set and met

in order to achieve

those objectives?

Environmental Objective:

"Overall environmental

goal, arising from the

environmental policy,

that an organization sets

itself to achieve, and

which is quantified

where practicable."

Figure 6
Do

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Act

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© 2001 NSF 29

Sec. 4

+

A sample process tool and

procedure for setting

objectives and targets are

included in the Tool Kit

(Appendix A).

• Environmental Policy

• Environmental Aspects

• Legal & Other

Requirements

• Structure &

Responsibility

• Operational Control

• Monitoring &

Measurement

• Management Review

Hints:

• Setting objectives and targets should involve people in

the relevant functional area(s). These people should be

well positioned to establish, plan for, and achieve these

goals. Involving people helps to build commitment.

• Get top management buy-in for your objectives. This

should help to ensure that adequate resources are applied

and that the objectives are integrated with other

organizational goals.

• In communicating objectives to employees, try to link

the objectives to the actual environmental

improvements being sought. This should give people

something tangible to work towards.

• Objectives should be consistent with your overall mission

and plan and the key commitments established in your

policy (pollution prevention, continual improvement, and

compliance). Targets should be sufficiently clear to

answer the question: “Did we achieve our objectives?”

• Be flexible in your objectives. Define a desired result,

then let the people responsible determine how to achieve

the result.

• Objectives can be established to maintain current levels

of performance as well as to improve performance. For

some environmental aspects you might have both

maintenance and improvement objectives.

• Communicate your progress in achieving objectives and

targets across the organization. Consider a regular report

on this progress at staff meetings.

• To obtain the views of interested parties, consider

holding an open house or establishing a focus group with

people in the community. These activities can have other

payoffs as well.

• How many objectives and targets should an organization

have? Various EMS implementation projects for small and

medium-sized organizations indicate that it is best to start

with a limited number of objectives (say, three to five) and

then expand the list over time. Keep your objectives

simple initially, gain some early successes, and then build

on them.

• Make sure your objectives and targets are realistic.

Determine how you will measure progress towards

achieving them.

• Keep in mind that your suppliers (of service or materials)

can help you in meeting your objectives and targets (e.g.,

by providing more “environmentally friendly” products).

Factors to consider

in setting objectives

and targets

 ̨ ability to control

 ̨ ability to track /

measure

 ̨ cost to track /

measure

 ̨ progress reporting

 ̨ links to policy

commitments
Do

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© 2001 NSF 30

Sec. 4

Comparing Objectives and Targets - Some Examples

Objectives Targets

Reduce energy usage • Reduce electricity use by 10% in 2001

• Reduce natural gas use by 15% in 2001

Reduce usage of hazardous chemicals • Eliminate use of CFCs by 2002

• Reduce use of high-VOC paints by 25%

Improve employee awareness of

environmental issues

• Hold monthly awareness training courses

• Train 100% of employees by end of year

Improve compliance with wastewater

discharge permit limits

• Zero permit limit violations by the end of

2001

PP POLLUTION PREVENTION PP

Pfizer Global Research & Development (formerly Warner-Lambert Parke-Davis) has

a pollution prevention program that shows that improving the environment and the

bottom line can go hand-in-hand. For example:

♦ By replacing chillers and redesigning chilling systems to be more efficient, the

company has realized $250,000 in energy savings. Also, because the company is

more energy efficient, it has reduced emissions from its local power supplier.

♦ By redesigning and modifying its dust collection system, the company replaced its

100-hp motors with 40 hp motors, without compromising the effectiveness of the

dust collection system. This project lowered the company’s operating costs and

reduced emissions at the local power plant.

PP POLLUTION PREVENTION PP

Some Motorola manufacturing sites have reduced their water consumption and

wastewater discharges by greater than 95% by installing ion exchange technology

and employing better operating techniques. These changes have lowered usage of

water treatment chemicals and have resulted in considerable cost savings.

EPA’s Performance Track program requires organizations to consider the

following factors in setting measurable objectives and targets:

• Prevention of noncompliance,

• Prevention of pollution at the source

• Minimization of cross-media pollutant transfers, and

• Environmental performance improvement.

Participating organizations also must show continued improvement in specific

environmental categories, such as energy use, water discharges, or waste

generation, among others.

See Appendix B for more information.
Do

Check

Act

 Plan

© 2001 NSF 31

Sec. 4

Capture the Learning: Objectives and Targets Worksheet

Do we have an existing process for

setting and reviewing environmental

objectives and targets?

If so, does that process need to be

revised? In what way(s)?

Who needs to be involved in this

process within our organization?

Should any outside parties be

involved?

When is the best time for us to

implement this process? Can it be

linked to another existing

organizational process (like our annual

or strategic planning process?)

What are our existing environmental

goals? How were these developed?

Who was involved?

What factors were considered in

setting these goals?

Who are our interested parties?

How do we obtain their views?

How effective has our process been?

How can we effectively and efficiently

track our progress and communicate

the results?

Who is in the best position to do this?

Our next step on environmental

objectives and targets is to ...
Do

Check

Act

 Plan

© 2001 NSF 32

Sec. 4

Environmental Management Program(s)

A road map for achieving environmental goals

At St. Joseph’s Mercy

Hospital (in Michigan),

mercury was in widespread

use. The Hospital had a

contract with a professional

environmental response

company to clean up and

dispose of any discarded

equipment and waste that

resulted from mercury spills.

Mercury was identified as

an environmental aspect

during EMS implementation,

leading to the development

of a Mercury Reduction

Initiative. This Initiative is

expected to save the

Hospital as much as

$20,000 per year.

So far, this Guide has focused on the foundations of an

EMS -- the planning elements. An important part of this

planning effort is defining what your organization intends to

achieve in the environmental area. To achieve your

objectives and targets, you need an action plan -- also

known as an environmental management program.

Your environmental management program should be linked

directly to your objectives and targets — that is, the

program should describe how the organization will translate

its goals and policy commitments into concrete actions

so that environmental objectives and targets are achieved.

To ensure its effectiveness, your environmental

management program should define:

• the responsibilities for achieving goals (who will do it?)

• the means for achieving goals (how will they do it?)

• the time frame for achieving those goals (when?)

Keep in mind that your program should be a dynamic one.

For example, consider modifying your program when:

• 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); or

• your products, services, processes, or facilities change

or other issues arise.

Your action plan need not be compiled into a single

document. A “road map” to several action plans is an

acceptable alternative, as long as the key responsibilities,

tactical steps, resource needs and schedules are defined

adequately in these other documents.

This program should not be developed in a vacuum — it

should be coordinated or integrated with other

organizational plans, strategies, and budgets. For

example, if you are planning for a major expansion in one of

your service operations, then it makes sense to look at the

possible environmental issues associated with this

operational expansion at the same time.

+

Hints:

• Build on the plans and programs you have now for

compliance, health & safety or quality management.

• Involve your employees early in establishing and

carrying out the program.

• Clearly communicate the expectations and

Objectives and

Targets

Established

Environmental

Management Program

Defined

Monitoring and

Measurement
Do

Check

Act

 Plan

© 2001 NSF 33

Sec. 4

Charlie Saunders, EMS Manager,

Pfizer Global Research &

Development

responsibilities defined in the program to those who need

to know.

• In some cases, your environmental management

program may encompass a number of existing

operating procedures or work instructions for

particular operations or activities. In other cases, new

operating procedures or work instructions might be

required to implement the program.

• Re-evaluate your action plan when you are considering

changes to your products, processes, facilities or

materials. Make this re-evaluation part of your change

management process.

• Keep it simple (see sample tool, below) and focus on

continual improvement of the program over time.

• There may be real opportunities here! Coordinating

your environmental program with your overall plans and

strategies may position your organization to exploit some

significant cost-saving opportunities.

• Objectives & Targets

• Structure &

Responsibility

• Communication

• Operational Control

• Monitoring &

Measurement

.

Figure 7: Environmental Management Program (Sample Form)

Objective / Target #1: _____

Action

Items

Priority Responsibilities Schedule Resources

Needed

Comments

A full-size copy of

this form and

another sample

form are provided in

the Tool Kit (see

Appendix A).

PP POLLUTION PREVENTION PP

March Coatings operated a de-ionization unit to purify water for its coating process.

While effective, the unit required 39,000 pounds of hydrochloric acid to operate.

Concerns about potential spills and worker health & safety impacts led the company

to replace the de-ionizer with a reverse osmosis unit, which completely eliminated the

use of hydrochloric acid.

“Before, we focused on

compliance issues without

the benefit of an EMS.

Now, we have a strategic

plan in place to look beyond

legal requirements and save

money. It makes my job

easier when I can prove my

department does not have

to be a cost center.”
Do

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Act

 Plan

© 2001 NSF 34

Sec. 4

Capture the Learning: Environmental Management Programs Worksheet

Do we have an existing process for

establishing environmental

management programs?

If yes, does that process need to be

revised? In what way?

What environmental management

programs do we have in place now?

What is the basis for our

environmental management programs

(for example, do they consider our

environmental objectives, our

environmental policy commitments and

other organizational priorities)?

Who needs to be involved in the

design and implementation of these

programs within our organization?

When is the best time for us to

establish and review such programs?

Can this effort be linked to an existing

organization process (such as our

budget, planning or auditing cycles?)

How do we ensure that changes to

products, processes, equipment and

infrastructure are considered in our

programs?

How will we otherwise keep our

programs up-to-date?

Our next step on environmental

management programs is to ...
Do

Check

Act

 Plan

© 2001 NSF 35

Sec. 4

Structure and Responsibility

Aligning your resources to succeed

 - ISO 14001

For an EMS to be effective, roles and responsibilities

must be clearly defined and communicated. The

commitment of all employees is needed for an EMS to

live up to its full potential.

Top management plays a key role by providing

resources needed to implement the EMS. This is one of

the most important jobs of top management (see “Finding

Resources” on next page). In some organizations, “top

management” might be a single individual, while in others

it might be a group of people (such as a board of

directors).

An effective management system needs an advocate.

Thus, top management should appoint a management

representative. This representative (1) ensures that

the EMS is established and implemented; (2) reports on

its performance over time; and (3) works with others to

modify the EMS as needed. The management

representative can be the same person who serves as

the project champion (as discussed in Section 3), but

this is not mandatory. A business owner, plant or shop

manager, or any number of other people might serve as

an effective EMS management representative.

Small and medium-sized organizations may have

advantages over larger ones in structuring their

resources for environmental management. Because

personnel and other resources are generally more

limited in smaller organizations, people often “wear more

than one hat” and have experience in performing

multiple functions. An individual responsible for

environmental management in a smaller organization

also might be responsible for quality, health & safety,

facilities, or other functions. In such cases, integrating

environmental responsibilities with other functions can

be greatly simplified.

Getting Started:

The following questions can help you determine the right

organizational structure for environmental management:

• What is the scope of our environmental

management program? What capabilities do we

need? Who will help to make the EMS effective?

What training or other resources do we need?

• What are our significant environmental aspects

and compliance needs? What operations / activities

need to be controlled? Who needs to be involved to

ensure that controls are implemented?

Getting Started

Look at:

 ̨ Program Scope

 ̨ Environmental

Aspects

 ̨ Objectives

 ̨ Previous audits

 ̨ Other systems

"Resources include human

resources and specialized

skills, technology, and

financial resources."

Characteristics of a

good management

representative:

• Knowledgeable

• Assertive

• Independent

More organizational

advantages of small business:

 ̨ shorter lines of

communication

 ̨ less complex organization

 ̨ limited delegation

 ̨ simpler access to

management
Do

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© 2001 NSF 36

Sec. 4

See Appendix C for information

on process mapping

What are the results of previous audits or other

assessments? What does this information tell us

about the effectiveness of our organizational structure

and how it might be improved?

• What are the current responsibilities for

environmental management? How can we

enhance ownership of environmental management

across the organization? How can other functions

support the EMS? (See next page.)

• What are our objectives and targets, including

those related to compliance and pollution

prevention? How will the organizational structure

help up achieve these goals?

• What quality management and / or other existing

management systems exist? What roles and

responsibilities exist in these management systems?

Do opportunities for system integration exist?

Consider flow charting your existing environmental

management activities. This can help you understand

how these processes work and the final product can be

a great communication and training tool. Flow charts

also can be useful to look at processes such as

chemical purchasing and distribution, employee

training, and preventive maintenance, among others.

Appendix C provides information on process mapping.

Appendix A provides a sample

+

responsibility matrix

Hints:

• Build flexibility into your organizational structure.

Recognize that environmental (and other)

management needs will change over time.

• Communicate to people what their roles are (as well

as the roles of others). One tool for communicating

these responsibilities is a responsibility matrix.

(See the Tool Kit in Appendix A for an example of

such a matrix.)

More information on resources

is found in Appendix F of this

Guide

• Objectives & Targets

• Training & Awareness

• Communication

• Management Review

Finding Resources

In most cases, developing and maintaining an EMS will

not require large capital outlays. What an EMS will

require is time. Many smaller organizations find they

can make effective use of interns or temporary

employees to perform potentially time-consuming EMS

development tasks (such as collecting data, drafting

procedures, etc.). This allows in-house personnel to

focus on more complex EMS development tasks. Also,

look for areas where environmental management can

support other organizational functions (and vice-versa —

see next page).

Consider integrating EMS

with your existing:

 ̨ information systems

 ̨ purchasing controls

 ̨ quality procedures

 ̨ work instructions

 ̨ training programs

 ̨ communication efforts

 ̨ reporting systems

 ̨ recruitment, appraisal

and disciplinary

processes
Do

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© 2001 NSF 37

Sec. 4

How Various Functions Can Support Your EMS

Functions How They Can Help (Possible Roles)

Purchasing • Develop and implement controls for chemical / other material

purchases

Human Resources • Define competency requirements and job descriptions for

various EMS roles

• Train temporary workers and contractors; maintain training

records

• Integrate environmental management into reward, discipline

and appraisal systems

Maintenance • Implement preventive maintenance program for key

equipment

• Support identification of environmental aspects

Finance • Track data on environmental-related costs (such as

resource, material and energy costs, waste disposal costs,

etc.)

• Prepare budgets for environmental management program

• Evaluate economic feasibility of environmental projects

Engineering • Consider environmental impacts of new or modified products

and processes

• Identify pollution prevention opportunities

Top Management • Communicate importance of EMS throughout organization

• Provide necessary resources

• Track and review EMS performance

Quality • Support document control, records management and

employee training efforts

• Support integration of environmental and quality

management systems

Line Workers • Provide first-hand knowledge of environmental aspects of

their operations

• Support training for new employees

For EPA’s Performance Track program, organizations must provide

appropriate incentives for personnel to meet EMS requirements.

See Appendix B for more information.

See the EPA/NSF project report, Implementing an EMS in Community-Based

Organizations for more ideas on how organizations with limited resources can

implement an EMS. Download the report free of charge at www.nsf-isr.org or

www.epa.gov.
Do

Check

Act

 Plan

© 2001 NSF 38

Sec. 4

Capture the Learning: Structure & Responsibility Worksheet

How do we define roles,

responsibilities and authorities for

environmental management now?

Is this process effective?

Who is / should be our EMS

Management Representative? Does

this individual have the necessary

authority to carry out the

responsibilities of this job?

Are our key roles and responsibilities

for environmental management

documented in some manner? If so,

how (e.g., job descriptions,

organizational charts, responsibility

matrix, etc.)?

How are EMS roles and responsibilities

communicated within our

organization?

How do we ensure that adequate

resources have been allocated for

environmental management? How is

this process integrated with our overall

budgeting process?

How are environmental expenditures

tracked?

How will we keep this information upto-date?

Our next step on structure and

responsibility is to ...
Do

Check

Act

 Plan

© 2001 NSF 39

Sec. 4

Training, Awareness and Competency

Building internal capabilities

Implementing and

maintaining an EMS

involves everyone

Here are two excellent reasons for training employees

about environmental management and your EMS:

• Every employee can have potential impacts on the

environment, and

• Any employee can have good ideas about how to

improve environmental management efforts.

Each person and function within your organization can

play a role in environmental management. For this

reason, your training program should cast a wide net.

Every employee and manager should be aware of the

environmental policy, the significant environmental

impacts of their work activities, key EMS roles and

responsibilities, procedures that apply to their work and

the importance of conformance with EMS requirements.

Employees also should understand the potential

consequences of not following EMS requirements

(such as spill, releases, fines or other penalties).

All personnel should receive appropriate training. Such

training should be tailored to the different needs of

various levels or functions in the organization.

However, training is just one element of establishing

competence, which is typically based on a combination

of education, training, and experience. For certain jobs

(particularly tasks that can cause significant

environmental impacts), you should establish criteria to

measure the competence of individuals performing

those tasks.

An example of a trainin log

is provided in the Tool Kit

(see Appendix A)

• Environmental Aspects

• Legal/Other

Requirements

• Structure &

Responsibility

• Operational Control

• Records

Getting Started:

• A critical first step in developing your training

program is assessing your training and skill

needs. In assessing these needs, you should

consider both general and specific needs (e.g.,

“What EMS procedures affect Joe’s daily work and

what happens if they aren’t followed?” “What

environmental impacts might Joe’s work cause?”

“What broader understanding of environmental

issues and our EMS does Joe need?”)

• Look at the training you conduct already, for

compliance with environmental and health and

safety regulations and other purposes. You may

find that your existing training efforts go a long way

towards satisfying the requirements for the EMS.

Competence might be established on the basis of

regulatory-required training, in some instances.

Reasons for

Training:

 ̨ motivation

 ̨ awareness

 ̨ commitment

 ̨ skills /

capability

 ̨ compliance

 ̨ performance
Do

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© 2001 NSF 40

Sec. 4

Milan Screw Products found

that it could provide a great

deal of its training during

“brown bag” lunches, during

which employees bring their

lunches, participate in a

training session, and remain

“on the clock” for the lunch

period.

Key Steps in Developing a Training Program

Step 1: Assess training needs & requirements

Step 2: Define training objectives

Step 3: Select suitable methods and materials

Step 4: Prepare training plan (who, what, when,

where, how)

Step 5: Conduct training

Step 6: Track training (and maintain records)

Step 7: Evaluate training effectiveness

Step 8: Improve training program (as needed)

 +

Hints:

• Because of the level of effort involved in training, this

is one EMS element where you don’t want to start

from scratch. Many employees may be qualified on

the basis of their experience and previous training.

(Keep in mind that all training should be

documented.) Since some employees might require

training on how to operate equipment safely, on-thejob training certainly can play an important role.

Computer-based training also may be an option,

especially for employees who spend much of their

time in the field.

• Plan and schedule training opportunities carefully.

While finding enough time for training can be a

challenge, you might find creative ways to make

“more time” (see “tip”, above left). Use safety

meetings, staff meetings, and tool box meetings to

provide training and reinforce key messages.

• New employees can pose a significant training

challenge. Consider developing an EMS training

package for new employee orientation. Even

better, videotape one of your current EMS training

courses to show to new employees.

• In reviewing training needs, don’t forget to consider

the qualifications and training needs of your

environmental manager and your trainers.

Professional certification programs may be

appropriate for certain functions.

• If the organization uses temporary or contract

workers, assess their training needs as well.

• Factor EMS skills requirements into your recruiting,

selection, and new employee orientation

processes.

Training Resources:

 ̨ internal trainers / experts

 ̨ consultants

 ̨ community colleges

 ̨ vendors / suppliers

 ̨ customers

 ̨ technical / trade /

business associations

 ̨ self-study or study

groups

 ̨ training consortia

(teaming with other local

companies)

 ̨ computer-based training
Do

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© 2001 NSF 41

Sec. 4

• Establishing competency for various tasks can be a

challenge. Competency criteria for jobs that can

cause significant environmental impacts should be as

objective as possible.

One informal method for assessing competency is to

question employees in critical functions as to how

they perform various aspects of their jobs (e.g.,

“Show me how you...”). Use responses to determine

whether they have the requisite skills and

understanding to perform the job safely. This can

help you gauge whether additional training might be

needed.

• Consider visual “job aids” to supplement training or

help establish competence. Examples of job aids

include written or pictorial job procedures, decision

tables or flow charts posted at the workstation.

• Finally, some organizations have been successful in

blending environmental awareness training into

existing safety training programs. This can be

particularly effective where safety training is

mandated (i.e., by regulation or other organizational

requirements) and has strong management support.

For EPA’s Performance Track, organizations must provide specific training for

employees whose responsibilities relate directly to achieving objectives and targets

and legal compliance.

See Appendix B for more information.

When Training

Might Be Needed:

 ̨ New employee is hired

 ̨ Employee is transferred to a

new job

 ̨ Individual doesn't follow

procedure / instruction

 ̨ Procedures are changed

 ̨ New process, material or

equipment is introduces

 ̨ Company changes objectives

and/or targets

 ̨ New regulation affects

organization's activities

 ̨ Job performance must be

improved

A Few Thoughts About Adult Learning

• Adults need the opportunity to integrate new ideas with what they already know.

• Information that conflicts sharply with existing beliefs or has little conceptual

overlap with what is already known is acquired more slowly.

• Adults prefer self-directed learning and want to have a hand in shaping the

training program.

• Adults have expectations. It is important to clarify these up-front.

• Adults prefer active participation to straight lecture.

- Adapted from “Adults Learning: What Do We Know For Sure”

 (Training Magazine, June 1995)
Do

Check

Act

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© 2001 NSF 42

Sec. 4

Capture the Learning: Training, Awareness & Competence Worksheet

Do we have an existing process for

environmental training?

If so, does that process need to be

revised? In what way(s)?

What types of training do we provide

now (e.g., new employee orientation,

contractor training, safety training)?

How would EMS-related training fit with

our existing training program?

Who is responsible for training

now? Who else might need to be

involved within our organization?

How do we determine training needs

now? (List methods used) Are these

processes effective?

Who is responsible for ensuring that

employees receive appropriate

training? How do we track training to

ensure we are on target?

How do we evaluate training

effectiveness? (List methods used,

such as course evaluation, posttraining testing, behavior observation)

How do we establish competency,

where needed? (List methods used,

such as professional certifications)

What are the key job functions and

activities where we need to ensure

environmental competency?

Our next step on training,

awareness & competence is to ...
Do

Check

Act

 Plan

© 2001 NSF 43

Sec. 4

Communications

Maintaining the flow of information

Pfizer Global Research &

Development (formerly

Warner-Lambert ParkeDavis) has hosted local

community leaders, state

agencies, and federal

agencies, to share its

environmental activities and

programs and to obtain

feedback.

The importance of employee involvement in developing

and implementing your EMS has been discussed earlier.

In addition, there may be parties with an interest in your

environmental performance and management efforts

outside the organization. Effective environmental

management requires effective communications, both

internally and externally.

Effective communications will help you:

• motivate your workforce;

• gain acceptance for your plans and efforts;

• explain your environmental policy and EMS and how

they relate to the overall organizational vision;

• ensure understanding of roles and expectations;

• demonstrate management commitment;

• monitor and evaluate performance; and,

• identify potential system improvements.

Effective internal communication requires mechanisms for

information to flow top-down, bottom-up and across

functional lines. Since employees are on the “front lines,”

they can be an excellent source of information, issues,

concerns and ideas.

Proactive, two way communication with external parties is

also important for an effective environmental management

system. Taking steps to obtain the views of these

stakeholders, which can include neighbors, customers,

community groups, and regulators, will help you better

understand how your organization is perceived by others.

These stakeholders can also bring important

environmental issues to your attention that should be

addressed in your EMS. Your should also condiser ways

to get specific advice from these stakeholders when

developing critical elements of your EMS such as setting

objectives and targets. Involving these parties, however,

does not mean you should cede control of your EMS to

them, but rather use their input to make your EMS

stronger and more responsive to community concerns.

Doing so will usually provide long-term benefits to your

organization.

Thus, an effective EMS should include procedures for:

• communicating internally (between levels and

functions within the organization), and

 • soliciting, receiving, documenting and responding to

external communications.

Consider

communication

strategies for:

 ̨ neighbors

 ̨ community groups

 ̨ other interest groups

 ̨ local officials

 ̨ regulatory agencies

 ̨ emergency

responders
Do

Check

Act

 Plan

© 2001 NSF 44

Sec. 4

Milan Screw Products’ staff

interviewed neighbors,

customers, suppliers, and

employees’ family members to

obtain the views of external

parties.

Getting Started:

The first step in designing a communications program is

determining your key audiences. Make a list of internal

and external audiences.

Once you have identified the audiences, determine what

you need to communicate to them. (What do they need to

know about your products, operations or management

efforts? What are their concerns?)

A sample procedure for

external communication is

provided in the Tool Kit (see

Appendix A)

Next, decide how you can best reach them. Appropriate

communication methods might vary from audience to

audience. Start by looking at your existing methods for

communicating, both internally and externally. These

might include:

Internal Methods

• newsletters

• intranet

• staff meetings

• employee meetings

• bulletin boards

• brown bag lunches

• training

External Methods

• open houses

• focus or advisory groups

• web site or e-mail list

• press releases

• annual reports

• advertising

• informal discussions

+

• Environmental Policy

• Environmental

Aspects

• Objectives & Targets

• Structure &

Responsibility

• Monitoring &

Measurement

• Management Review

Hints:

• Determine how proactive your external communications strategy

should be. Select an approach that fits your organization’s

culture and strategy. Consider, for example, whether reporting

on environmental performance and progress might give you a

competitive edge.

• While a proactive external communications program may require

some resources, many organizations find that a proactive

communication strategy can be beneficial. Weigh the costs and

benefits for yourself, but keep in mind that you might have many

interested audiences.

• In communicating with employees, it is helpful to explain not only

what they need to do but also why they need to do it. For

example, when describing a requirement based on a regulation,

explain the purpose behind the rule and why it is important. Also,

make a clear connection between the requirement and how it

applies to each person’s job.

• Keep the message simple, clear, concise, and accurate.

• Managing responses to external inquiries does not have to be

burdensome. Use a simple method, such as stapling an inquiry

to its written response and then filing them together. The key is

to be able to demonstrate that the organization has a process for

gathering and responding to external inquiries.
Do

Check

Act

 Plan

© 2001 NSF 45

Sec. 4

PP POLLUTION PREVENTION PP

and Public Involvement

Motorola has conducted Household Waste Electronics Recycling Days for local residents.

Working in collaboration with local solid waste authorities, the Company has collected for

recycle a variety of home electronic and entertainment equipment, small appliances and other

products. At one of these events, over 21 tons of materials were collected and over 95% of

these materials were recycled.

For EPA’s Performance Track, organizations must commit to public outreach and

performance reporting. Specifically, participating organizations must prepare an

annual report on their EMS, a summary of progress on performance commitments,

and of their public outreach activities.

See Appendix B for more information.

 The community as part of the solution....

In an effort to involve stakeholders in the EMS process the Town of Londonderry, NH and

the City of Lowell, MA engaged residents to collect information pertaining to environmental

issues that affect their communities. For example, the Town of Londonderry, NH in

conjunction with its household hazardous waste collection day, asked residents to complete

a survey to prioritize community related environmental issues. The residents identified the

fast pace at which the small community is growing as their top-priority issue. The City of

Lowell, MA's wastewater treatment plant asked local residents to assist with efforts to

address the plant's odor issues. A number of residents throughout the surrounding area

recorded weather information on days the odor was prevalent. This information identified

odor patterns which would aid the City's efforts to identify a solution to this problem.
Do

Check

Act

 Plan

© 2001 NSF 46

Sec. 4

Capture the Learning: Communications Worksheet

Who are our key external

stakeholders?

How were these stakeholders

identified?

With regard to our organization, what

are the key concerns of these

stakeholders?

How do we know this?

What community outreach efforts

are we making now (or have we made

in the recent past)?

How successful have these efforts

been?

What methods do we use for external

communications? Which appear to be

the most effective?

Who has primary responsibility for

external communications?

How do we gather and analyze

information to be communicated?

Who has responsibility for this?

How do we communicate internally

(as well as with our suppliers and

contractors)? What processes do we

have to respond to internal inquiries,

concerns and suggestions?

How effective are these methods?

Our next step on communication

is to ...
Do

Check

Act

 Plan

© 2001 NSF 47

Sec. 4

EMS Documentation

Describing the EMS and how the pieces fit together

 Easy to read and understand

equals

easy to implement

To ensure that your EMS is well understood and operating

as designed, you must provide adequate information to the

people doing the work. There also may be external parties

that want to understand how your EMS is designed and

implemented, such as customers, regulators, lending

institutions, registrars and the public. For these reasons,

the various processes that make up your EMS should be

documented.

The EMS Manual (or description document)

A “road map” or description that summarizes how the

pieces of the EMS fit together can be a very useful tool.

This roadmap generally takes the form of an EMS manual.

An EMS manual is a series of explanations of the

processes your organization implements to conform to the

EMS criteria (such as the elements discussed in the

Guide). While you don’t need to maintain a single

“manual” that contains all of your EMS documentation, you

should maintain a summary of the EMS that:

• describes the system’s core elements (and how the

elements relate to each other), and

• provides direction to related documentation.

Other EMS Documentation

In addition to the EMS manual, your organization should

maintain other documentation of its EMS.

First, you should document the processes used to meet

the EMS criteria. (For example, “How do we identify

environmental aspects?” “How do we implement

corrective actions?”) This documentation generally takes

the form of system procedures. In addition, you might

maintain area-or activity-specific documentation (such as

work instructions) that instructs employees on how to carry

out certain operations or activities.

EMS documentation is related to (but not the same as)

EMS records. EMS documentation describes what

your system consists of (i.e., what you do and how you do

it), while EMS records demonstrate that you are doing

what the documentation said you would do. Document

control and records management are discussed later in

this Guide.

One way to think about your EMS documentation is to use

the figure shown at left, which also can be applied to

quality or other management system documents.

Rule of thumb:

Try to keep the EMS

description

document (or

manual) to no more

than one page per

EMS element

Figure 8:

Hierarchy of EMS

Documentation

Policy

EMS Manual

Procedures

Forms, Drawings, etc.
Do

Check

Act

 Plan

© 2001 NSF 48

Sec. 4

+

Use flow charts or other

graphics where they help

explain the linkages from one

system element to another

• Environmental Policy

• Environmental

Management

Programs

• Document Control

• Operational Control

You can maintain EMS documentation either on paper or

electronically. There may be some advantages to

maintaining documents electronically, such as ease of

updating, controlling access, and ensuring that all readers

are using the most up-to-date versions of documents.

Hints:

• Keep EMS documentation simple. Choose a format

that works best for your organization. Your manual

does not need to describe every detail of your EMS.

Instead, the manual can provide references to other

documents or procedures.

• Use the results of your preliminary assessment to

prepare your EMS documentation. In the course of

conducting this assessment, you should have collected

or prepared useful material on how your organization

satisfies the selected EMS criteria. The box below

illustrates what constitutes EMS documentation.

• The usefulness of your EMS manual can be improved

by including the organization’s mission statement, vision

or guiding principles (if these exist). These will improve

understanding of the organization and how the EMS

supports its overall goals.

• An EMS manual can be a useful tool for explaining your

EMS to new employees, customers and others. A

sample outline for an EMS manual is provided in the

Tool Kit (see Appendix A).

• EMS documentation should be updated as needed,

based on any system improvements you put in place.

However, if you put too much detail in an EMS manual,

you might need to update the manual frequently (see

first hint, above).

What Constitutes EMS Documentation? Consider the following:

• your environmental policy

• your organizational structure and key responsibilities

• a description or summary of how your organization satisfies EMS requirements

(e.g., “How do we identify environmental aspects?”. “How do we control

documents?” How do we comply with legal requirements?”)

• system-level procedures (e.g., procedure for corrective action)

• activity- or process-specific procedures / work instructions

• other EMS-related documents (such as emergency response plans, training

plans, etc.)
Do

Check

Act

 Plan

© 2001 NSF 49

Sec. 4

Capture the Learning: EMS Documentation Worksheet

Do we have existing documentation

of our EMS?

If yes, how is this EMS documentation

maintained (electronically? In paper

form?)

Who is responsible for maintaining

EMS documentation within our

organization?

Do we have an EMS manual or other

summary document that describes the

key elements of the EMS?

If so, does this document describe the

linkages among system elements?

What does our EMS documentation

consist of? (List components such as

environmental policy, EMS manual,

activity-level procedures or work

instructions, emergency plans, etc.)

Is our EMS documentation integrated

with other organizational

documentation (such as human

resource plans or quality procedures)?

If so, how do we ensure proper

coordination between environmental

and these other functions?

How will we keep our EMS

documentation up-to-date?

Our next step on EMS

documentation is to ...
Do

Check

Act

 Plan

© 2001 NSF 50

Sec. 4

Document Control

Ensuring that everyone works with the right tools

 Document control

should address:

• Preparation

• Issuance / distribution

• Revision

• Periodic review

• Disposition of obsolete

documents

People in your organization probably use various

documents (procedures, work instructions, forms,

drawings and the like) as they perform their duties. To

ensure that personnel are consistently performing their

jobs in the right way, the organization must provide them

with the proper tools. In the context of an EMS, the “tools”

needed are correct and up-to-date procedures,

instructions and other documents. Without a mechanism

to manage these EMS documents, the organization cannot

be sure that people are working with the right tools.

To ensure that everyone is working with the proper EMS

documents, your organization should have a procedure

that describes how such documents are controlled.

Implementation of this procedure should ensure that:

• EMS documents can be located (we know where to

find them),

• they are periodically reviewed (we check to make sure

they are still valid),

• current versions are available where needed (we make

sure the right people have access to them), and

• obsolete documents are removed (people don’t use the

wrong documents by mistake).

Your procedure should designate responsibility and

authority for preparing documents, making changes to

them and keeping them up-to-date. In other words, you

need to make it clear who can actually generate and

change documents and the process for doing so.

Getting Started:

• EMS document control requirements are almost a

mirror image of the ISO 9001 requirements.

Organizations that have or are developing an ISO 9001

management system can enjoy some advantages here.

• Even if your organization doesn’t have an ISO 9001

system, you might be better off than you think. Your

organization probably has document controls in place

for other purposes (such as finance, human resources

or purchasing). Assess how well these controls work

and if they can be adapted for your EMS.

Key Questions:

Is everyone working with

the same set of

documents?

Do people who need

access have access?

Suggested elements

of document control

 ̨ issue / revision date

 ̨ effective date

 ̨ approval

(i.e., signature)

 ̨ revision number

 ̨ document number

(or other identifier

 ̨ copy number

 ̨ cross references
Do

Check

Act

 Plan

© 2001 NSF 51

Sec. 4

+

• EMS Documentation

• Operational Control

• Records

The Tool Kit contains a sample

index of EMS-controlled

documents (see Appendix A).

Hints:

• Don’t make your procedure more complicated than it

needs to be. While larger organizations often have

complex processes for document control, smaller

organizations can use simpler processes.

• Limiting distribution can make the job easier. Could

everyone have access to one or a few copies?

Determine how many copies you really need and

where they should be maintained for ease of access.

• If the people that need access to documents are

connected to a local area network or have access to

the organization’s internal web site, consider using a

paperless system. Such systems can facilitate control

and revision of documents considerably. There also

are a number of commercial software packages that

can simplify the document control effort.

• Prepare a document control index that shows all of

your EMS documents and the history of their revision.

Include this index in your manual. Also, if multiple

paper copies of documents are available at the facility,

prepare a distribution list, showing who has each copy

and where the copies are located.

• As your procedures or other documents are revised,

highlight the changes (by underlining, boldface, etc.).

This will make it easier for readers to find the changes.

What EMS documents should be controlled?

Consider the following:

 ̨ Environmental policy

 ̨ Objectives and targets

 ̨ Roles, responsibilities and authorities

 ̨ EMS description document (“manual”)

 ̨ System-level procedures

 ̨ Process- or activity-level procedures / work instructions

 ̨ Related plans (such as emergency response plans)
Do

Check

Act

 Plan

© 2001 NSF 52

Sec. 4

Capture the Learning: Document Control Worksheet

Do we have an existing process for

controlling EMS documents?

If yes, does that process need to be

revised? In what way?

Who needs to be involved in this

process within our organization?

Who needs access to controlled

copies of EMS documents? How do

we ensure that they have access?

How do we ensure that EMS

documents are periodically reviewed

and updated as necessary?

Who has authority to generate new

documents or modify existing ones?

How is this process managed?

How are users alerted to the

existence of new EMS documents or

revisions to existing ones?

How do we ensure that obsolete

documents are not used?

Is our EMS document control process

integrated with other organizational

functions (such as quality)?

If so, how do we ensure proper

coordination between environmental

and other functions?

Our next step on document

control is to ...
Do

Check

Act

 Plan

© 2001 NSF 53

Sec. 4

Operational Control

Building environmental performance into operations and activities

Figure 9 To ensure that you satisfy the commitments in your

environmental policy, certain operations and activities

must be controlled. Where operations or activities are

complex and/or the potential environmental impacts are

significant, controls should include documented

procedures. Procedures can help your organization to

manage its significant environmental aspects, ensure

regulatory compliance and achieve environmental

objectives. Procedures can also play a prominent role in

employee training.

Documented procedures should be established where the

absence of procedures could lead to deviations from the

environmental policy (including the commitments to

compliance and pollution prevention) or from your

objectives and targets. Determining which operations

should be covered by documented procedures and how

those operations should be controlled is a critical step in

designing an effective EMS. Keep in mind that you might

need operational controls in order to manage significant

aspects or legal requirements, regardless of whether you

established objectives and targets for each of them.

In determining which operations and activities need to be

controlled, look beyond routine production or service.

Activities such as equipment maintenance, management

of on-site contractors, and services provided by

suppliers or vendors could affect your organization’s

environmental performance significantly.

Getting Started:

• Start by looking at the environmental aspects and

legal requirements that you identified earlier. Identify

the operations and other activities that are related to

these significant impacts and legal requirements, then

consider what types of controls might be needed to

manage these aspects and compliance requirements. If

you have flow charts of these processes (or can

develop them), this may simplify the identification of the

process steps where some type of control might be

appropriate.

• Prepare draft procedures and review them with the

people who will need to implement them. This will help

to ensure that the procedures are appropriate, realistic

and practical. Don’t be surprised if reviewers come up

with a simpler way to achieve the same results!

Environmental

Policy

Significant

Environmental

Aspects

Operational

Controls

Objectives &

Targets

Examples of activities and

operations that might require

operational controls:

 ̨ management / disposal of

wastes

 ̨ approval of new chemicals

 ̨ storage & handling of raw

materials and chemicals

 ̨ equipment servicing

 ̨ wastewater treatment

 ̨ operation of paint line

 ̨ operation of plating system

 ̨ management of contractors

Legal & Other

Requirements
Do

Check

Act

 Plan

© 2001 NSF 54

Sec. 4

+

Hints:

• Review procedures you already have in place to comply

with environmental and health & safety regulations.

Some of these may be adequate to control significant

impacts (or could be modified to do so). Develop a chart

to keep track of what controls are needed, such as:

Operation or

Activity

Procedure is

needed (none

exists)

Procedure

exists, but is not

documented

Procedure

exists and is

documented

No procedure

is needed

1 X

2 X

3 X

4 X

• Rules of Thumb: In general, the more highly skilled and trained

your employees are, the less critical documented work instructions

become. As work becomes more complex or as the potential

impact on the environment increases, the more important these

documented work instruction will be.

• Once you have identified operations that require control, consider

what kinds of maintenance and calibration may be appropriate.

Maintenance of equipment that could have significant

environmental impacts or result in non-compliance should be

considered, and the need for a plan to manage such maintenance

should not be overlooked. An elaborate preventive or predictive

maintenance program is not needed in all cases. Assess your

existing maintenance program and its effectiveness before making

significant changes.

Hints on Writing Procedures

• Understand the existing process. Start with a flow

chart, if one is available. Build on informal procedures

where possible.

• Focus on steps needed for consistent implementation.

• Use a consistent format and approach.

• Review draft procedures with employees that will have

to implement them. (Better yet, enlist employees to

help write them.)

• Keep procedures simple and concise. Excessive detail

does not provide better control and can confuse the

user.

Factors that could affect

the need for documented

procedures

 ̨ risk of activity

 ̨ complexity of activity /

methods

 ̨ degree of supervision

 ̨ skills / training of

workforce
Do

Check

Act

 Plan

© 2001 NSF 55

Sec. 4

• Policy

• Environmental

Aspects

• Legal/Other

Requirements

• Objectives &

Targets

• Training

• Monitoring &

Measurement

• Some of your identified environmental aspects may relate

to the chemicals, raw materials, or other goods and

services you obtain from vendors/suppliers. Likewise,

the activities of your contractors can affect your

environmental performance. Communicate your

expectations (including any relevant procedures) to these

business partners.

• While the development of procedures can be timeconsuming, organizations have come up with creative

ways to reduce the burden. For example, consider using a

college intern or temporary employee to interview

employees “on the line”, collecting information on what

employees do and how they do it.

• If your organization uses a “work team” concept, ask the

work teams to draft procedures for their work areas (or to

modify existing procedures for EMS purposes).

For EPA’s Performance Track program, organizations must have operation and

maintenance programs for equipment and operations that relate to legal compliance

and significant environmental aspects.

See Appendix B for more information.

PP POLLUTION PREVENTION PP

Rochester Midland Corporation, a manufacturer of cleaning and

other chemical products, formed a partnership with a cleaning

contractor that uses Rochester Midland’s products, the owners of a

building where the products are used, and building tenants, to lessen

the risks associated with cleaning products. The partners began by

developing common goals, identifying alternative cleaning products and

processes, and identifying opportunities to reduce risks to building

occupants and cleaning staff. Over a two-month period, they were able

to: reduce chemical exposures; improve tenant satisfaction; improve

communication, awareness, and training; achieve a 50% reduction in

cleaning products; and achieve measurable cost savings.
Do

Check

Act

 Plan

© 2001 NSF 56

Sec. 4

Capture the Learning: Operational Controls Worksheet

Have we identified operations and

activities associated with significant

environmental aspects, legal

requirements and environmental

objectives?

If not how will this be accomplished?

Who should be involved?

What operations and activities are

associated with significant

environmental aspects?

What operations and activities are

associated with legal requirements?

What operations and activities are

associated with environmental

objectives and targets?

How are the above operations and

activities controlled? (list methods)

How do we know whether these

controls are adequate (i.e., to

manage significant aspects, to ensure

compliance, to achieve objectives?

How do we train employees and

contractors on relevant operating

controls?

If new controls are needed (or

existing ones need to be revised),

what is our process for doing so?

Who needs to be involved in this

process?

Our next step on operational

control is to ...
Do

Check

Act

 Plan

© 2001 NSF 57

Sec. 4

Emergency Preparedness and Response

Minimizing the impacts of uncontrolled events

Don’t think only about

response – focus on how

to prevent accidents in the

first place

Review prior accidents

and incidents as one

guide to where future

incidents may occur.

Despite an organization’s best efforts, the possibility of

accidents and other emergency situations still exists.

Effective preparation and response can reduce

injuries, prevent or minimize environmental impacts,

protect employees and neighbors, reduce asset losses

and minimize downtime.

An effective emergency preparedness and response

program should include provisions for:

• assessing the potential for accidents and

emergencies;

• preventing incidents and their associated

environmental impacts;

• plans / procedures for responding to incidents;

• periodic testing of emergency plans / procedures;

and,

• mitigating impacts associated with these incidents.

Consistent with the focus on continual improvement, it

is important to review your emergency response

performance after an incident has occurred. Use this

review to determine if more training is needed or if

emergency plans / procedures should be revised.

Getting Started:

• This is another area where you should not have to start

from scratch. Several environmental and health and

safety regulatory programs require emergency plans

and/or procedures. Look at what you have now and

assess how well it satisfies the items discussed above.

• Two planning components that many organizations

overlook are how they identify the potential for

accidents and emergencies and how they mitigate

the impacts of such incidents. A cross-functional

team (with representatives from engineering,

maintenance and environmental health & safety, for

example) can identify most potential emergencies by

asking a series of “what if” questions related to

hazardous materials, activities, and processes

employed at the site. In addition to normal operations,

the team should consider start-up and shutdown of

process equipment, and other abnormal operating

conditions.

 USEFUL INFORMATION

SOURCES:

• Material safety data sheets

• Plant layout

• Process flow diagrams

• Engineering drawings

• Design codes and

standards

• Specifications on safety

systems (alarms,

sprinklers, etc.)
Do

Check

Act

 Plan

© 2001 NSF 58

Sec. 4

• Environmental Aspects

• Legal/Other

Requirements

• Training & Awareness

• Communication

• Document Control

• Ask yourself: Does everyone (including new

employees) know what to do in an emergency? How

would contractors or site visitors know what to do in an

emergency situation?

• Communicate with local officials (fire department,

hospital, etc.) about potential emergencies at your site

and how they can support your response efforts.

+

Hints:

• Mock drills can be an excellent way to reinforce

training and get feedback on the effectiveness of your

plans / procedures.

• Post copies of the plan (or at least critical contact

names and phone numbers) around the site and

especially in areas where high hazards exist. Include

phone numbers for your on-site emergency

coordinator, local fire department, local police, hospital,

rescue squad, and others as appropriate.

• Revise and improve your plan as you learn from

mock drills, training or actual emergencies.

Checklist for Emergency Preparedness and Response Plans

Does your plan describe the following:

 ̨ potential emergency situations (such as fires, explosions, spills or releases of hazardous

materials, and natural disasters)?

 ̨ hazardous materials used on-site (and their locations)?

 ̨ key organizational responsibilities (including emergency coordinator)?

 ̨ arrangements with local emergency support providers?

 ̨ emergency response procedures, including emergency communication procedures?

 ̨ locations and types of emergency response equipment?

 ̨ maintenance of emergency response equipment?

 ̨ training / testing of personnel, including the on-site emergency response team (if

applicable)?

 ̨ testing of alarm / public address systems?

 ̨ evacuation routes and exits (map), and assembly points?
Do

Check

Act

 Plan

© 2001 NSF 59

Sec. 4

Capture the Learning: Emergency Preparedness & Response Worksheet

Have we reviewed our operations

and activities for potential emergency

situations?

If not how will this be accomplished?

Who should be involved?

Do our existing emergency plans

describe how we will prevent incidents

and associated environmental

impacts?

If not how will this be accomplished?

Who should be involved?

Have we trained personnel on their

roles and responsibilities during

emergencies?

What emergency equipment do we

maintain? How do we know that this

equipment is adequate for our needs?

How do contractors and other

visitors know what to do in an

emergency situation?

When was our last emergency drill? Is

there a plan / schedule for conducting

future drills?

Have we established a feedback loop

so we can learn from our experiences?

Our next step on emergency

preparedness & response is to ...
Do

Check

Act

 Plan

© 2001 NSF 60

Sec. 4

Monitoring and Measurement

Assessing how well the system is performing

- Peter Drucker

Management Expert

An EMS without effective monitoring and measurement

processes is like driving at night without the headlights on

—you know that you are moving but you can’t tell where

you are going! Monitoring and measurement enables an

organization to:

• evaluate environmental performance;

• analyze root causes of problems;

• assess compliance with legal requirements;

• identify areas requiring corrective action, and,

• improve performance and increase efficiency.

In short, monitoring helps you manage your

organization better. Pollution prevention and other

strategic opportunities are identified more readily when

current and reliable data is available.

Your organization should develop procedures to:

• monitor key characteristics of operations and

activities that can have significant environmental

impacts and/or compliance consequences;

• track performance (including your progress in

achieving objectives and targets);

• calibrate and maintain monitoring equipment; and,

• through internal audits, periodically evaluate your

compliance with applicable laws and regulations.

Getting Started:

• Monitoring and measuring can be a resource-intensive

effort. One of the most important steps you can take is

to clearly define your needs. While collecting

meaningful information is clearly important, resist the

urge to collect data “for data’s sake.”

• Review the kinds of monitoring you do now for

regulatory compliance and other purposes (such as

quality or health and safety management). How well

does this serve your EMS purposes? What additional

monitoring or measuring might be needed?

• You can start with a relatively simple monitoring and

measurement process, then build on it as you gain

experience with your EMS.

“If you can’t

measure it, you

can’t manage it.”

What are the key

characteristics of these

operations and activities?

Attributes of effective

measurement programs

 ̨ simple

 ̨ flexible

 ̨ consistent

 ̨ ongoing

 ̨ produce reliable data

 ̨ communicate results

Which operations and

activities can have

significant environmental

impacts?

How do we measure

these characteristics?
Do

Check

Act

 Plan

© 2001 NSF 61

Sec. 4

+

EPA policies provide

incentives for effective

compliance management

programs. See “Incentives for

Self-Policing: Discovery,

Disclosure, Correction and

Prevention of Violations"

(http://es.epa.gov/oeca/finalpo

lstate.pdf) and “Small

Business Compliance Policy”

(http://es.epa.gov/oeca/sbcp

2000.pdf)

Employees should have a

mechanism to report

regulatory violations (or other

EMS issues) without fear of

retaliation by their employer

Hints:

• Monitoring key process characteristics: Many

management theorists endorse the concept of the “vital

few” — that is, that a limited number of factors can have

a substantial impact on the outcome of a process. The

key is to figure out what those factors are and how to

measure them. Process mapping can help you

determine what those factors might be.

• Most effective environmental measurement systems

use a combination of process and outcome measures.

Outcome measures look at results of a process or

activity, such as the amount of waste generated or the

number of spills that took place. Process measures

look at “upstream” factors, such as the amount of paint

used per unit of product or the number of employees

trained on a topic. Select a combination of process and

outcome measures that are right for your organization.

• Equipment calibration: Identify process equipment

and activities that truly affect your environmental

performance. As a starting point, look at those key

process characteristics you identified earlier. Some

organizations place critical monitoring equipment under

a special calibration and preventive maintenance

program. This can help to ensure accurate monitoring

and make employees aware of which instruments are

most critical for environmental monitoring purposes.

Some organizations find it is more cost-effective to

subcontract calibration and maintenance of monitoring

equipment than to perform these functions internally.

• Regulatory compliance: Determining your compliance

status on a regular basis is very important. You should

have a procedure to systematically identify, correct,

and prevent violations. Effectiveness of the

compliance assessment process should be considered

during EMS management review. EPA encourages

“systematic discovery” of regulatory violations, which

means detecting potential violations through

environmental audits or compliance management

systems that show due diligence in preventing,

detecting and correcting violations.

Focus on things that you

can do something about

• Operational performance: Consider what information

you will need to determine if the company is

implementing operational controls as intended. The

example on Page 62 illustrates the relationship among

monitoring and measurement, operational controls and

significant environmental aspects.

• Progress on meeting objectives: You should measure

progress on achieving objectives and targets on a

regular basis and communicate the results of such

measurement to top management. To measure

progress in meeting objectives, select appropriate

performance indicators (see below).
Do

Check

Act

 Plan

© 2001 NSF 62

Sec. 4

• Environmental Aspects

• Legal/Other

Requirements

• Objectives & Targets

• Operational Control

• Corrective Action

• Management Review

The value of periodic monitoring:

St. Joseph’s Mercy Hospital

noticed an increase in its

discharge of silver to the local

wastewater treatment plant. They

investigated what had changed at

the Hospital and found that a new

x-ray processor had been installed

without a silver recovery system.

Once the recovery system was

installed, silver discharge levels

returned to permitted levels.

• Selecting performance indicators: Performance

indicators can help you to understand how well your

EMS is working. Start by identifying a few performance

indicators that are:

- simple and understandable;

- objective;

- measurable; and

- relevant to what your organization is trying to

achieve (i.e., its objectives and targets)

Data collected on performance indicators can be quite

helpful during management reviews. So, select

indicators that will provide top management with the

information it needs to make decisions about the EMS.

Make sure you can commit the necessary resources

to track performance information over time. It is OK to

start small and build over time as you gain experience

in evaluating your performance. Keep in mind that no

single measurement will tell your organization how it

is doing in the environmental area.

• Communicating performance: People respond best

to information that is meaningful to “their world.”

Putting environmental information in a form that is

relevant to their function increases the likelihood

they will act on the information. Be sure to link your

measurement program with your communications

program and other elements of the EMS (such as

management reviews, as discussed later).

• Compliance auditing guidance: The USEPA has

prepared guidance documents and protocols for

conducting environmental compliance audits under a

number of its regulatory programs. For more

information, check the EPA web site at

www.epa.gov/oeca/index.html.

PP POLLUTION PREVENTION PP

A Pitney Bowes Inc. facility formed a Zero Discharge Task Team to design

projects to reduce emissions over a five-year period. Wastes were ranked

ordered in terms of their potential risks to the environment and employee

safety. Those with high rankings were evaluated on a priority basis.

Through the implementation of many projects, the facility has reduced

hazardous waste generation by 69%, EPCRA 313 air emissions by 98%

and treated wastewater by 93%. Projects included finding substitutes for

parts cleaning and degreasing, replacement of all cyanide processes, and

installation of fume scrubbers on plating lines, among others.
Do

Check

Act

 Plan

© 2001 NSF 63

Sec. 4

Figure 10:

Linking Monitoring Processes to Operational Controls: One Example

Operation with

Significant

Environmental

Aspect

Operational

Controls

Key Characteristics

of Operation

or Activity

Monitoring or

Measurement

Methods

Equipment

Calibration

Needs

Surface

Coating

Operation

(significant

aspect is VOC

emissions)

• Approved list

of coatings

• Coating work

instruction

• Permit report

procedure

• Type of

coating

• Rate of

application

• Frequency

of

application

• Emissions

of VOCs

• Compare to

approved list

• Measure

quantity applied

• Use coating

 log book

• Calculate

based on use

• None

• Flow meter

• None

• Flow meter

Liquid

Waste

Storage

(significant

aspect is

potential for

spills)

• Generator

• procedure

• Storage

area procedure

• Use of proper

containers

• Segregation

of

incompatibles

• Availability of

spill equipment

• Inspections of

storage area

• Inspections of

storage area

• Inspections of

storage area

• None

• None

• None

Examples of EMS Performance Indicators

 ̨ Pounds of VOC emitted per unit of production

 ̨ Pounds of hazardous waste generated per year

 ̨ Percentage of employees completing environmental training

 ̨ Average time for resolving nonconformities

 ̨ Energy use per unit of production

 ̨ Percentage of solid waste recycled / reused
Do

Check

Act

 Plan

© 2001 NSF 64

Sec. 4

Capture the Learning: Monitoring and Measurement Worksheet

Have we identified operations and

activities associated with significant

environmental aspects, legal

requirements and environmental

objectives? If, not how will this be

accomplished?

What type(s) of monitoring and

measurement do we need to ensure

that operational controls are being

implemented correctly?

What type(s) of monitoring and

measurement do we need to ensure

that we are complying with applicable

legal requirements?

What type(s) of monitoring and

measurement do we need to ensure

that we are achieving our

environmental objectives & targets?

How do we identify the equipment

used for any of the monitoring or

measurement listed above? If not how

will this be accomplished?

How will we ensure that monitoring and

measurement equipment is properly

calibrated and maintained?

What process do we have to

periodically evaluate compliance with

legal requirements? How effective is

this process?

Our next step on monitoring and

measurement is to ...
Do

Check

Act

 Plan

© 2001 NSF 65

Sec. 4

Nonconformance and Corrective / Preventive Action

Fixing EMS problems – and avoiding them in the future

No EMS is perfect. You will probably identify problems

with your system (especially in the early phases) through

audits, measurement, or other activities. In addition, your

EMS will need to change as your organization changes

and grows. To deal with system deficiencies, your

organization needs a process to ensure that:

• problems (including nonconformities) are identified

and investigated;

• root causes are identified;

• corrective and preventive actions are identified and

implemented; and,

• actions are tracked and their effectiveness is

verified.

EMS nonconformities and other system deficiencies

(such as legal noncompliance) should be analyzed to

detect patterns or trends. Identifying trends allows you

to anticipate and prevent future problems.

Focus on correcting and preventing problems.

Preventing problems is generally cheaper than fixing

them after they occur (or after they reoccur). Start

thinking about problems as opportunities to improve!

 = System Improvement

 +

Hints:

• If your organization has an ISO 9001 management

system, you should already have a corrective and

preventive action process for quality purposes. Use

this as a model (or integrate with it) for EMS purposes.

• Some organizations find that they can combine some

elements of their management review and corrective

action processes. These organizations use a portion of

their management review meetings to review

noncomformities, discuss causes and trends, identify

corrective actions and assign responsibilities.

"Nonconformance"

means...

• system does not meet

the EMS criteria

-- or --

• implementation is not

consistent with the

EMS description

Key Steps

 ̨ identify the problem

 ̨ investigate to identify

the root cause

 ̨ come up with solution

 ̨ implement solution

 ̨ document solution

 ̨ communicate solution

 ̨ evaluate effectiveness

of solution

Figure 11: Management

Review

System

Audits

Corrective

Action
Do

Check

Act

 Plan

© 2001 NSF 66

Sec. 4

• Legal & Other

Requirements

• Operational

Control

• Monitoring &

Measurement

• EMS Audits

• Management Review

• The amount of planning and documentation needed for

corrective & preventive actions will vary with the

severity of the problem and its potential environmental

impacts. Don’t go overboard with bureaucracy —

simple methods often work quite effectively.

• Once you document a problem, the organization must

be committed to resolving it in a timely manner. Be

sure that your corrective & preventive action process

specifies responsibilities and schedules for

completion. Review your progress regularly and follow

up to ensure that actions taken are effective.

• Make sure your actions are based on good information

and analysis of causes. While many corrective actions

may be “common sense,” you need to look beneath

the surface to determine why problems occur. Many

organizations use the term “root cause” in their

corrective and preventive action processes. While this

term can be used to describe a very formal analysis

process, it can also mean something simpler – looking

past the obvious or immediate reason for a

nonconformance to determine why the nonconformance

occurred.

• Rule of thumb: Corrective actions should (1) resolve

the immediate problem (2) consider whether the same

or similar problems exist elsewhere in the organization,

and (3) prevent the problem from recurring. The

corrective action process also should define the

responsibilities and schedules associated with these

three steps.

• Initially, most EMS problems may be identified by your

internal auditors. However, over the long run, many

problems and good ideas may be identified by the

people doing the work. This should be encouraged.

Find ways to get employees involved in the system

improvement process (for example, via suggestion

boxes, contests or incentive programs).

Why do EMS problems

occur?

Typical causes include:

 ̨ poor communication

 ̨ faulty or missing procedures

 ̨ equipment malfunction

(or lack of maintenance)

 ̨ lack or training

 ̨ lack of understanding

(of requirements)

 ̨ failure to enforce rules

 ̨ corrective actions fail to

address root causes of

problems
Do

Check

Act

 Plan

© 2001 NSF 67

Sec. 4

People doing the

work are often in

the best position

to see problems

and suggest

solutions

The Tool Kit

contains a sample

corrective action

procedure and

tracking log

(see Appendix A)

Audits Monitoring Other

Sources

Employee

Suggestions

Sources

of change

Corrective 

Action

Process

Management

Review

Investigate and

recommend

solutions

Institutionalize

Change Figure 12

PP POLLUTION PREVENTION PP

By switching from a solvent-based paint that contained lead to a no

lead, low-solvent, water-based paint, March Coatings dramatically

decreased its volatile organic compound (VOC) air emissions from over

19 tons in 1995 to less than 6 tons in 1999 while simultaneously

increasing production. The company went from being a large quantity

generator of hazardous waste to small quantity generator status under

RCRA. March Coatings accomplished this by working closely with its

paint supplier to find a formula that met their needs.
Do

Check

Act

 Plan

© 2001 NSF 68

Sec. 4

Capture the Learning: Corrective & Preventive Action Worksheet

Do we have an existing process for

corrective and preventive action?

If yes, does that process need to be

revised? In what way?

Who needs to be involved in this

process within our organization?

How are nonconformities and other

potential system deficiencies

identified? (List methods such as

audits, employee suggestions, ongoing

monitoring, etc.)

How do we determine the causes of

nonconformities and other system

deficiencies? How is this information

used?

How do we track the status of our

corrective and preventive actions?

How is / can information on

nonconformities and corrective actions

be used within the EMS (for example,

in management review meetings, in

employee training sessions, in review

of procedures, etc.)

How do we ensure the effectiveness

of our corrective and preventive

actions?

Our next step on corrective and

preventive action is to ...
Do

Check

Act

 Plan

© 2001 NSF 69

Sec. 4

Records

Evidence that the EMS is working as intended

The value of records management is fairly simple — you

should be able to demonstrate that your organization is

actually implementing the EMS as designed. While

records have value internally, over time you may need to

provide evidence of EMS implementation to external

parties (such as customers, a registrar, or the public).

Records management is sometimes seen as

bureaucratic, but it is difficult to imagine a system

operating consistently without accurate records.

The basics of records management are straightforward:

you need to decide what records you will keep, how you

will keep them and for how long. You should also think

about how you will dispose of records once you no

longer need them.

If your organization has an ISO 9001 (or other)

management system, you should have a process in place

for managing records. This process could be adapted for

EMS purposes.

+

Records should be

important to the operation

of the EMS, including your

regulatory compliance

efforts.

Hints:

• Start by identifying what EMS records are required. Look

at your other procedures and work instructions to determine

what evidence is needed to demonstrate implementation.

Also consider records that are required by various legal

requirements.

• Focus on records that add value — avoid bureaucracy. If

records have no value or are not specifically required, don’t

collect them. The records you choose to keep should be

accurate and complete.

• You may need to generate certain forms in order to

implement your EMS. When these forms are filled out, they

become records. Forms should be simple and

understandable for the users.

• Establish a records retention policy and stick to it. Make sure

that your policy takes into account records retention

requirements specified in applicable environmental

regulations.

• In designing your records management process, be sure to

consider:

- who needs access?

- to what records?

- in what circumstances?

What are “records”?

Records provide evidence

that the processes that

make up your EMS are

being implemented as

described.
Do

Check

Act

 Plan

© 2001 NSF 70

Sec. 4

• If your organization uses computers extensively,

consider using an electronic EMS records management

system. Maintaining records electronically can provide

an excellent means for rapid retrieval of records as well

as controlling access to sensitive records.

• Think about which records might require additional

security. Do you need to restrict access to certain

records? Should a back-up copy of critical records be

maintained at another location?

Virtually every element

of an EMS can result in

the generation of

records

The Tool Kit contains a tool

for organizing your filing

system (see Appendix A).

You can copy the pages, cut

out the tabs, and use them to

set up your filing system.

Types of Records You Might Maintain (Examples):

• legal, regulatory and other code requirements

• results of environmental aspects identification

• reports of progress towards meeting objectives and

targets

• permits, licenses and other approvals

• job descriptions and performance evaluations

• training records

• EMS audit and regulatory compliance audit reports

• reports of identified nonconformities, corrective

action plans and corrective action tracking data

• hazardous material spill / other incident reports

• communications with customers, suppliers,

contractors and other external parties

• results of management reviews

• sampling and monitoring data

• maintenance records

• equipment calibration records

Capture the Learning: Records Management Worksheet

Have we identified what records

need to be maintained? Where is this

defined?

Have we determined records retention

times? Where is this defined?

Have we established an effective

storage and retrieval system?

Our next step on records is to ...

Key Questions

 ̨ what records are kept?

 ̨ who keeps them?

 ̨ where are they kept?

 ̨ how are they kept?

 ̨ how long are they kept?

 ̨ how are they accessed?

 ̨ how are they disposed?
Do

Check

Act

 Plan

© 2001 NSF 71

Sec. 4

EMS Auditing

Objective evidence of conformance with EMS requirements

Once your organization has established its EMS, verifying

the implementation of the system will be critical. To

identify and resolve EMS deficiencies you must actively

seek them out.

In a smaller organization, periodic audits can be

particularly valuable. Managers are often so close to the

work performed that they may not see problems or bad

habits that have developed. Periodic EMS audits will

help determine whether all of the requirements of the

EMS are being carried out in the specified manner.

For your EMS audit program to be effective, you should:

• develop audit procedures and protocols;

• determine an appropriate audit frequency;

• select and train your auditors; and,

• maintain audit records.

Results of your EMS audits should be linked to the

corrective and preventive action process, as described

earlier.

While they can be time-consuming, EMS audits are

critical to EMS effectiveness. Systematic identification

and reporting of EMS deficiencies to management

provides a great opportunity to:

• maintain management focus on the environment,

• improve the EMS and its performance, and

• ensure the system’s cost-effectiveness.

 - ISO 14001

Getting Started:

• How frequently do we need to audit?

To determine an appropriate frequency of your EMS

audits, consider the following factors:

- the nature of your operations and activities,

- your significant environmental aspects / impacts

(which you identified earlier),

- the results of your monitoring processes, and

- the results of previous audits.

As a rule of thumb, all parts of the EMS should be audited

at least annually. You can audit the entire EMS at one

time or break it down into discrete elements for more

frequent audits. (There may be advantages to

conducting frequent audits, but the decision is up to you).

EMS Audit

"A systematic and

documented verification

process of objectively

obtaining and evaluating

evidence to determine

whether an organization's

environmental

management system

conforms to the

environmental

management system

audit criteria set by the

organization, and for

communication of the

results of this process to

management.

Audits are vital to

continual

improvement

of your EMS
Do

Check

Act

 Plan

© 2001 NSF 72

Sec. 4

• Who will perform the audits? You should select and

train EMS auditors. Auditor training should be both

initial and ongoing. Commercial EMS auditor training

is available, but it might be more cost-effective to link up

with businesses or other organizations in your area

(perhaps through a trade association) to sponsor an

auditor training course. Some local community colleges

also offer EMS auditor training courses.

Auditors should be trained in auditing techniques and

management system concepts. Familiarity with

environmental regulations, facility operations, and

environmental science can be a big plus, and in some

cases may be essential to adequately assess the EMS.

Some auditor training can be obtained on-the-job.

Your organization’s first few EMS audits can be

considered part of auditor training, but make sure that

an experienced auditor leads or takes part in those

“training” audits.

Auditors should be independent of the activities

being audited. This can be a challenge for small

organizations. See the box on next page for ideas.

If your company is registered under ISO 9001, consider

using your internal quality auditors as EMS auditors.

While some additional training might be needed for

EMS auditing, many of the required skills are the same.

• How should management use audit results?

Management can use EMS audit results to identify

trends or patterns in EMS deficiencies. The

organization also should ensure that identified system

gaps or deficiencies are corrected in a timely fashion

and that corrective actions are documented.

+

Hints:

• Your EMS audits should focus on objective evidence

of conformance. During an audit, auditors should

resist the temptation to evaluate, for example, why a

procedure was not followed — that step comes later.

• During an audit, auditors should review identified

deficiencies with people who work in the relevant

area(s). This will help the auditors verify that their

audit findings are correct. This also can reinforce

employee awareness of EMS requirements.

• If possible, train at least two people as internal

auditors. This will allow your auditors to work as a

team. It also allows audits to take place when one

auditor has a schedule conflict, which is often

unavoidable in a smaller organization!

Audit procedures should

describe:

 ̨ audit planning

 ̨ audit scope (areas and

activities covered)

 ̨ audit frequency

 ̨ audit methods

 ̨ key responsibilities

 ̨ reporting mechanisms

 ̨ recordkeeping

Traits of a good

auditor:

 ̨ Independent

(of the activity

being audited

 ̨ Objective

 ̨ Impartial

 ̨ Tactful

 ̨ Attentive to detail

Sources of Evidence

 ̨ interviews

 ̨ document review

 ̨ observation of

work practices
Do

Check

Act

 Plan

© 2001 NSF 73

Sec. 4

Results of regulatory

compliance audits are often

good indicators of EMS

deficiencies. Use

compliance audit findings to

guide your EMS efforts

The Tool Kit includes a sample

EMS audit procedure, sample

EMS audit questions, and a

number of sample audit forms

(see Appendix A)

• Structure & Responsibility

• Training & Awareness

• Corrective Action

• Management Review

Options for Auditor Independence

- Barter for audit services with other small organizations

in your area

- Use external auditors

- Have office personnel audit production areas

(and vice versa)

• Before you start an audit, be sure to communicate

the audit scope, criteria, schedule, and other pertinent

information to the people in the affected area(s). This

helps to avoid confusion and facilitate the audit

process.

• Consider integrating your EMS and regulatory

compliance audit processes, but keep in mind that

these audit processes have different purposes. While

you might want to communicate the results of EMS

audits widely within your organization, the results of

compliance audits might need to be communicated in a

more limited fashion.

• Final thought: An EMS audit is a check on how well

your system meets your own established EMS

requirements. An EMS audit is not an assessment of

how well employees do their jobs. Auditors should

avoid the “gotcha” mentality. Audits should be judged

on the quality of findings, rather than on the number of

findings.

Even if you have an

effective internal audit

program, consider periodic

external audits to ensure

objectivity

Figure 13:

Linkages among EMS audits, corrective action and

management reviews

EMS

Established

Management

Reviews

Periodic

EMS Audits

Corrective Action

Process
Do

Check

Act

 Plan

© 2001 NSF 74

Sec. 4

Capture the Learning: EMS Auditing Worksheet

Have we developed an EMS audit

program? If not, how will this be

accomplished?

Who need to be involved in the audit

process?

Is there another audit program with

which our EMS audits could be linked

(for example, our quality or health &

safety management system audits)?

Have we determined an appropriate

audit frequency? What is the basis

for the existing frequency? Should the

frequency of audits be modified?

Have we selected EMS auditors?

What are the qualifications of our

auditors?

What training has been conducted or

is planned for our EMS auditors?

Have we conducted EMS audits as

described in the audit program?

Where are the results of such audits

described?

How are the results of EMS audits

communicated to top management?

How are the records of these audits

maintained?

Our next step on EMS auditing

 is to ...
Do

Check

Act

 Plan

© 2001 NSF 75

Sec. 4

Management Review

Closing the continual improvement loop

Just as a person should have periodic physical exams,

your EMS must be reviewed periodically by top

management to stay “healthy”. Management reviews are

one key to continual improvement and for ensuring that

the EMS will continue to meet your organization’s needs

over time.

Management reviews also offer a great opportunity to

keep your EMS efficient and cost-effective. For

example, some organizations have found that certain

procedures and processes initially put in place were not

needed to achieve their environmental objectives or to

control key processes. If EMS procedures and other

activities don’t add value, eliminate them.

The key question that a management review seeks to

answer:

“Is the system working?” (i.e., is it suitable,

adequate and effective, given our needs?)

+

Milan Screw Products

The Tool Kit contains a

sample Management Review

procedure.

(See Appendix A)

Hints:

• Two kinds of people should be involved in the

management review process:

- people who have the right information / knowledge,

- people who can make decisions about the

organization and its resources (top management).

• Determine management review frequency that will

work best for your organization. Some organizations

combine these reviews with other meetings (such as

director meetings). Other organizations hold “standalone” reviews. At a minimum, consider conducting

management reviews at least once per year.

• During management review meetings, make sure that

someone records what issues were discussed, what

decisions were arrived at, and what action items were

selected. Results of management reviews should be

documented.

• Management reviews should assess how changing

circumstances might influence the suitability,

effectiveness or adequacy of your EMS. Changing

circumstances might be internal to your organization

(such as new facilities, new raw materials, changes in

products or services, new customers, etc.) or might be

external factors (such as new laws, new scientific

information or changes in adjacent land use).

"Many of the benefits

of an EMS cannot be

anticipated

beforehand. You will

have to discover them

as pleasant surprises

at some point after

implementation. They

will be there.

An effective EMS

is one that:

 ̨ meets the

organization’s

needs

 ̨ produces results

 ̨ conforms to EMS

criteria

 ̨ has staying power
Do

Check

Act

 Plan

© 2001 NSF 76

Sec. 4

• After documenting the action items arising from your

management review, be sure that someone follows-up.

Progress on action items should be tracked to

completion.

• As you assess potential changes to your EMS, consider

other organizational plans and goals. In this way,

environmental decision-making can be integrated into

your overall management and strategy.

Consider holding

management review meetings

"after hours" to minimize

disruption of work.

All elements of the

EMS should be

considered as part

of Management

Review

Management Review: Questions to Ponder

• Did we achieve our objectives and targets? If not,

why not? Should we modify our objectives?

• Is our environmental policy still relevant to what we do?

• Are roles and responsibilities clear, do they make

sense and are they communicated effectively?

• Are we applying resources appropriately?

• Are our procedures clear and adequate? Do we need

other controls? Should we eliminate some of them?

• Are we fixing problems when we find them?

• Are we monitoring our EMS (e.g., via system audits)?

What do the results of those audits tell us?

• What effects have changes in materials, products, or

services had on our EMS and its effectiveness?

• Do changes in laws or regulations require us to

change some of our approaches?

• What other changes are coming in the near term?

What impacts (if any) will these have on our EMS?

• What stakeholder concerns have been raised since

our last review? How are concerns being addressed?

• Is there a better way? What can we do to improve?

Information sources to

consider:

 ̨ Audit results

 ̨ Internal suggestions

 ̨ External communications

 ̨ Progress on objectives

and targets

 ̨ Other environmental

performance measures

 ̨ Reports of emergencies,

spills, other incidents

 ̨ New or modified

legislation and

regulations

 ̨ New scientific / technical

data on materials and

processes used by the

organization

YOU SHOULD NOW UNDERSTAND ALL OF

THE ELEMENTS OF AN EFFECTIVE EMS !!

NOW YOU'RE READY TO "GO"! (See next section)

Smaller organizations often favor employee experience over written procedures and

documented systems. However, personnel turnover without documented systems can

stall progress. When the manager of the Washtenaw County Home Toxics Reduction

Program took over his position, there had been a six-month gap since his predecessor

had left and very little in place to tell him what to do, whom to contact, or what the

history of the program was. Having an EMS can facilitate a smooth transfer of

responsibilities for environmental management.

The Washtenaw County Home Toxics Reduction Program (HTRP) successfully
Do

Check

Act

 Plan

© 2001 NSF 77

Sec. 4

Capture the Learning: Management Review Worksheet

Do we have an existing process for

conducting management reviews?

If yes, does that process need to be

revised? In what way?

Who needs to be involved in this

process within our organization?

When is the best time for us to

implement this process? Can this

effort be linked to an existing

organization process (such as our

budget, annual planning or auditing

cycles?)

How frequently are management

reviews? What is the basis for this

frequency?

Should we conduct reviews more or

less frequently?

Who is responsible for gathering the

information needed to conduct

management reviews? Who is

responsible for presenting this

information?

How do we ensure that changing

circumstances (both internal and

external to the organization) are

considered I this process?

How do we ensure that the

recommendations of management

reviews are tracked and acted upon?

Our next step on management

review is to ...
© 2001 NSF 78

Sec. 5

Section 5 : GO! (Roadmap for EMS Development)

A sequence of activities for building an EMS from the ground up

Ford Motor Company

conducted ISO 14001

implementation

workshops for its

suppliers. Part of these

workshops was devoted

to a discussion of how to

“launch” the EMS effort

through a set of

implementation steps.

The Washtenaw County

Home Toxics Reduction

Program (HTRP)

successfully linked its

management review

process with its new

Business Improvement

Process (BIP). HTRP used

its environmental objectives

as input to the BIP and

reviewed progress annually

to determine what worked

and to make adjustments,

where needed. The output

of BIP will feed into the

County’s budgeting

process.

Once you gain an understanding the individual elements of

an EMS, you can begin the process of putting these

elements in place. Each of the individual EMS elements

is described in detail in Section 4. Also, several “up front”

EMS planning tasks (such as gaining top management

commitment) were described in Section 3.

Experience of many organizations shows that the order in

which EMS implementation activities should take place is

not always obvious or intuitive. Further, the optimal

sequence of implementation activities does not

necessarily follow the order in which elements are

described in various EMS models, such as ISO 14001.

Using a logical sequence can save time and money and

minimize the “false starts” an organization might make.

This section provides a step by step action plan for

developing and implementing the elements of an EMS. It

describes a logical sequence or “roadmap” for planning

and implementing EMS elements and explains how this

sequence can be important in building an effective EMS.

Keep in mind that this is just one way to do the job– you

might find other approaches that work just as well.

Figure 14 illustrates the suggested implementation

process flow. Each of the steps (and a rationale for their

sequence) is discussed below.

A few hints to keep in mind as you build your EMS:

• You may already have some EMS elements in

place, as indicated by the preliminary review that

you performed earlier (see Section 3 for more

details).

• Make sure to build in the links between elements.

Refer back to Section 4 for information on the key

links. The effectiveness of your EMS depends as

much on the strength of its links as it does on the

strength of the individual elements themselves.

• For many EMS elements, you will need to design

and implement a process. In these cases, you

also should consider documenting the process in

the form of a procedure.
© 2001 NSF 79

Sec. 5

Identify

Legal & Other

Requirements

Identify & Evaluate

Environmental

Aspects, Related

Operations & Activities

Define Views

of Interested

Parties

Prepare

Environmental

Policy

Define Key

Roles and

Responsibilities

Establish

Objectives

& Targets

Identify

Operational

Controls

Environmental

Management

Programs

Identify

Monitoring &

Measurement

Needs

Define

Job-Specific

Roles and

Responsibilities

Prepare

EMS

Documentation

(manual)

Conduct Specific

Employee Training

Conduct

Internal

EMS Audits

Conduct

Management

Reviews

Establish

Other

System-Level

Procedures

Initial

Employee

Awareness

Establish

Operational

Controls &

Monitoring

Processes

Figure 14: GO!

Establish

Procedures for

Corrective/

Preventive

Action,

Document

Control &

Records

Management
© 2001 NSF 80

Sec. 5

Creating Your EMS: Step by Step

A first step in the EMS-building process is understanding the

legal and other requirements that apply to what you do (i.e.,

that apply to your products, activities and services). This step is

important for understanding compliance obligations and how

these obligations affect the overall EMS design. For example,

you might have an operation that is covered by an air quality

permit or might provide a service that results in the generation

of regulated wastes. Your EMS should include processes to

ensure that such legal requirements are addressed when you

conduct these operations (or when they are modified).

Your EMS should be designed to help you accomplish more that

just compliance with applicable laws and regulations, but these

compliance requirements should be a major consideration.

Performing this step first allows you to understand how legal

requirements might relate to the environmental aspects and

impacts of your products, activities and services, as discussed

next.

Once you understand what “rules” apply, you should assess

how your organization interacts with the environment. This

is accomplished by identifying your environmental aspects and

impacts and determining which of them are significant. Some

of your environmental aspects may be regulated, while others

may not be.

As you identify and assess your aspects, you also should

identify specific products, operations and activities from

which these aspects / impacts arise. Likewise, you can identify

any monitoring that is performed of these operations or

activities for environmental purposes. For example, if you

identify the generation of a particular air emission as a

significant environmental aspect, it would help to know which

operation(s) generate such air emissions. It might also help to

know whether these air emissions are monitored or otherwise

measured in some manner.

Collecting this information at an early stage will help you

implement subsequent EMS elements. You can use a form

(such as Figure 15) to capture this information. One caveat --

just because you identify an existing control and/or monitoring

activity related to a particular operation or activity, don’t

automatically assume that these controls are adequate for

EMS purposes. The adequacy of these controls will depend on

several factors, including your objectives and targets.

Identify

Legal and

Other

Requirements

Identify

Environmental

Aspects and

Related Products,

Operations and

Activities
© 2001 NSF 81

Sec. 5

Figure 15: Linking Operations, Aspects, Controls and Monitoring (example)

Source Significant Aspect(s) Regulated? Associated Controls Associated

Monitoring

or Measurement

Operations

Parts painting • Air emissions

(VOCs)

• Solvent waste

generation

• Yes

• Yes

• Limits on VOC

content in paints

and operating hours

• SOP for HW

generation

• Paint use records,

log of operating

hours

• Waste tracking

sheet

Parts plating • Waste generation

• Water discharges

• Yes

• Yes

• SOP for HW

generation

• Notification to site

effluent treatment

plant

• Waste tracking

sheet

• Pre-discharge

sampling

Other Activities

Raw material

storage

• Potential spills • Yes • Stormwater

Pollution Prevention

Plan

• Weekly

inspections of

storage area

Fleet maintenance • Waste oil generation

• Potential spills

• Yes

• Yes

• SOP for HW

generation

• Stormwater

Pollution Prevention

Plan

• Waste tracking

sheet

• Weekly

inspections of

storage area

Products

Pumps • Energy Use

• Chromium content

• No

• No

• None

• None

• None

• None

Services

Equipment servicing

at customer sites

• Waste generation

• Fuel use

• No

• No

• SOP for equipment

service

• None

• Waste tracking

sheet

• Fuel dispensing

records
© 2001 NSF 82

Sec. 5

Armed with information on applicable legal and other

requirements as well as the environmental attributes of your

products, activities and services, you should gather

information of the views of your “stakeholders” (or

interested parties). Stakeholders might include, for example,

your neighbors, interest groups, regulators and others. Their

views might address how your organization affects the

environment, how well you are meeting your environmental

obligations, and whether your organization is a “good neighbor”,

among other topics. There are many ways to collect information

on stakeholder views, as discussed in Section 4 (See

“Communication”).

Gathering this information now allows you to consider

stakeholder input in the development of your environmental

policy. Since you have already assessed your legal and other

requirements and your environmental aspects, you should be in

a good position to have meaningful dialogues with these

stakeholders.

At this point, you should have a sound basis for developing (or

possibly amending) your environmental policy. Using the

information developed in the previous three steps allows your

organization to prepare a policy that is relevant to the

organization and the key issues that it faces. For example, you

will have information on the views of your stakeholders that

might be valuable in developing an environmental policy.

Keep in mind that you evaluated your current environmental

programs when you performed the preliminary review (see

Section 3), so you should understand how (and how well) you

are currently managing these key issues.

Once the environmental policy has been written, you can begin

to define key roles and responsibilities within the EMS. At

this stage of implementation, focus on “higher-level”

responsibilities, such as the roles and responsibilities of senior

management, key functional leaders and environmental staff (if

one exists). EMS responsibilities for other specific jobs or

functions will be identified in a later step. Once the key roles

and responsibilities have been defined, obtain the input of these

individuals in the next step of the process – establishing

objectives and targets.

Define

Views of

Interested

Parties

Prepare

Environmental

Policy

Define

Key Roles

and

Responsibilities
© 2001 NSF 83

Sec. 5

At this point you are ready to establish environmental

objectives and targets for your organization. These objectives

should be consistent with your environmental policy. Each of

your objectives also should reflect the analyses you carried out

on legal and other requirements, environmental aspects and

impacts, and the views of interested parties (as well as the other

factors discussed in Section 4).

You identified the operations and activities related to your

significant aspects and impacts in an earlier step. Also, you

defined certain key roles and responsibilities. This information

will help you to determine the relevant levels and functions

within the organization for achieving objectives and targets. For

example, if you set an objective to reduce hazardous waste

generation by 10% this year, you also should know which parts

of the organization must be involved in order to meet this

objective.

Figure 16

This brings us to one of the most challenging (and

potentially most valuable) steps in the overall process.

Armed with an understanding of legal requirements,

your significant environmental aspects and impacts,

and your objectives and targets, your are ready to

tackle several EMS elements simultaneously.

These elements include the design of environmental

management programs, the initial identification of

necessary operational controls, and the initial

identification of monitoring and measurement needs.

One reason combining these steps is that they can

often overlap significantly. For example, your

environmental management program for achieving a

certain objective (such as maintaining compliance with

regulations) might consist of a number of existing

operational controls (procedures) and monitoring

activities. Similarly, achieving an objective might

require a feasibility study or the implementation of

certain “new” operational controls. Likewise,

determining progress on achieving objectives often

requires some form of monitoring or measurement.

Establish

Objectives

And

Targets

Identify

Operational

Controls

Develop

Environmental

Management

Programs

Identify

Monitoring and

Measurement

Needs
© 2001 NSF 84

Sec. 5

An example of a form for

describing environmental

management programs that

shows the links between

programs and operational

controls is provided in the

Tool Kit (Appendix A)

One important caveat: Keep in mind that operational

controls and monitoring / measurement processes might

be needed even if no objective (or corresponding

management program) exists for a particular operation or

activity. For example, controls might be needed for

certain operations to ensure compliance with legal

requirements or to control a significant environmental

aspect, even where no specific objective has been set.

The initial identification of operational control needs at this

point in the process should be supplemented by a more

detailed design of operational controls and monitoring

processes, as described in a subsequent process step.

Also keep in mind that this process is usually iterative.

That is, you might need to “re-visit” your management

programs, operational controls and monitoring processes

over time to ensure they are consistent and up-to-date.

You should already have a head start on this step, since

you identified operations and activities related to your

significant environmental aspects (as well as existing

control and monitoring processes) several steps ago.

Remember how we said this was a good idea?

Your don’t need to fully develop these operational

controls and monitoring activities yet – that step comes

later (see “Design Operational Controls & Monitoring

Processes”). What you need to do now is compile a list

of your operational control and monitoring needs. As

you develop your environmental management programs,

ask yourself the following questions:

• How do we control this operation or activity now?

• Are these controls adequate to meet our objectives

and to ensure compliance?

• If additional controls are needed, what types of

controls make sense?

• What type of monitoring / measurement is needed to

track our progress in achieving objectives and to

ensure that operational controls are implemented as

designed?
© 2001 NSF 85

Sec. 5

At this stage of implementation, your EMS will begin to

generate some documents (such as procedures and

forms) and records (that demonstrate that various

processes are being carried out). For this reason, it is a

good time to establish procedures for

corrective/preventive action, document control, and

records management. These three processes are

essentially “system maintenance” functions. As you

develop and implement other system-level procedures,

work instructions for various activities, and other EMS

documents, you need a process for controlling the

generation and modification of these documents.

Likewise, you will need a process to ensure that you can

fix (or correct) problems when they occur. In addition,

many of these processes (such as monitoring activities)

will generate records, so you need an effective way to

manage the records that your EMS generates.

Once the system maintenance functions are in place, you

can start in earnest the establishment of activity- or

area-specific operational controls and monitoring

processes. As a starting point, refer back to the list of

operational control and monitoring needs that you

generated in preparing your environmental management

programs (see earlier step). Also, you should have a

template for the development of these work instructions

(or standard operating procedures), since your document

control process was established in the prior step.

Remember that you might need operational controls and

monitoring processes to meet your policy commitments

and control significant environmental aspects, even

where no specific objectives or environmental

management programs have been established.

Employees that work in relevant operations or activities

can provide a lot of support here. Also, note that these

operational controls and monitoring processes can play

an important role in employee training, as discussed later.

Also keep in mind that you also need a procedure for

conducting periodic compliance evaluations.

Establish

Corrective Action,

Document Control &

Records Management

Processes

Establish

Operational

Controls &

Monitoring

Processes
© 2001 NSF 86

Sec. 5

As part of the process described above, you should

define job-specific roles and responsibilities. Such

roles and responsibilities should address the specific

operational controls and monitoring processes discussed

above. You might want to document these

responsibilities in a responsibility matrix or in some

other form that is easily communicated to employees.

Initial employee awareness training should be

conducted to promote understanding of the organization’s

EMS efforts and the progress made to-date. As a first

step, train employees on the environmental policy and

other elements of the EMS. Discuss the environmental

impacts of their activities, any new / modified procedures,

the organization’s objectives and targets, as well as their

EMS responsibilities. If you have contractors or others at

your site who are not employees of your organization,

consider whether these other individuals should be

included in these EMS awareness sessions.

Some system-level procedures (such as the procedures

for identification of environmental aspects and access to

legal and other requirements) were developed at earlier

stages of the process. At this point, you can establish

any other procedures required for the EMS. These

other system-level procedures might include, for example:

• employee training and awareness,

• internal and external communication,

• emergency preparedness and response,

• EMS auditing, and

• management review.

Once you have established roles and responsibilities and

defined all of your system-level procedures, preparing

the EMS manual should be a relatively simple matter.

The manual should summarize the results of your efforts

so far (that is, it should describe the processes you have

developed, the roles and responsibilities you have defined

as well as other EMS elements). Also, it is important to

describe the links among system elements and provide

direction to other system documents. Keep the manual

simple – there is no need to provide great detail on any

particular system process. Readers can be referred to

the detailed procedures if more information is needed.

Define

Job-Specific

Roles and

Responsibilities

Plan and

Conduct

Initial

Employee

Awareness

Establish

Other

System-Level

Procedures

Prepare

EMS

Documentation

(manual)
© 2001 NSF 87

Sec. 5

Once the procedures and other system documentation

have been prepared, you are ready to conduct specific

employee EMS training. As a first step, identify specific

training needs. Employee training should be designed to

ensure understanding of:

• key system processes,

• operational controls related to their specific jobs, and

• any monitoring or measurement for which they are

responsible.

Job-specific training should also cover topics such as

EMS auditing for those employees that will conduct

internal EMS audits.

Once internal auditors have been selected and trained,

you should design and initiate the internal auditing

process. At this point, you should have sufficient EMS

processes in place to conduct meaningful audits. Many

organizations find that it is easier to start with smaller,

more frequent audits that to audit the entire EMS at once.

These early audits can serve as a learning tool for the

auditors.

Once the audit results are known, use the corrective and

preventive action process you developed earlier to

address any identified problems. Audit records should be

managed in accordance with the records management

process.

Use the results of your internal audits (along with other

information on the EMS) to conduct management

reviews. Management should consider the need for any

changes to the EMS and make assignments for any

changes needed. Such assignments should be

consistent with the roles and responsibilities established

previously.

Plan and

Conduct

Specific

Employee

Training

Conduct

Internal

EMS

Audits

Conduct

Management

Reviews
© 2001 NSF 88

A

Appendix A: TOOL KIT

Sample Environmental Policies .............................................................................................89

Environmental Impact Identification and Evaluation: Techniques .and Data Sources..96

Sample Procedure: Instructions for Environmental Aspects Identification Form...........98

Environmental Aspects Identification Form..........................................................................103

Sample Environmental Aspect Evaluation and Scoring Tools........................................104

Resources for Tracking Environmental Laws and Regulations .......................................106

Sample Process Tool: Setting Objectives & Targets........................................................108

Sample Procedure: Setting Objectives & Targets.............................................................111

Sample Tools: Environmental Management Program........................................................113

Sample Responsibility Matrix.................................................................................................117

Sample Environmental Training Log.....................................................................................120

Sample Procedure: Communications with External Parties.............................................123

Sample Document Index.........................................................................................................125

Outline of Sample EMS Manual and Other EMS Documents.........................................127

Sample Records Management Form (supplied courtesy of..............................................130

General Oil Company) .............................................................................................................132

Sample Procedure: Corrective and Preventive Action.....................................................134

(includes tracking log)..............................................................................................................134

Sample Environmental Records Organizer..........................................................................136

Sample Procedure: EMS Audits ...........................................................................................136

Sample EMS Audit Forms.......................................................................................................141

Sample EMS Audit Questions ................................................................................................143

Sample Procedure: Management Review...........................................................................149

Note: The examples in the Tool Kit are drawn from many different sources. They are not

designed to be used together in EMS development.
© 2001 NSF 89

A

Sample

Environmental

Policies
Sample policy – Actual policy reproduced with permission. Policy is not in original format.

© 2001 NSF 90

A

NEO INDUSTRIES

HEALTH, SAFETY AND ENVIRONMENTAL POLICY

Neo Industries is committed to managing health, safety and environmental (HS&E) matters as an

integral part of our business. In particular, it is our policy to assure the HS&E integrity of our processes

and facilities at all times and at all places. We will do so by adhering to the following principles:

We will comply with all applicable laws and regulations and will implement programs and procedures

to assure compliance. Strict compliance with HS&E standards will be a key ingredient in the training,

performance reviews and incentives of all employees.

Where existing laws and regulations are not adequate to assure protection of human health, safety

and the environment, we will establish and meet our own HS&E quality standards.

We will employ management systems and procedures specifically designed to prevent activities and /

or conditions that pose a threat to human health, safety or the environment. We will minimize risk and

protect our employees and the communities in which we operate by employing safe technologies and

operating procedures, as well as being prepared for emergencies.

We will strive to prevent releases to the atmosphere, land or water. We will minimize the amount and

toxicity of waste generated and will ensure the safe treatment and disposal of waste.

We will communicate our commitment to HS&E quality to our employees, vendors and customers. We

will solicit their input in meeting our HS&E goals and in turn will offer assistance to meet their goals.

We will continuously seek opportunities to improve our adherence to these principles, and will

periodically report progress to our stakeholders.

{Signature}

Neil K. Holt March 1995

President

Compliance

Prevention

Continuous Improvement

Communication
Sample policy – Actual policy reproduced with permission. Policy is not in original format.

© 2001 NSF 91

A

Pacific Gas and Electric Company

Environmental Quality Policy Statement

PG&E is committed to a

clean, healthy environment.

We will provide our

customers with safe,

reliable, and responsive

 utility service in an

environmentally sensitive

and responsible manner

We believe that sound

environmental policy

contributes to our

competitive strength and

benefits our customers,

shareholders, and

employees by contributing

to the overall well-being

and economic health of the

communities we serve.

September 1995

(Actual policy is printed on recycled paper)

We will:

Comply fully with the letter and spirit of

environmental laws and regulations, and

strive to secure fundamental reforms that will

improve their environmental effectiveness

and reduce the cost of compliance.

Consider environmental factors and the full

acquisition, use, and disposal costs when

making planning, purchasing, and operating

decisions.

Work continuously to improve the

effectiveness of our environmental

management.

Provide appropriate environmental training

and educate employees to be environmentally

responsible on the job and at home.

Monitor our environmental performance

regularly through rigorous evaluations.

Seek to prevent pollution before it is

produced, reduce the amount of waste at our

facilities, and support pollution prevention by

our customers and suppliers.

Manage land, water, wildlife, and timber

resources in an environmentally sensitive

manner.

Use energy efficiently throughout our

operations, and support the efficient use of

gas and electricity by our customers and

suppliers.

Re-use and recycle whenever possible.

Use environmentally preferred materials.

Clean up residual pollution from past

operations in a cost-effective manner.

Work cooperatively with others to further

common environmental objectives.

Communicate and reinforce this policy

throughout the company.
Sample policy – Actual policy reproduced with permission. Policy is not in original format.

© 2001 NSF 92

A

CAMPBELL & CO. ENVIRONMENTAL POLICY

Campbell & Co’s commitment to improve the

environment is an expression of our Guiding

Principles, and a demonstration of “think globally

and act locally” sensibilities.

We strengthen this commitment by

employing Quality Operating System

methodology as the framework to identify

objectives and targets for addressing areas

of environmental significance.

Campbell & Co. is improving the condition of

our environment by preventing pollution,

specifically through the reduction of natural

resource usage. We are also helping to

preserve the environment by promoting

recycling as well as continuing to make

responsible environmental choices when

purchasing products.

 Campbell & Co. will comply with all federal,

state and local legislation and regulatory

requirements, as well as those requirements

adopted through the Michigan Business

Pollution Prevention Partnership Policy.

 Above all, Campbell & Co. employees will

strive to continuously improve our efforts to

create a cleaner and safer environment.

________________________________________________

 David Scheinberg, President & CEO

Created: June 6, 2000

Revised: October 6, 2000
Sample policy – Actual policy reproduced with permission. Policy is not in original format.

© 2001 NSF 93

A

 Village Of Chelsea, Michigan

Statement Of Environmental Policy

The Village of Chelsea is committed to continual improvement of its Environmental

Management System and is in compliance with all relevant federal, state, and local

environmental legislation and regulations. The Village of Chelsea will meet and

strive to exceed all environmental requirements and will seek to prevent pollution

before it is produced. To sustain this commitment, the requirements of the

Environmental Management System described in this Manual apply to all activities

and employees. The Village’s Department Superintendents are the Village’s

Management Representatives who have the responsibility and authority to plan,

enforce, and maintain the Village’s Environmental Management System. This

responsibility also includes stoppage of activities that deviate from the

 requirements of this Manual. The EMS Management Representative may

delegate some of this authority downward through the organization in order to

implement the system effectively. We will continuously seek opportunities to

improve our adherence to the principles of environmental management.

Policy adopted by Village Council on March 11, 1997.

Village President

Village Clerk

[Signatures included in original policy.]
Sample policy – Actual policy reproduced with permission. Policy is not in original format.

© 2001 NSF 94

A

Saint Joseph Mercy Hospital (in Michigan) demonstrated that an environmental policy can

be written in the form of a procedure. One advantage of this approach is that hospital staff can

make a direct connection between the policy and their departmental responsibilities for

implementing the policy. The hospital includes its policy in the Administrative Policy Manual

because that manual was already well established and widely distributed. Integrating EMS

requirements with existing manuals, procedures, training, and responsibilities was a key

implementation strategy for the hospital.

 Saint Joseph Mercy Hospital

Administrative Policy and Procedure

Subject: Environmental Compliance Policy

Effective Date: September 14, 1998

Revised Date:

Approved By: President and CEO

POLICY

It is the policy of St. Joseph Mercy Hospital (SJMH), which includes all SJMH owned and

operated buildings and services, to conduct all of its operations in an environmentally

responsible and sensitive manner. St. Joseph Mercy Hospital will fully comply with both

the letter and the spirit of all applicable federal, state and local regulatory requirements

governing hazardous materials and wastes, pollution prevention and environmental

protection. It is recognized that the health and well being of the environment contributes to

the health and well being of the communities and populations we serve. St. Joseph Mercy

Hospital will strive to continuously improve its systems and procedures related to

environmental protection and pollution prevention activities. St. Joseph Mercy Hospital will

manage its facilities and properties in an environmentally responsible manner. St. Joseph

Mercy Hospital will participate as appropriate in community, industry, and/or governmental

sponsored groups addressing environmental issues affecting the communities we serve.

NARRATIVE

Environmental protection is the responsibility of all SJMH departments and employees. As a

health care organization, SJMH must handle and manage a wide variety of potentially

hazardous or polluting materials including medical wastes, radioactive materials and

hazardous chemicals and wastes. Many of our processes present potential water and air

quality issues that demand continuous monitoring and control. Proper and responsible

handling of these materials and processes is imperative to prevent pollution, reduce waste

and protect our environment. A host of federal, state and local regulatory requirements are in

place to guide this organization in achieving environmental compliance.

PROCEDURE

I. Each department will continuously assess its operations to identify potential safety

hazards and pollution risks. Each department is responsible for establishing and

maintaining department specific policies and procedures designed to reduce or

eliminate environmental hazards and minimize any negative environmental impact

when applicable.

A. Potential risks will be minimized to the extent possible by seeking out less

environmentally hazardous products, equipment or procedures.

B. Appropriate engineering controls will be implemented when it is not

possible to eliminate an environmentally hazardous material or
Sample policy – Actual policy reproduced with permission. Policy is not in original format.

© 2001 NSF 95

A

procedure.

C. All departments and employees will strive to reduce all types of wastes

through identifying and eliminating wasteful practices and products and

participate in organizational recycling and waste reduction programs.

D. Departments will educate and communicate organizational and

department specific environmental policies, goals and objectives to

employees as required.

E. Departments will consider using products that have recycled content

taking economic and quality factors into account.

II. The Safety Steering Committee is responsible for monitoring environmental

compliance issues recommending and assuring that corrective action is

implemented as warranted to correct deficiencies.

A. Objectives and targets will be established to assure continuous

improvement in organizational environmental performance. Safety

Committee structure is responsible for establishing goals and

implementing programs to meet targets. The Safety Steering Committee

is responsible for monitoring progress and reporting activities to

Executive Management.

REFERENCES

• Safety Steering Committee

• Hazardous Material and Waste Committee

• Product Value Analysis Committee

• Safety Policy Manual Section III_300 – “Hazardous Materials and Waste”

• Departmental Specific Hazardous Material/Pollution Prevention Policies and Procedures
© 2001 NSF 96

A

Environmental Impact

Identification and Evaluation:

Techniques and

Data Sources
© 2001 NSF 97

A

SOME TECHNIQUES AND DATA SOURCES FOR IDENTIFYING AND

EVALUATING ENVIRONMENTAL IMPACTS

Process Hazard

Analyses

Used to identify and assess potential impacts associated

with unplanned releases of hazardous materials.

Methodology in common use due to OSHA Process Safety

Management regulations. Typically employs team approach

to identify and rank hazards.

Failure Mode and

Effects Analyses

Commonly used in quality field to identify and prioritize

potential equipment and process failures as well as to

identify potential corrective actions. Often used as a

precursor to formal root cause analyses.

Process Mapping See Appendix C for details of this technique.

Environmental Impact

Assessments

Used to satisfy requirements of National Environmental

Policy Act (NEPA) regarding the evaluation of environmental

impacts associated with proposed projects. Methodology in

common use, but not typically used to assess environmental

impacts associated with existing operations.

Life Cycle

Assessments

Used to assess full range of impacts from products, from

raw material procurement through product disposal.

Methodologies somewhat subjective and can be resource

intensive. Described in ISO 14040-14048.

Risk Assessments Used to assess potential health and/or environment risks

typically associated with chemical exposure. Variety of

qualitative and quantitative methodologies in common use.

Project Safety / Hazard

Reviews

Used to assess and mitigate potential safety hazards

associated with new or modified projects. Methodologies in

common use. Typically do not focus on environmental

issues.

Emission Inventories Used to quantify emissions of pollutants to the air. Some

data may already by available to the organization, based on

EPCRA requirements and CAA Title V permitting program.

Pollution Prevention

or Waste Minimization

Audits

Used to identify opportunities to reduce or eliminate pollution

at the source and to identify recycling options. Requires

fairly rigorous assessment of facility operations. Typically

does not examine off-site impacts.

Environmental

Property Assessments

Used to assess potential environmental liabilities associated

with facility or business acquisitions or divestitures. Scope

and level of detail is variable. Typically do not assess

impacts associated with products or services.

Environmental Cost

Accounting

Used to assess full environmental costs associated with

activities and/or products. Emerging protocols require

comprehensive assessment to quantify costs.

Environmental

Compliance Audits

Used to assess compliance with federal, state and local

environmental regulations. Methodologies in common use.

Scope and detail vary. Not typically directed at examining

environmental impacts (particularly for products).
© 2001 NSF 98

A

Sample Procedure:

Instructions for Environmental Aspects

Identification Form

(courtesy of ZEXEL Corporation)
© 2001 NSF 99

A

OPERATIONAL PROCEDURE Issue Date:

August 04, 2000

Number:

OP-EV0100.R06

Author:

Ronda Moore

Approval: _________________________

Vice President Operations

Title:

Environmental Aspects & Impacts Reviewed By:

_________________________

Waste Water Group Leader

1.0 Purpose

The purpose of this procedure is to provide a system and instructions to identify

environmental aspects of ZEXEL's activities, products, and services in order to

determine those which may have a significant impact on the environment.

2.0 Scope

This procedure covers all activities, products, and services associated with ZEXEL. For

purposes of evaluation, activities, products, and services with similar characteristics may

be grouped together.

3.0 Reference Documents

Document Name Document Number

Objectives and Targets OP-EV0103

Management Review OP-ZX006

Aspect/Impact Evaluation Form WF-ES002

Aspect/Impact Listing - Decatur WF-ES008

Aspect/Impact Listing - Arcola WF-ES058

Initial Production Control OP-ZX001

Contract Review OP-SA001

4.0 Procedure

4.1 The procedure consists of an initial screening of activities, products, and services, based

on data submitted to the ISO 14000 Task Force by the Area Managers. The Task Force

assesses the aspects, determines associated impacts, and assigns an impact rating.

The Task Force will review the evaluation results, and up-date as needed.

4.2 Area Managers are responsible for developing a flowchart for their department(s)

showing all inputs and outputs to their processes. Inputs into the process may include

supplies, raw materials, chemicals, packaging, and energy consumption. Outputs from

the process may include products, solid wastes, liquid wastes, emissions, noise, and

odor. The flowcharts shall also include the current method of handling generated

wastes.

4.3 The Task Force shall evaluate the information submitted on the flowcharts. The Task

Force may call upon other ZEXEL Team Members to assist, as needed. Each activity,

product, and service shall be evaluated from the time the material is accepted on site

through the time of sale, at the sale location. If a waste is being evaluated, the timeline

to consider is the time the material is accepted on site through ultimate disposal, as

displayed by the diagram below.
© 2001 NSF 100

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Accept Material Sale Location

|-----------Product--------------------------------| Ultimate Disposal

|-----------Waste-----------------------------------------|

4.4 The Task Force shall assign an impact rating according to the scales described below,

while considering each of the following stages: raw material storage, production

(accidents, start up, and normal operation), product and waste storage, transportation,

and ultimate disposal.

4.5 The Task Force shall ask for each aspect / impact evaluation:

a) Is it in our permits / permittable?

b) Is it regulated by law?

c) Do we have control over it?

If the answer to a and/or b is "yes", the impact must be included on the list of significant

impacts. If the answer to c is "no", the impact shall not be included on the list of significant

impacts. The following table explains the different possible answers.

Possible Answer Permitted /

Permittable

Regulated by Law Do we have

Control

Yes must include must include may include

No may include may include shall not include

4.6 When evaluating the "frequency", the number shall be determined from the following

scale, based on documented evidence, by asking the following questions to determine

frequency of use and of accidents: (1). How often does the process occur? and (2).

How often has a problem occurred?

Frequency Scale

Continuously 10

once per shift 9

once per day 8

Weekly 7

Monthly 6

Quarterly 5

semi-annually 4

Annually 3

once every 1 to 5 years 2

over 5 years 1

Never 0
© 2001 NSF 101

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4.7 When evaluating the "severity" the task force shall assign an impact number by selecting

the highest evaluated rate from the scale below, based on documented evidence. When

considering human impact, it is important to include contractors, neighbors, customers,

etc., as well as team members.

Severity

Scale

Human Impact Animal / Plant

Effect

Public Relations

10 multiple deaths widespread

permanent

destruction

plant closure

9 single death on-site permanent

destruction

permanent public

disfavor

8 disabling injury widespread genetic

impact

interrupted

operations

7 long term health

effects

on site genetic

impact

loss of historical

assets

6 lost time

Injury/Illness

wide spread

disfigurement

state or national

protest

5 restricted duty on-site disfigurement city or county protest

4 medical only wide spread

appearance

employee protest

3 first aid treatment reduction of natural

beauty

public inconvenience

2 Discomfort on-site appearance public disfavor

1 None none none

4.8 Impact ratings shall be determined by multiplying the frequency and severity numbers.

The Task Force shall determine an appropriate cutoff level for significant impacts.

4.9 The Environmental Manager shall work closely with ZEXEL's Plant Management to

ensure that the identified significant environmental aspects are considered in

establishing environmental objectives and targets for ZEXEL, as stated in the Objectives

and Targets OP.

4.10 The results of the most recent environment aspect / impact identification is reviewed as

part of the Management Review process, as specified in the Management Review OP.

From this review ZEXEL Management determines the need to update the environmental

impact evaluation. Factors considered in the determination to update the assessment

include improved methodologies, and major changes in ZEXEL's policies, products, or

processes. Aspect reviews may also be triggered from the Initial Production Control

(IPC) and Contract Review process. Environmental impact evaluations shall be

conducted at least, on an annual basis, by the end of each calendar year, even if none

of the factors listed above dictate a review.
© 2001 NSF 102

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ASPECT / IMPACT EVALUATION

Aspect/Impact/Activity: Date:

Frequency Severity

Category Stages Use Incident Human

Impact

Animal/Plant Public Impact

Rating

Air Quality Raw Material

Storage

Water

Quality

Production

(Start-Up)

Land Quality Production

(Normal)

Consumption Product/

Waste Storage

Transportation

Ultimate

Disposal

Overall Rating

Please note: Significant Impact if

- permittable

- required by law

- over the establish cut off

Severity

Frequency Human Impact Animal/ Plant Effect Public Relations Scale

continuously multiple deaths widespread perm.

destruction

plant closure 10

1 per shift single death on-site permanent

destruction

permanent public

disfavor

9

1 per day disabling injury widespread genetic

impact

interrupted

operations

8

weekly long term health

effects

on-site genetic impact loss of historical

assets

7

monthly lost time injury/

illness

widespread

disfigurement

state or national

protest

6

quarterly restricted duty on-site disfigurement city or county

protest

5

semi-annually medical only widespread appearance employee protest 4

annually first aid

treatment

reduction of natural

beauty

public

inconvenience

3

1 every 1 - 5 yrs discomfort on-site appearance public disfavor 2

over 5 yrs none none none 1

never (Use Only) 0
© 2001 NSF 103

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Environmental Aspects Identification Form

(courtesy of Johnson Controls, Inc. –

Automotive Systems Group)

Note: The instructions and form were developed within the context of a comprehensive

EMS. References are made to processes outside of the instructions.

This is intended as an example, not a stand-alone document.
© 2001 NSF 104

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Provided courtesy of Johnson Controls, Inc., Automotive Systems Group

Instructions for Environmental Aspect Identification Form

Responsibilities

The facility Cross Functional Team (CFT) led by the Management Representative (MR) is

responsible for completing this form for each Core Process and Supporting Activity within a

facility. If possible, members of the CFT must conduct a physical inspection when completing

this form. The completed form is a material balance of a process or activity and is used to

identify Environmental Aspects. The facility CFT compares the resulting material balance and

list of facility-specific aspects to any information available in the form of generic “HSE Process

Profiles” produced for similar type processes or activities.

At a minimum, the CFT will review and revise the completed forms, by means of physical

inspection, as necessary at issuance, annually, prior to and immediately following

implementation of new or modified processes/activities.

All environmental aspects are evaluated for significance and managed as defined in the

Environmental Aspects Control Plan form.

Conducting a Material Balance

The material balance consists of identifying all raw materials, chemicals, and utilities used as

input along with their relative usage rates, and all output as product and by-products produced.

The latter is all wastes produced, all recycled materials, water discharges, and air emissions

known for the process(es), and any available rates of production.

1.0 Record the Plant Name, Process/Activity Name, and Location.

2.0 Provide a description of the process/activity.

3.0 Determine and record if the Process/Activity is a Contracted Process/Activity.

4.0 Record Material Inputs and Outputs. If the Process/Activity is installed or in place,

conduct the identification by means of physical inspection.

Raw material inputs

• Parts: Enter the major, non-chemical parts/supplies used in the process.

• Chemical: Enter any chemical materials used in the process.

• Energy: Enter energy type and usage. (Levels are relative to the facility.)

• Other Input: Enter inputs that are not covered clearly in other categories. (e.g.

packaging, containers)

• Water Use: Enter water type (e.g. city, well, storm, process, chilled) and usage.

(Levels are relative to the facility.)
© 2001 NSF 105

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Provided courtesy of Johnson Controls, Inc., Automotive Systems Group

Process Output

• List all products produced by the process specifically produced for sale.

Recyclable and Chemical By-Product (e.g. Rebond) outputs are entered in the

waste section.

• List all air emissions whether they are drawn directly through a stack or are

discharged into the room and escape as fugitive emissions. Include noise and

odor as an air emission if potentially noticeable outside the facility.

• Enter wastes. Wastes are any materials intended to be discarded or disposed of,

whether regulated or not, and include liquids, solids, and gases. Also include

recycled materials, returnable containers and chemical by-products under this

category

• Check the recycled box if the material is currently recycled, internally or

externally. It does not include materials that go directly back into the process

(i.e., Calibration shots returned to day tanks, etc.)

• Include containerized wastewater transported off-site.

• Enter all wastewater streams that discharge directly to storm or sanitary sewer

systems or surface waters. Containerized wastewater should be included in the

waste section. In the bottom portion of the wastewater section, list any treatment

that occurs before the water is discharged.

5.0 Compare the completed form to any information available in the form of generic “HSE

Process Profiles” produced for similar type processes or activities.

6.0 Sign and date the form with the date the form was completed or revised.

7.0 Collect all completed Aspect Identification forms and enter data into the supporting

Environmental Aspect Control Plan form.
© 2001 NSF 106

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Environmental Aspects Identification

Process Overview

Establish Cross

Functional Team

(CFT)

Determine Core

Processes and

Supporting Activities

Inspect each

Process/Activity and

conduct material

blanace

Identify and record

aspects

Compare to available

profiles

Proceed to

Environmental

Aspects

Analysis and

Control Form

HSE Level 2

Procedure
© 2001 NSF 107

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© 2001 NSF 108

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Sample Environmental

Aspect Evaluation and

Scoring Tools
© 2001 NSF 109

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Sample 1: Environmental Aspect/Impact Scoring Worksheet

A company identified “Spills from Unloading Trucks” as an environmental aspect of its

operations. The company used the following worksheet and rating criteria to determine

whether the environmental impacts (on water quality and/or soil contamination) of this

aspect should be considered significant.

First, the company determined that the LIKELIHOOD of a spill was low, since it had not

experienced any spills of this type in the prior three years. Second, they determined that the

MAGNITUDE (or SEVERITY) of the environmental impact would be moderate for most of

the types of materials that they unload from trucks at the loading dock. The company noted,

however, that certain chemicals are regulated and that spills of such materials in reportable

quantities would require an appropriate response to regulatory agencies.

Using the “Key to Impact Rating” (see below), an environmental impact with a Low

Likelihood and a Moderate Magnitude received an overall score of “low impact

significance”. Thus, “spills from unloading trucks” was not considered a significant

environmental aspect.

Area or

Activity

Aspect Impacts Impact Scoring

(see below)

Significance

Shipping

Dock

Spills from

Unloading

Trucks

Water Quality

 and

Soil

Contamination

Likelihood is

low

Magnitude

is moderate

OVERALL

IMPACT

SCORE IS

LOW

Not

Significant

(Note: spills

of

reportable

quantities of

certain

chemicals

must be

reported)

Key to Impact Rating

Likelihood of

Occurrence

or Impact(s)

Magnitude

(severity of impacts, actual or potential

Severe Moderate Low

High High

Significance

High

Significance

Medium

Significance

Medium High

Significance

Medium

Significance

Low

Significance

Low Medium

Significance

Low

Significance

Low

Significance

Excerpted from “Environmental Management Systems: A Guide for Metal Finishers”

(NSF International), available for free download at www.nsf-isr.org.
© 2001 NSF 110

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Sample 2: Environmental Aspect/Impact Scoring Worksheet

Approach

For each product, service or activity (or group of products, services or activities), each

element in the table is assigned two scores, based on (1) the degree of impact and (2)

frequency or likelihood of the associated environmental impacts.

Degree of Impact

4 = serious (likely to result in severe or widespread damage to human health or the

environment)

3 = moderate

2 = minor

1 = no impact (unlikely to have an adverse impact on human health or the environment)

Frequency/Likelihood of Impact

4 = continuous (impact occurs on an on-going basis)

3 = frequent (impact occurs more than once / month)

2 = infrequent (impact occurs more than once / year but less than once / month)

1 = improbable / never (impact has never occurred or is highly unlikely to occur)

Scores are added for each indicator across the relevant life cycle stages (as shown in the

example below) to generate a total impact score.

PreProductionManufacturingProduction/

Distribution

Use /

Service

Waste

Mgt

TOTAL

SCORE

Category Indicator

Human Health

Employees 3/2 2/2 2/1 4/2 2/2 22

Surrounding

Community

2/2 2/3 2/2 1/2 2/2 20

Global 1/2 1/2 1/3 1/2 1/3 17

Environment

Air Quality

Surface

Water

Ground

Water

Land / Soil

Ecosystem

Effects

Noise

Resource Use

Fuels

Water

Raw

Materials
© 2001 NSF 111

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Resources for Tracking Environmental

Laws and Regulations
© 2001 NSF 112

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Resources for Tracking Environmental Laws and Regulations

Over the last few years, the Internet has emerged as a tremendous tool for tracking and

obtaining information on environmental laws and regulations. For example, the USEPA

home page (see address below) in one quite useful Internet source. See Appendix F for

additional information on resources.

This table describes a variety of commercial and non-commercial sources of information on

federal and state environmental laws and regulations. This list is not intended to be

comprehensive. Appearance on this list should not be construed as an endorsement by

EPA or NSF of any commercial products listed here.

Source Description

USEPA

Small Business Ombudsman

(1-800-368-5888)

Regulatory explanations and guidance, research, case

studies, contacts for additional information. Variety of hotlines

available for particular statutes (such as RCRA). Internet

access also available (http://www.epa.gov).

USEPA Web Site Provides a variety of information of environmental laws and

regulations as well as tools and compliance guidance.

(http://www.epa.gov).

Small Business Assistance

Programs (various states)

Guidance on regulations and compliance issues. Initially

focused on clean Air Act requirements, but expanding into

other environmental media.

US Small Business

Administration

Various services available to small businesses in the US.

US Government Printing Office

(202-512-1800)

Federal Register published daily with all federal proposed and

final rules. (Also available on line via GPO Access)

Trade and Professional

Associations (various)

Provide a variety of services related to environmental laws

and regulations, including regulatory updates and training.

Contact individual associations for details.

Counterpoint Publishing

(1-800-998-4515)

CD-ROM and Internet dial-up access to legal / regulatory

information for federal government and all 50 states, updated

daily.

Bureau of National Affairs

(1-800-372-1033)

Information on EHS laws, regulations and activities at

international, national and state level. Paper and electronic

access available.

Thompson Publishing Group

(1-800-677-3789)

Manuals on a variety of federal and state environmental

programs with monthly updates and newsletters.

Business & Legal Reports, Inc.

(1-800-727-5257)

Access to federal and state regulations with monthly, updates

on available on CD-ROM.

Aspen Law and Business

(1-800-638-8437)

Publishes compliance manuals with regular update service for

RCRA and Clean Air Act.
© 2001 NSF 113

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Sample Process Tool:

Setting Objectives & Targets
© 2001 NSF 114

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Sample Process Tool for Setting Objectives & Targets

Step 1: A cross-functional team is a good way for your organization to set realistic objectives

and targets. List here who needs to be involved on the team:

Name

•

•

•

•

•

•

Contacted?

•

•

•

•

•

•

Step 2: Think about what information sources your team will need to establish objectives and

targets. Pull together information sources such as:

Information Sources

• process maps

• waste, and emission data

• site maps

• compliance audit reports

• list of identified environmental aspects and

impacts

• communications from interested parties

• others??

•

•

(you may also want to do a plant tour or “walk

through” to identify other issues)

How they will help

e.g.,

• identify process steps with environmental

aspects

• determine current wastes and sources

• etc.

Step 3: Is there other information that might be helpful to the team?

Other Information Needed

•

•

•

Where we will get it

•

•

•
© 2001 NSF 115

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Step 4: List the significant environmental impacts (you identified these earlier). You can

categorize these impacts by type:

Energy

Use

Raw

Materials

Air

Impacts

Water

Impacts

Waste

Impacts

Land

Issues

Other

(specify)

Step 5: Look at processes (such as plating or assembly) and activities (such as shipping or

purchasing). Are there any other issues the team should consider, in addition to those

listed above as significant impacts? (For example, you might want to establish an

objective to reduce spills of hazardous materials at the loading dock, even if this was not

identified as a potentially significant environmental impact.)

Process or activity Issues Possible Objectives & Targets

Step 6: List any new regulatory requirements that affect the facility (or other regulations for

which the need for additional actions has been identified).

Regulations, other requirements Possible Objectives & Targets

Step 7: Consider inputs from interested parties. Any need for additional objectives related to

views of neighbors, community groups or other parties?

Inputs from Interested Parties Possible Objectives & Targets
© 2001 NSF 116

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Step 8: Look at the lists of possible objectives developed in Steps 4 -7. Brainstorm

with the team on whether these objectives are:

• reasonable,

• technologically feasible,

• consistent with other organizational plans/goals, and

• affordable.

List preliminary objectives and targets based on this exercise:

Selected Preliminary Objectives

•

•

•

•

•

Step 9: Determine how you will measure each of the selected preliminary objectives. (If you

cannot establish an effective way to measure it, put that objective “on-hold” for later

consideration).

Selected Objectives Performance Indicator(s)

Step 10: For each objective that you selected, determine who is going to develop the action plan

(who, what, when, where, how). List these names below:

Selected Objectives Responsibility for Action Plan
© 2001 NSF 117

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Sample Procedure:

Setting Objectives & Targets
© 2001 NSF 118

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EMS PROCEDURE: SETTING AND TRACKING OF ENVIRONMENTAL

OBJECTIVES AND TARGETS

I. Purpose

The purpose of this procedure is to ensure that the organization establishes and maintains

documented environmental objectives and targets.

II Scope

This procedure applies to environmental objectives and targets set at all relevant levels

within the organization.

III. Definitions

Environmental (or environmental) objective- A site goal that is consistent with the

environmental policies and considers significant environmental impacts and applicable laws

and regulations. Objectives are quantified wherever practicable.

Environmental (environmental) target- A detailed performance requirement (quantified

wherever practicable) based on an environmental objective. A target should be met in order

for the underlying objective to be achieved.

IV. General

The organization establishes environmental objectives and targets in order to implement the

environmental policies. Objectives and targets also provide a means for the organization to

measure the effectiveness of its environmental efforts and improve the performance of the

environmental management system. In establishing environmental objectives, the

organization considers:

• applicable laws and regulations (and requirements of other programs, such as ...);

• environmental aspects of the organization’s activities and products;

• technological, financial, operational, and other organizational requirements; and,

• the views of employees and other interested parties.

Based on the organization 's environmental objectives, targets are established for different

functions within the organization and for different areas of the plant. For example, the

organization may establish an environmental objective to "reduce waste generation by 10%

per year". Based on this objective, different areas of the plant might set targets for reducing

individual waste streams in order to ensure that the organization’s objective was achieved.

An organization-wide environmental objective might also be translated into individual

projects (such as changes in production processes, materials or pollution control equipment)

in different plant areas.
© 2001 NSF 119

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V. Procedure

A. The organization’s top management is responsible for establishing environmental

objectives on an annual basis. To initiate the process, the Plant Manager holds a

meeting of all staff members to discuss the development of environmental objectives.

B. Objectives are action- and prevention-oriented and are intended to result in meaningful

improvements in the organization 's environmental performance.

C. Each plant area or functional manager is responsible for providing input from his / her

own function (Finance, Engineering, etc.) or shop area (Fabrication, Assembly, Shipping /

Receiving, etc.). The organization’s environmental manager is responsible for providing

input on applicable laws and regulations, significant site environmental impacts, and the

views of interested parties. (These inputs are obtained from the separate analyses

required by Procedure #'s).

D. As a starting point, the organization’s management evaluates its performance against

environmental objectives for the current year. As part of this effort, management

examines the results of its environmental performance evaluations.

E. Preliminary environmental objectives are developed for further discussion and evaluation.

Each manager is responsible for evaluating the potential impacts within his / her

functional or shop area (if any) of the proposed environmental objectives. The

organization’s environmental manager reviews proposed objectives to ensure

consistency with the overall environmental policy.

F. Environmental objectives are finalized, based on review comments from site managers

and employees. Each manager identifies the impacts of the objectives in his / her

function or shop area, establishes targets to achieve the objectives, and develops

appropriate measures to track progress towards meeting the objectives and targets.

G. Each manager is responsible for communicating objectives and targets (and the means

for achieving them) to others in his / her part of the organization.

H. Progress towards the objectives and targets is reviewed on a regular basis at

management meetings. The progress is also communicated to plant employees via

bulletin boards and other similar means.

I. At the end of each calendar year, the organization’s management reviews its performance

with regard to achieving the objectives and targets. This information is used as input to

setting objectives and targets for the succeeding year.
© 2001 NSF 120

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Sample Tools:

Environmental Management Program
© 2001 NSF 121

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Sample Environmental Management Program Form

(Note: Use one form per objective)

Date Individual Responsible:

(_____/_____/____)

Environmental Objective:

Related Target(s):

Related Significant Environmental Aspect(s):

Specific Function and/or Department:

Target Date (Month/Year): (____________/____________)

Environmental Management Program: Action Plan

How will this objective be met? (attach additional pages as necessary)

What operational controls might support the achievement of this objective?

How will this objective be tracked? (attach additional pages as necessary)

What resources will be required to achieve this objective? (attach additional

pages as necessary)

Adapted from the EPA/NSF guide “Environmental Management Systems: A Guide for Metal

Finishers” (December 1998). Available for free download at www.nsf-isr.org.
© 2001 NSF 122

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Environmental Management Program - Sample Tool

Objective / Target #1: ________________

Action Items Priority Responsibilities Schedule Resources

Needed Comments
© 2001 NSF 123

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Sample Responsibility Matrix
© 2001 NSF 124

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Plant

M’gr

EHS

M’gr

HR

M’gr

Maintenance Purchasing /

Materials

Engineering Production

Supervisor(s)

Finance EMS

Mg’t Rep.

Employees

Communicate importance of

environmental management

L S S

Coordinate auditing efforts L S S

Track / analyze new

regulations (and maintain

library)

L

Obtain permits and develop

compliance plans

L S

Prepare reports required by

regulations

L

Coordinate communications

with interested parties

L

Train employees S L

Integrate environmental into

recruiting practices

L

Integrate environmental into

performance appraisal

process

L

Communicate with

contractors on

environmental expectations

L

Comply with applicable

regulatory requirements

L L S S S S S S S S

Conform with organization's

EMS requirements

L L S S S S S S S S

Maintain equipment / tools

to control environmental

impact

L

Monitor key processes S L

Coordinate emergency

response efforts

L S

Identify environmental

aspects of products,

activities, or services

S L S S S S S S S

Establish environmental

objectives and targets

L S S

Develop budget for

environmental management

S L

Maintain EMS records

(training, etc.)

L

Coordinate EMS document

control efforts

S L

Responsibility Matrix

Legend:

L = Lead Role

S = Supporting Role
© 2001 NSF 125

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Sample Environmental Training Log
© 2001 NSF 126

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EMS Training Log (Sample)

Training Topic Attendees* Frequency Course Length Course

Method

Comments Date

Completed

EMS Awareness

Supervisor EHS Training

Hazardous Waste

Management

Hazardous Waste

Operations

Spill Prevention &

Response

Chemical Management

Emergency Response

Accident Investigation

Hazardous Materials

Transport

Hazard Communication

Personal Protective

Equipment

Fire Safety

Electrical Safety

Hearing Conservation

Confined Space Entry

Lock-out/Tag-out

Bloodborne Pathogens

Job-Specific Training (list)

Attendees Code

1: All Employees

2: Supervisors / Managers

3: Operators

4: Maintenance

5: Material Handlers

6: Engineering
© 2001 NSF 127

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Sample Procedure:

Communications with External

Parties
© 2001 NSF 128

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EMS PROCEDURE: COMMUNICATIONS

WITH EXTERNAL PARTIES

I. Purpose

This procedure is intended to establish a process for outreach and communication

with external parties regarding the organization's environmental management system

(Note: the organization should also consider external communication regarding its

significant environmental aspects).

II. Scope

This procedure describes how the organization receives, documents, and responds to

communications from external parties. In addition, it discusses proactive steps that

the organization takes to maintain a meaningful dialogue with external parties on

environmental matters.

III. Definitions

Interested Parties- Individuals or groups with an interest in the environmental impacts

of the organization's products, activities or services. These parties include regulators,

local residents, employees, stockholders, insurers, customers, environmental groups

and the general public (adapted from ISO 14001).

IV. General

The organization uses a number of mechanisms to ensure effective communication

with interested parties. These mechanisms include regulatory filings (such as permit

applications and reports), open houses, the media, and informal discussions with

regulators, community representatives, and local business leaders.

To solicit the views of interested parties, the organization may use additional

techniques, including (but not limited to) surveys, community advisory panels,

newsletters, or informal meetings with representatives of external groups.

General rules for external communications require that the information provided by the

organization:

• be understandable and adequately explained to the recipient(s); and

• present an accurate and verifiable picture of the organization and its

environmental management system, its environmental performance, or other

related matters.
© 2001 NSF 129

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V. Procedure

A. Management of Communications from External Parties

1. Inquiries and other communications (received by mail, fax, telephone, or in

person) from external parties concerning the organization's EMS or

environmental performance may be received by a number of the

organization’s representatives, including the Plant Manager, the

environmental manager, and the human resources manager, among others.

All such communications are reviewed by the Plant Manager or his / her

designee to determine the appropriate response.

2. Communication with representatives of regulatory agencies is delegated to

the organization’s environmental manager, who maintains records of all

such communications (both incoming and outgoing). In the absence of the

environmental manager, communications with regulatory officials are

delegated to the human resources manager.

3. Copies of all other written communications on environmental matters are

maintained by the human resources manager. All non-written

communications from external parties are documented using telephone logs

or similar means. All records of external communications are maintained as

discussed in Procedure # (Records Management).

4. A record of the responses to all communications from external parties is

maintained by the human resources manager in files designated for that

purpose.

B. Outreach to Interested Parties

1. The organization solicits the views of interested parties on its environmental

management system, its environmental performance, and other related

matters. In particular, such outreach is conducted when significant changes

at the facility are being considered, such as facility expansion or other

actions that might affect the actual or potential environmental impacts of the

organization’s products, activities, or services.

2. As part of the Management Review process, the team designated to

conduct the Review evaluates proactive efforts to communicate with

external parties. Based on this evaluation and other factors, the

organization’s management determines the need for outreach with external

parties in the coming year and how such communications can be carried

out most effectively.

External Hazard and Emergency Communication

Note: All external communications regarding emergency response are addressed in

Procedure #.
© 2001 NSF 130

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Sample Document Index
Sample Document Index

(sample indicates individual that revised document, his/her position/department and date(s) of revision)

© 2001 NSF 131

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Document 1 2 3 4 5 6

Environmental Policy John Smith

Plant Manager

1/1/98

John Smith

Plant Manager

1/1/99

Environmental Manual

Procedure 1:

Environmental Aspects

Identification

Procedure 2: Access to

Laws and Regulations

Procedure 3: Setting

Objectives & Targets

Procedure 4:

Environmental Training

Procedure 5: External

Communications

Procedure 6: Internal

Communications

Procedure 7: Document

Control

Procedure 8:

Emergency

Preparedness

Procedure 9: Corrective

Action

Procedure 10: Records

Management

Procedure 11: EMS

Audits

Procedure 12:

Management Reviews

Procedures 13-X (list

individually)

EMS Audit Checklist

Other plans &

documents related to

above procedures (list

separately, e.g. SPCC

Plan, Emergency

Response Plan, etc.).

Other forms and

checklists (list)

Revision Number
© 2001 NSF 132

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Outline of Sample

EMS Manual and

Other EMS Documents
© 2001 NSF 133

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Outline of Sample EMS Manual and Other EMS Documents

Basic EMS Manual

• Index / Revision History / Distribution List

• Environmental Policy

• Description of How Our EMS Addresses Each of the EMS Elements (and linkages

among these elements)

- How We Identify Significant Environmental Aspects

- How We Access and Analyze Legal and Other Requirements

- How We Establish and Maintain Objectives and Targets

- How the Organizational Structure Supports EMS (organization charts, key

responsibilities)

- How We Train our Employees and Ensure Competence

- How We Communicate (internally and externally)

- How We Control EMS Documents

- How We Identify Key Processes and Develop Controls for them

- How We Prepare for and Respond to Emergencies

- How We Monitor Key Characteristics of Operations and Activities

- How We Identify, Investigate and Correct Nonconformance

- etc.

Environmental Management Program Description

• Annual Objectives and Targets

• Action Plans (to achieve objectives and targets)

• Tracking and Measuring Progress

EMS Procedures

• Index / Revision History / Distribution List

• Organization-wide Procedures (for some EMS elements there might be more than

one procedure)

- Environmental Aspects Identification

- Access to Legal and Other Requirements

- Training, Awareness and Competence

- Internal Communication

- External Communication

- Document Control

- Change Management Process(es)

- Management of Suppliers / Vendors

- Emergency Preparedness and Response

- Monitoring and Measurement

- Calibration and Maintenance of Monitoring Equipment

- Compliance Evaluation

- Corrective and Preventive Action

- Records Management

- EMS Auditing

- Management Review

• Procedures / Work Instructions for Specific Operations or Activities

- Waste Management

- Wastewater Treatment (These are examples only)

- Operation of the Paint Line

Other EMS Documentation (Emergency Response Plans, etc.)
© 2001 NSF 134

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Sample Records Management Form

(supplied courtesy of

General Oil Company)
© 2001 NSF 135

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Title: EMS RECORDS MANAGEMENT TABLE

Revision Date: November 7, 2000

Print Date: January 29, 2001 (Uncontrolled document if

printed)

Doc. No.: EMF-4.5.3

Approval by:

Page 135 of 1

EMS Records Management Table

The following table lists records related to the Environmental Management System, in

accordance with EMP-4.5.3 (Record keeping procedure).

Record Type Person Responsible Location File

Method

Retention

minimum

ADMINISTRATION

Records on costs - purchasing,

operations, and disposal

Office Manager Admin. Office Date order 3 years

Utility bills Office Manager Admin. Office Date order 3 years

Record of annual waste quantity

received

Office Manager Admin. Office Date order Life of Co.

Certificates of Insurance Office Manager Admin. Office Date order Life of

Company

Waste Analysis Sheets Office Manager Admin. Office Customer

name

3 years

Waste Manifests - outgoing Office Manager Admin. Office Date order 3 years

ENVIRONMENTAL

Incident Reports Env. Dept. Env. Office Date order 3 years

Complaint Reports Env. Dept. Env. Office Date order 3 years

EMS Communications with external

parties

Env. Dept. Env. Office Issue 3 years

Decision regarding external

communication of significant

environmental aspects

Env. Dept. Env. Office Date order 3 years

Major Source Determination Records Env. Dept. Env. Office Date order Life of Co.

Title V Permit Exemption Env. Dept. Env. Office Date order Life of

Company

Correspondence regarding Air Notices Env. Dept. Env. Office Date order 5 years

Odor Control System Permit Env. Dept. Env. Office Date order 5 years or

per Permit

Air Emission Reports Env. Dept. Env. Office Date order 5 years

Records on waste disposal sites used Env. Dept. Env. Office Site name Life of Co.

EMS Monitoring Inspection reports Env. Dept. Env. Office Date order 5 years
© 2001 NSF 136

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Sample Procedure:

Corrective and Preventive Action

(includes tracking log)
© 2001 NSF 137

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EMS PROCEDURE: PREVENTIVE AND CORRECTIVE ACTION

I. Purpose

The purpose of this procedure is to establish and outline the process for identifying,

documenting, analyzing, and implementing preventive and corrective actions.

II. Scope

Preventive or corrective actions may be initiated using this procedure for any environmental

problem affecting the organization.

III. General

A. Corrective action is generally a reactive process used to address problems after they

have occurred. Corrective action is initiated using the Corrective Action Notice (CAN)

document as the primary vehicle for communication. Corrective action may be triggered

by a variety of events, including internal audits and management reviews. Other items

that might result in a CAN include neighbor complaints or results of monitoring and

measurement.

B. Preventive action is generally a proactive process intended to prevent potential problems

before they occur or become more severe. Preventive action is initiated using the

Preventive Action Notice (PAN). Preventive action focuses on identifying negative trends

and addressing them before they become significant. Events that might trigger a PAN

include monitoring and measurement, trends analysis, tracking of progress on achieving

objectives and targets, response to emergencies and near misses, and customer or

neighbor complaints, among other events.

C. Preventive and corrective action notices are prepared, managed and tracked using the

preventive and corrective action database.

D. The ISO Management Representative (or designee) is responsible for reviewing issues

affecting the EMS, the application and maintenance of this procedure, and any updates to

EMS documents affected by the preventive and corrective actions.

E. The ISO Management Representative is responsible for logging the PAN or CAN into the

database, and tracking and recording submission of solutions in the database. The

requester and recipient of the CAN or PAN are responsible for verifying the effectiveness

of the solution. The ISO Management Representative is responsible for overall tracking

and reporting on preventive and corrective actions.

F. Personnel receiving PAN’s and CAN’s are responsible for instituting the required

corrective or preventive action, reporting completion of the required action to the ISO

Management Representative, and assuring sustained effectiveness.
© 2001 NSF 138

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III. General (cont’d.)

G. Completed records of PAN’s and CAN’s are maintained in the database for at least two

years after completion of the corrective or preventive action.

IV. Procedure

A. Issuing a CAN or PAN

1. Any employee may request a CAN or PAN. The employee requesting the CAN or

PAN is responsible for bringing the problem to the attention of the ISO Management

Representative. The ISO Management Representative is responsible for

determining whether a CAN or PAN is appropriate and enters the appropriate

information into the corrective and preventive action database. Responsibility for

resolving the problem is assigned to a specific individual (“the recipient”).

2. The ISO Management Representative, working with the recipient, determines an

appropriate due date for resolving the CAN or PAN.

B. Determining and Implementing Corrective and Preventive Actions

1. The CAN or PAN is issued to the recipient, who is responsible for investigation and

resolution of the problem. The recipient is also responsible for communicating the

corrective or preventive action taken.

2. If the recipient cannot resolve the problem by the specified due date, he / she is

responsible for determining an acceptable alternate due date with the ISO

Management Representative.

C. Tracking CAN’s and PAN’s

1. CAN’s or PAN’s whose resolution dates are overdue appear on the Overdue

Solutions report. The ISO Management Representative is responsible for issuing

this report on a weekly basis to the Plant Manager and the recipients of any

overdue CANs or PANs.

2. Records of PANs and CANs are maintained in the database for at least two years

after completion of the corrective or preventive action.

D. Tracking Effectiveness of Solutions

1. The recipient of a CAN or PAN, in conjunction with the requester, are responsible for

verifying the effectiveness of the solution. If the solution is deemed not effective, the

CAN or PAN will be reissued to the original recipient.
© 2001 NSF 139

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SAMPLE CORRECTIVE ACTION NOTICE

CAN Number: Issue Date: Solution Due Date:

Name Location Phone:

Requested By:

Issued To:

Problem Statement (completed by ISO Management Representative):

Most Likely Causes (completed by ISO Management Representative):

Implemented Solutions (completed by recipient - include dates as applicable):

Results (confirming effectiveness):

Closed by: Closing Date:
© 2001 NSF 140

A

CORRECTIVE ACTION TRACKING LOG

CAN

Number

Requested

By

Issued

To

Plan

Due

(Date)

Plan

Completed

(Date)

Corrective

Action

Completed

(Date)

Effectiveness

Verified

(Date)

CAN

Closed

(Date)
© 2001 NSF 141

A

Sample Environmental

Records Organizer
© 2001 NSF 142

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Environmental Records Organizer (SAMPLE)

Air Emissions Regulations

Air Emissions Fees

Air Emissions Inventories

Air Emissions Permits

Air Permit Applications

Air Permit(s): Historical

Annual Licenses & Fees

Compliance Reporting

Compliance Plans

Community Right-to-Know

EPCRA Regulations

EPCRA Reporting

Hazardous Waste Regulations

Hazardous Waste Permit/ID Number

Hazardous Waste Fees

Hazardous Waste Biennial Report

Hazardous Waste: Open Manifests

Hazardous Waste: Closed Manifests

Historical Data

Indoor Air Quality

Loss Prevention Information

Other Permits & Permit Applications

Pollution Prevention (P2) Regulations

Pollution Prevention Fees

Pollution Prevention Reporting

Recycling Information

Recycling Projects

Special Wastes

Solid Waste Permit

Solid Waste Fees

Spill Reports

Spill Response Actions

Stormwater Regulations

Stormwater Permit

VOC/HAPs Reporting

VOC Annual Analysis

Wastewater Regulations

Wastewater Fees

Wastewater Permit

Wastewater: Semi-Annual Reporting
© 2001 NSF 143

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Sample Procedure: EMS Audits
© 2001 NSF 144

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EMS Procedure: Environmental Management System Audits

I. Purpose

To define the process for conducting periodic audits of the environmental management

system (EMS). The procedure defines the process for scheduling, conducting, and

reporting of EMS audits.

II. Scope

This procedure applies to all internal EMS audits conducted at the site.

The scope of EMS audits may cover all activities and processes comprising the EMS or

selected elements thereof.

III. General

Internal EMS audits help to ensure the proper implementation and maintenance of the EMS

by verifying that activities conform with documented procedures and that corrective actions

are undertaken and are effective.

All audits are conducted by trained auditors. Auditor training is defined by Procedure #.

Records of auditor training are maintained in accordance with Procedure #.

When a candidate for EMS auditor is assigned to an audit team, the Lead Auditor will

prepare an evaluation of the candidate auditor’s performance following the audit.

The ISO Management Representative is responsible for maintaining EMS audit records,

including a list of trained auditors, auditor training records, audit schedules and protocols,

and audit reports.

EMS audits are scheduled to ensure that all EMS elements and plant functions are audited

at least once each year.

The ISO Management Representative is responsible for notifying EMS auditors of any

upcoming audits a reasonable time prior to the scheduled audit date. Plant areas and

functions subject to the EMS audit will also be notified a reasonable time prior to the audit.

The Lead Auditor is responsible for ensuring that the audit, audit report and any feedback to

the plant areas or functions covered by the audit is completed per the audit schedule.

The ISO Management Representative, in conjunction with the Lead Auditor, is responsible

for ensuring that Corrective Action Notices are prepared for audit findings, as appropriate.
© 2001 NSF 145

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IV. Procedure

A. Audit Team Selection - One or more auditors comprise an audit team. When the team

consists of more than one auditor, a Lead Auditor will be designated. The Lead Auditor is

responsible for audit team orientation, coordinating the audit process, and coordinating

the preparation of the audit report.

B. Audit Team Orientation - The Lead Auditor will assure that the team is adequately

prepared to initiate the audit. Pertinent policies, procedures, standards, regulatory

requirements and prior audit reports are made available for review by the audit team.

Each auditor will have appropriate audit training, as defined by Procedure #.

C. Written Audit Plan - The Lead Auditor is responsible for ensuring the preparation of a

written plan for the audit. The Internal EMS Audit Checklist may be used as a guide for

this plan.

D. Prior Notification - The plant areas and / or functions to be audited are to be notified a

reasonable time prior to the audit.

E. Conducting the Audit

1. A pre-audit conference is held with appropriate personnel to review the scope, plan

and schedule for the audit.

2. Auditors are at liberty to modify the audit scope and plan if conditions warrant.

3. Objective evidence is examined to verify conformance to EMS requirements,

including operating procedures. All audit findings must be documented.

4. Specific attention is given to corrective actions for audit findings from previous audits.

5. A post-audit conference is held to present audit findings, clarify any

misunderstandings, and summarize the audit results.

F. Reporting Audit Results

1. The Team Leader prepares the audit report, which summarizes the audit scope,

identifies the audit team, describes sources of evidence used, and summarizes the

audit results.

2. Findings requiring corrective action are entered into the corrective action database.
© 2001 NSF 146

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IV. Procedure (cont’d.)

G. Audit Report Distribution

1. The ISO Management Representative is responsible for communicating the audit

results to responsible area and / or functional management. Copies of the audit

report are made available by the ISO Management Representative.

2. The ISO Management Representative is responsible for ensuring availability of audit

reports for purposes of the annual Management review (see Procedure #).

H. Audit Follow-up

1. Management in the affected areas and / or functions is responsible for any follow-up

actions needed as a result of the audit.

2. The ISO Management Representative is responsible for tracking the completion and

effectiveness of corrective actions.

I. Record keeping

1. Audit reports are retained for at least two years from the date of audit completion.

The ISO Management Representative is responsible for maintaining such records.
© 2001 NSF 147

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Audit Plan

Area or

Function to be

Audited

Lead

Auditor

Audit Team

Members

Target

Date

Special Instructions

• Purchasing • Jim H. • Linda B.

• Joe S.

• 11/10/00 - Verify corrective actions

from previous audit

- Interview new employee

in department

• • • • •

• • • • •

• • • • •

• • • • •

• • • • •

• • • • •
© 2001 NSF 148

A

Sample Communications to Audit Team

ENVIRONMENTAL MANAGEMENT SYSTEM AUDIT

Lead Auditor:

Audit Team Members:

Audit Area: Target Due Date:

Listed above is the area to be audited. The due date given is the target to have the entire audit

completed, including the report and follow-up meeting with the responsible area management. Listed

below are the areas of environmental management systems criteria that you are to assess. If you

have any questions, please call me. Special instructions, if any, are listed below. Thank you for your

help. Effective audits help make an effective environmental management system.

__ Policy __ Legal and Other Requirements

__ Environmental Aspect identification __ Objectives and Targets

__ Environmental Management Program __ Structure and Responsibility

__ Training, Awareness, Competence __ Communication

__ EMS Documentation __ Document Control

__ Operational Controls __ Emergency Preparedness

__ Monitoring and Measurement __ Nonconformance / Corrective Action

__ Records

__ Management System Audits

__ Management Review

Special Instructions:

ISO Representative (signature)
© 2001 NSF 149

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Sample EMS Audit Forms
© 2001 NSF 150

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EMS AUDIT SUMMARY SHEET

Organization Audited:______________________________________________

Lead Auditor: Date: 

ELEMENT NUMBER AND DESCRIPTION AUDIT RESULTS

No. of Majors / No. of Minors A, N, or X*

4.2 Environmental Policy

4.3 Planning

4.3.1 Environmental Aspects

4.3.2 Legal and Other Requirements

4.3.3 Objectives and Targets

4.3.4 Environmental Management Program(s)

4.4 Implementation and Operation

4.4.1 Structure and Responsibility

4.4.2 Training, Awareness, and Competence

4.4.3 Communication

4.4.4 EMS Documentation

4.4.5 Document Control

4.4.6 Operational Control

4.4.7 Emergency Preparedness and Response

4.5 Checking and

Corrective Action

4.5.1 Monitoring and Measurement

4.5.2 Corrective and Preventive Action

4.5.3 Records

4.5.4 EMS Audit

4.6 Management Review

TOTAL

Legend:

A = Acceptable: Interviews and other objective

evidence indicate that the EMS meets all the

requirements of that section of the standard.

N = Not Acceptable: The auditor has made

the judgment that, based on the number and

type of nonconformances, the requirements

of that the section of the standard are not

being met.

X = Not Audited
© 2001 NSF 151

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EMS AUDIT FINDINGS FORM

Type of Finding (circle one):

 Nonconformance: Major Minor Positive Practice Recommendation

Description (include where in the organization the finding was identified):

_________________________________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________

__________________________________________________________

ISO 14001 (or other EMS criteria)

Reference:

_________________________________

Date:

_______________

Finding Number:

_______________

Auditor:__________________________ Auditee’s Rep.: ______________________

Corrective Action Plan (including time frames):

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

___________________________________________________________________

Preventive Action Taken:

________________________________________________________________________

_________________________________________________________________________

_______________________________________________________________________

Individual Responsible for Completion of the

Corrective Action:

________________________________________

Date Corrective Action Completed:

_____________________________

Corrective Action Verified By:

______________________________________________________Date:______________
© 2001 NSF 152

A

Sample EMS Audit Questions

(by organizational function)

The following questions are excerpted from a

comprehensive list of EMS audit questions contained in

the NSF-ISR project report, “Implementing Environmental

Management Systems in Community-Based

Organizations: Part 2”.

For a complete list of EMS audit questions by function,

download Part 2 of the project report from the NSF web

site (www.nsf-isr.org)
© 2001 NSF 153

A

Function: TOP MANAGEMENT

4.2 Environmental Policy

Top Management Objective Evidence

a. Describe your role in the development of the

environmental policy.

b. How do you know that your policy is

appropriate for your activities, products, and

services?

c. What is management’s role in the review and

revision of the policy?

d. How does management ensure continued

adherence to the policy throughout the

company?

e. How does the policy help guide organizational

decisions?

f. How are employees made aware of the

environmental policy?

g. How is the policy made available to the public?

[Auditor Note: Is there evidence that the policy was

issued by top management? (e.g., Is the policy signed?

By whom? At what level in the organization are they?)]

Notes:
© 2001 NSF 154

A

Function: TOP MANAGEMENT

4.3.3 Objectives and targets

Top Management Objective Evidence

a. What are the environmental objectives and

targets for your organization? What is your role

in approving them?

What are the relevant functions and levels within

your organization that support the attainment

each of the objectives and targets?

b. How are the environmental objectives linked to

other organizational goals (and vice versa)?

c. Are the objectives/targets consistent with the

goals of the environmental policy for prevention

of pollution and continual improvement?

d. How were the objectives and targets developed

by or communicated to management?

e. How does management keep up with progress

in meeting their objectives and targets

throughout the year?

f. How often are you informed of the status of the

objectives and targets?

g. On what basis are the objectives and targets

reviewed and modified?

Notes:
© 2001 NSF 155

A

Function: TOP MANAGEMENT

4.4.1 Structure and responsibility

Top Management Objective Evidence

a. At what level within the organization is the

designated EMS representative placed?

Auditor Note: Is the EMS representative at a level within

the organization to effectively implement an EMS for

his/her organization?]

b. What authority does the EMS representative

have to carry out his/her responsibilities?

c. How does the organization assess its resource

needs for environmental management? How

are these factored into operating and strategic

plans (and vice-versa)?

d. What resources (financial, technical personnel)

has management provided to develop or

maintain the EMS?

e. How are you informed on the performance of

the EMS? Do you receive routine reports?

f. Are responsibilities for the environmental

management of the organization documented?

If so, where?

Is an integrated structure in place in which

accountability and responsibility are defined,

understood, and carried out?

g. How are these responsibilities communicated to

all employees (including managers)?

Notes:
© 2001 NSF 156

A

Function: TOP MANAGEMENT

4.4.3 Communication

Top Management Objective Evidence

a. How are you informed of the environmental

issues within your organization? How often

does this take place? Does this include

compliance issues?

b. How are you kept up to date with progress in

meeting your organization’s environmental

objectives and targets?

How is this information passed on to your

managers?

c. How do you communicate with the 

organization on environmental issues?

How is this done? How frequently?

d. How does the organization handle inquiries

from interested parties (e.g., the public,

regulators, other organizations) on

environmental matters?

Who has responsibility for responding to such

inquiries?

4.6 Management review

Top Management Objective Evidence

a. Describe the organization’s management

review process.

b. How often are management reviews

performed? How was this frequency

determined?

c. Who is involved in the management review

process? What are their roles in this process?

d. What changes have been made to the EMS as a

result of the last review?

Notes:
© 2001 NSF 157

A

Sample Procedure:

Management Review
© 2001 NSF 158

A

EMS PROCEDURE: MANAGEMENT REVIEW

I. Purpose

The purpose of this procedure is to document the process and primary agenda of issues to

be included in the Management Review meetings for evaluating the status of the

organization’s environmental management system (EMS).

II. Scope

This procedure applies to all Management Review meetings conducted by the organization.

III. General

The Management Review process is intended to provide a forum for discussion and

improvement of the EMS and to provide management with a vehicle for making any

changes to the EMS necessary to achieve the organization’s goals.

IV. Procedure

A. The ISO Management Representative is responsible for scheduling and conducting a

minimum of two Management Review meetings during each 12-month period. The ISO

Management Representative is also responsible for ensuring that the necessary data and

other information are collected prior to the meeting.

B. At a minimum, each Management Review meeting will consider the following:

• suitability, adequacy and effectiveness of the environmental policy;

• suitability, adequacy and effectiveness of the environmental objectives (as well as

the organization’s current status in achieving these objectives);

• overall suitability, adequacy and effectiveness of the EMS;

• status of corrective and preventive actions;

• results of any EMS audits conducted since the last Management Review meeting;

• suitability, adequacy and effectiveness of training efforts; and,

• results of any action items from the previous Management Review meeting.

C. Minutes of the Management Reviews will be documented and will include, at a minimum

the list of attendees, a summary of key issues discussed and any actions items arising

from the meeting.

D. A copy of the meeting minutes will be distributed to attendees and any individuals

assigned action items. A copy of the meeting minutes will also be retained on file.
© 2001 NSF 159

B

Appendix B:

EPA’s National Environmental Performance

Track and Other Government EMS Initiatives
© 2001 NSF 160

B

National Environmental Performance Track Program

The National Environmental Performance Track is designed to recognize and encourage top

environmental performers – those who go beyond compliance with regulatory requirements

to attain levels of environmental performance and management that benefit people,

communities, and the environment. As top environmental performers, participants earn

access to a unique reward package that includes recognition, better information, and

administrative streamlining.

The Performance Track consists of two levels. The first level, the National Environmental

Achievement Track, is available now and is open to facilities of all types, sizes, and

complexity, public or private, manufacturing or service-oriented. It is designed to recognize

facilities that consistently meet their legal requirements and have implemented high-quality

environmental management systems, as well as encourage them to even better

achievement by continuously improving their environmental performance and informing and

involving the public. The second level, the National Environmental Stewardship Track, is

designed to recognize and encourage broader and higher levels of voluntary environmental

performance than those expected under the Achievement Track. The Stewardship Track is

still under development, and EPA plans to have it available by May 2001.

Any program for improving environmental performance must aim for participation by small

businesses and other small entities, such as local governments. EPA is making every effort

to make the Achievement Track accessible for small entities. This effort is reflected in

several aspects of the design. For example, depending on the nature and extent of a

facility’s operations, the EMS for a small facility may be simpler than one for a larger, more

complex facility. For the same reason, a small facility may have fewer environmental

aspects. In addition, a small facility is not asked to make as many performance

commitments as other participants.

Environmental Management System (EMS) Requirements

Facilities wanting to participate in the Performance Track must meet several requirements.

A facility will certify that it has an EMS in place.1 The EMS will include the elements listed

below and will have gone through at least one full cycle of implementation (i.e., planning,

setting performance objectives, EMS program implementation, performance evaluation, and

management review). A facility that has adopted systems based on EMS models with a

Plan-Do-Check-Act framework would meet most of these elements.

EPA recognizes that the scope and level of formality of the EMS will vary, depending on the

nature, size, and complexity of the facility. EPA's experience with a variety of programs

suggests that these EMS elements are within the capability of small facilities and can be met

through a variety of approaches. To help small facilities implement an EMS, EPA will make

guidance documents and assistance materials available.

A facility will certify that it has implemented an EMS that includes these elements:

 

1

 For purposes of the Achievement Track, an EMS represents an organization’s systematic

efforts to meet its environmental requirements, including maintaining compliance and

achieving performance objectives that may be related to unregulated aspects of the

organization’s activities.
© 2001 NSF 161

B

Policy

A written environmental policy, defined by top facility management, that includes

commitments to: (1) compliance with both legal requirements and voluntary

commitments; (2) pollution prevention (based on a pollution prevention hierarchy

where source reduction is the first choice); (3) continuous improvement in

environmental performance, including areas not subject to regulations; and (4)

sharing information about environmental performance and the operation of the EMS

with the community.

Planning

• Identification of significant environmental aspects2 and legal requirements, including

procedures for integrating anticipated changes to the facility's requirements or

commitments into the EMS.

• Measurable objectives and targets to meet policy commitments and legal

requirements, to reduce the facility’s significant environmental impacts, and to

meet the performance commitments made as part of the facility’s participation in

the program. In setting objectives and targets, the facility should consider the

following criteria: preventing non-compliance, preventing pollution at its source,

minimizing cross-media pollutant transfers, and improving environmental

performance.

• Active, documented programs to achieve the objectives, targets, and

commitments in the EMS, including the means and time-frames for their

completion

Implementation and Operation

• Established roles and responsibilities for meeting objectives and targets of the

overall EMS and compliance with legal requirements, including a top

management representative with authority and responsibility for the EMS.

• Defined procedures for: (1) achieving and maintaining compliance and meeting

performance objectives; (2) communicating relevant information regarding the

EMS, including the facility’s environmental performance, throughout the

organization; (3) providing appropriate incentives for personnel to meet the EMS

requirements; and (4) document control, including where documents related to

the EMS will be located and who will maintain them.

• General environmental training programs for all employees, and specific training

 

2

 An “environmental aspect” is defined as an “element of an organization’s activities,

products, or services that can interact with the environment.” Facilities are asked to use their

list of significant environmental aspects in selecting performance commitments under this

program.
© 2001 NSF 162

B

for those whose jobs and responsibilities involve activities directly related to

achieving objectives and targets and to compliance with legal requirements.

• Documentation of the key EMS elements, including the environmental policy,

significant environmental aspects, objectives and targets, a top management

representative, compliance audit program, EMS audit program, and overall EMS

authority.

• Operation and maintenance programs for equipment and for other operations

that are related to legal compliance and other significant environmental aspects.

• An emergency preparedness program.

Checking and Corrective Action

• An active program for assessing performance and preventing and detecting nonconformance with legal and other requirements of the EMS, including an

established compliance audit program and an EMS audit program.

• An active program for prompt, corrective action of any non-conformance with

legal requirements and other EMS requirements.

Management Review

• Documented management review of performance against the established

objectives and targets and the effectiveness of the EMS in meeting policy

commitments.

*******

Although a third-party audit of the EMS is not necessary to qualify for the Achievement

Track, a facility is asked in the application form if it has undergone such an audit. If it has

not, it will have conducted a self-assessment. A facility will retain EMS documentation and

provide a summary of its performance, including performance against objectives and

targets, and a summary of the results of compliance and EMS audits, in its Annual

Performance Report.

For more information about the National Environmental Performance Track, contact the EPA

via:

Web: www.epa.gov/performance track

E-Mail: ptrack@indecon.com

Phone: 888-339-PTRK
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The Multi-State Working Group on Environmental Management

Systems Overview of Organizational and State Activities

MSWG is an organization that convenes government, non-government, business and

academic interests to conduct research, promote dialogue, create networks and establish

partnerships that improve the state of the environment, economy and community through

systems-based public and private policy innovation. Its quarterly meetings move around the

US to accommodate participation. Meetings are open; everyone is welcome. All have a right

to speak. Decisions are by consensus. The Council of State Governments (CSG) handles

administration and to accommodate gifts has 501(c)(3) status. Voluntary dues support

MSWG. NGOs do not pay dues. New members are welcome, especially businesses and

NGOs. All 50 states are enrolled in MSWG and linked by e-mail. About 25 states regularly

participate at quarterly meetings and 30-40 states attend the annual meeting and workshop.

Check www.mswg.org for information.

What activities does MSWG sponsor?

• Pilot projects: In partnership with the U.S. EPA, the Environmental Law Institute, and

University of North Carolina-Chapel Hill, MSWG states sponsor about 75 EMS pilot

projects that produce data for a national database project funded by the EPA’s Office of

Water. The purpose of the pilots is to evaluate the ability of environmental management

systems to improve the environment. Information is at: www.eli.org/isopilots.htm

• EMS Research: MSWG held six EMS research roundtables at major universities that led

to a Research Summit, held in 1999 at The Brookings Institution in cooperation with

CSG and the National Academy of Public Administration. The Summit produced an EMS

research agenda. Summit papers are included in a textbook, edited by Harvard

University and the Massachusetts Institute of Technology, published in 2001 by

Resources for the Future. Plans are being made for a second summit.

• EMS Policy Academy: With funding from The Joyce Foundation to CSG and support of

business, MSWG has a design team of business, government, academic and NGO

appointees preparing recommendations for a national EMS Policy Academy. The

“virtual” Academy will focus on learning about public policy EMSs, not those within the

confines of a private organization and will complement and not compete with existing

services. Public policy EMSs have designed to have credibility with business,

government, NGO, consumer and enlightened shareholder interests.

• Workshops: Each June or July, MSWG sponsors, with support from EPA and

businesses, an annual EMS workshop. It is a “hands-on” event that hosts EMS

practitioners from the US and abroad. It has grown from 75 participants in Cary, NC

1998 to nearly 300 in San Diego, CA in 1999.

• Networking: MSWG provides a networking function between states and EMS support

functions, especially those focused on EMSs that fit into a public policy strategy.

Technical assistance centers in Florida, Georgia, Iowa, Kentucky, Massachusetts and

South Carolina help MSWG participants.

• Other activities: MSWG members contribute to numerous public policy-related

environmental initiatives and discussions including EPA’s Performance Track, ISO

14001 revisions; Environmental Council of States forums; Global Environmental

Management Initiative meetings; professional and trade association programs and

Commission for Environmental Cooperation.
© 2001 NSF 164

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MSWG is state-driven. Several states sponsor EMS pilot projects and contribute data to the

UNC-ELI database. They are: AZ, CA, IL, IN, NC, NH, OR, PA VT and WI. These states

have or are developing public-policy-related EMS policies, programs, internal EMSs or

environmental laws that recognize EMSs: AZ, CA, CT, FL, IA, IL, IN, LA, MA, ME, MN, NC,

NH, OH, OR, PA, SC, TX, VA, WA, VT and WI. Contact Marci Carter, carterm@uni.edu for

state contact information or questions. Many MSWG states participate in EPA’s performance

track program, whose businesses use EMSs for public policy purposes.
© 2001 NSF 165

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Implementing Environmental Management Systems

In Government Entities

Fourteen government entities were selected from an applicant pool of 50 to participate in a

pilot project designed to assist public-sector organizations develop and implement an

environmental management system (EMS) based on the ISO 14001 protocol. The U.S.

Environmental Protection Agency’s (U.S. EPA) Office of Water, Office of Compliance, and

Office of Air and Radiation, including Regions I and IX, jointly sponsor this initiative which

runs from April 2000 to January 2002.

Each participating organization has selected a facility/organization ("fenceline") in which to

implement the EMS, as noted below.

Public Entity Fenceline

City of Berkeley, CA Solid Waste Management Division

City of San Diego, CA Refuse Disposal Division

City of Detroit, MI Department of Recreation & Public

Lighting

Florida Gulf Coast University - Fort Myers, FL Solid Waste Activities and Services

Port of Houston, TX Container Terminal and the Central

Maintenance Department

Jefferson County, AL General Services Department

Little Blue Valley Sewer District - Independence, MO Wastewater Treatment Facility

All operations

Louisville and Jefferson County Metropolitan Sewer

District Louisville, KY

Wastewater Treatment Facility and

Purchasing Department

Wisconsin Department of Natural Resources -

Madison, WI

Air Management Bureau

Tri-County Metropolitan Transportation District

Portland, OR

Maintenance Facilities

King County Solid Waste Division - Seattle, WA Entire Division - Eight Transfer Stations &

one Regional Landfill

Massachusetts Department of Environmental

Protection Lawrence, MA

Wall Experiment Station

Analytical Laboratory

University of Massachusetts - Lowell, MA Olney Science Building - Laboratory

New Hampshire Department of Transportation

Concord, NH

Bureau of Traffic

In 1997, U.S. EPA sponsored the first two-year EMS project for nine local governments.

Participants experienced compelling environmental and economic benefits over the two-year

project period:

• Improved Environmental Awareness - "There's a much better understanding of

environmental issues in every department of the fenceline, not just in the environmental

department. We are recognizing simple internal "housekeeping" measures that are

having a positive effect on our environmental performance. We have self-imposed

additional requirements to help prevent pollution, reduce energy use, manage our

contractors, and expand environmental education for our citizens. Employees are

bringing ideas for reducing our waste streams, for less toxic products. There has been a

definite improvement in involvement and morale."
© 2001 NSF 166

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• Improved Efficiency - "Systematically analyzing compliance issues revealed an

opportunity for cost savings. Fifteen departments were responsible for obtaining their

own air quality permits - 23 altogether. The implementation team consolidated these

permits into eight, saving the city $16,000 per year."

• A Positive Effect on Environmental Compliance and Performance - "With regards to

environmental compliance, we have a better understanding of our legal requirements.

We have better-trained employees whose competence in their work area is critical to the

environment. We expect that our EMS efforts will increase our ability to stay in

compliance."

For case study information, see the final report at www.getf.org/projects/muni.cfm.

THE SECOND GOVERNMENT EMS INITIATIVE

Due to the overwhelming success of the first program and local governments’ growing

interest in EMSs, U.S. EPA decided to conduct a second EMS initiative to gather additional

data about the value of EMS tools in government organizations. The Global Environment &

Technology Foundation (GETF) was again selected to lead the effort, providing in-depth

training, coaching and on-site technical assistance to help participants design and

implement their EMS’s.

Jim Horne, the National Project Manager, from U.S. EPA's Office of Water said,

“The U.S. EPA team was extremely gratified by the level of interest shown by local

governments for this second initiative and the level of sophistication of the applications. It is

clear that public-sector organizations are rapidly becoming aware of the value of

implementing EMS’s and the value of working with U.S. EPA. We are delighted with the

diverse range of organizations that were selected and expect great things from each of

them.”

During the two-year project, participants attend five comprehensive workshops. At each they

receive training, materials, and technical assistance to help them accomplish EMS

milestones in each of the four implementation phases.

The Houston Port Authority, TX had the following to say about the project:

“This will be an interesting two-year process, learning with and from other organizations who

share our interest in protecting the environment while providing public services. We plan to

convey all that we learn to our tenants, the city and county, and other port authorities so that

we can all do a better job as stewards of the environment.”

For more information on the Local Government EMS Initiative, please contact Craig Ruberti

(cruberti@getf.org) at 703-750-6401, Faith Leavitt (fleavitt@earthvision.net) at 941-489-

1647, or Jim Horne (horne.james@epa.gov) at 202-260-5802 or visit the project web site

(http://www.getf.org/projects/muni.cfm) for regular updates on the project.
© 2001 NSF 167

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NEIC Compliance-Focused Environmental Management System

Since the late 1980s, civil multimedia compliance investigations conducted by the EPA

National Enforcement Investigations Center (NEIC) have increasingly involved identifying

causes of observed noncompliance. In a significant number of cases, the causes arise from

inadequate environmental management systems (EMSs). NEIC, in response, developed

key elements for a compliance-focused EMS (CFEMS) model, which have been used as the

basis for EMS requirements in several settlement agreements. The CFEMS, which includes

a guide for using it in settlement agreements, was published in August 1997 and revised in

January 2000.3

The CFEMS elements are as follows:

1. Environmental Policy

2. Organization, Personnel, and

Oversight of EMS

3. Responsibility and Accountability

4. Environmental Requirements

5. Assessment, Prevention and Control

6. Environmental Incident and

Noncompliance Investigations

7. Environmental Training, Awareness,

and Competence

8. Environmental Planning and

Organizational Decision-Making

9. Maintenance of Records and

Documentation

10. Pollution Prevention Program

11. Continuing Program Evaluation and

Improvement

12. Public Involvement/Community

Outreach

To achieve maximum benefit from the CFEMS elements, the overall EMS in which they are

incorporated should embody the “plan, do, check, and act” model for continuous

improvement. Consequently, the compliance-focused EMS model described here is

intended to supplement, not replace, EMS models developed by voluntary consensus

standards bodies, such as the ISO 14001 EMS standard developed by the International

Organization for Standardization.

Settlement agreements that require an EMS typically include a requirement that the

organization conduct an initial review of its current EMS, followed by development of a

comprehensive CFEMS that must be documented in a manual. The EMS manual must

contain policies, procedures, and standards for the 12 key elements, at a minimum, and

should also identify other, more detailed procedures and processes (e.g., inspections and

self-monitoring) that may be located elsewhere at the facility. After the organization has

had sufficient time to implement and refine the EMS (usually 2 to 3 years), the agreement

should require at least one EMS audit by an independent third-party auditor, with results

reported to both the organization and EPA. However, additional audits may be required, as

individual circumstances dictate

 

3

The document is available on NEIC’s website.

http://es.epa.gov/oeca/oceft/neic/12elmenr.pdf
© 2001 NSF 168

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The intended result of this approach is twofold: first, to have the organization develop an

EMS that will both improve its compliance with applicable environmental requirements and,

second, to improve its environmental performance by achieving the organization’s

environmental targets and objectives.

The January 2000 revision involved enhancing several of the elements and more completely

incorporating the due diligence provisions of the EPA audit policy. Refinement continues

through settlement negotiations, and discussions with EPA staff, EMS consultants, and

environmental personnel from several companies with medium-size and large facilities.
© 2001 NSF 169

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Appendix C:

Information on Process Mapping and Design

for Environment
© 2001 NSF 170

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Introduction to Process Mapping

Organizations operate using a collection of processes. A process can be defined as a

method of doing something, generally involving a number of steps or actions. An EMS is

one example of linked organizational processes that are directed at a specific purpose.

Most organizations employ a variety of processes to carry out their core functions, such as

manufacturing a product or providing a service.

A process typically has four components. Two of these are inputs (the items to which action

is done) outputs (the results of those actions). In addition, a process has controls (which

direct the action) and mechanisms (which are the resources that actually perform the

action). Mechanisms can be people or machines that change the inputs to the outputs.

Other concepts that are important to process mapping are process boundaries (which define

the limits of a particular process from its larger environment), suppliers (who provide the

process inputs) and customers (whoever receives the output of the process).

Process mapping is a tool that allows an organization to visualize and understand how work

gets accomplished and how its work processes can be improved. It is a simple but powerful

tool through which an organization can focus its efforts where they matter most and

eliminate process inefficiencies. Used properly, process mapping can help an organization

understand its environmental aspects and reduce wastes and pollution. It also can help an

organization to reduce operating costs by identifying and eliminating unnecessary activities.

As an EMS tool, process mapping can help an organization to:

• improve its understanding of existing processes, including the key inputs

(such as chemicals, raw materials and other resources used), outputs (including

products, wastes, air emissions, etc.) and interactions with other processes.

• identify areas for process improvement that can result in environmental

performance improvements (such as pollution prevention opportunities)

Over time, processes are often modified many times in seemingly small ways. Over time,

these process modifications can result in a process that is ineffective. This is one of the

bases for the concept of “re-engineering” which seeks to examine processes in a holistic

manner to ensure they are effective and necessary to achieve an organization’s mission.

Getting Started on Process Mapping

• Select a process (or set of related processes) to examine. Processes might be

prioritized for review based on a number of criteria, such as relevance or importance to

the organization, prior assessments of the process, existing knowledge of the

environmental significance of the process, or history of problems with the process,

among others. Define the process boundaries.

• Use a team to understand and map how these existing process(es) work. At a

minimum, the team should include the process “owner” as well as individuals that are

actively involved in carrying out the process. Many organizations use a facilitator that is

independent of the process under review to manage team meetings. Don’t be surprised
© 2001 NSF 171

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if a diversity of opinions exists among team member exist regarding how the existing

process works.

• Clarify the objectives of the process under review. Each process should have a

primary customer and a primary performer, although additional (secondary) customers

and performers also might exist.

• As a team, determine the level of detail needed to accurately map your processes.

Initially, you might map at a fairly high level, then get into more detail as improvement

opportunities as identified.

• Decide on a set of symbols that the team will use to visually describe the process. For

example, use one symbol for work steps, another symbol for process inputs, a third

symbol for process outputs, a fourth symbol for decision points, a fifth symbol for

measurement points, etc.

• Identify the key steps (or “unit operations”) in the process first, then go back and

analyze each of these steps in more detail. Use lines or arrows to show the

relationships among individual process steps. Use brainstorming and/or storyboarding

techniques to identify the process steps, then agree upon the sequence of these steps.

• Start with the preparation of an “as is” map that describes how the process works

now, including key process inputs to and outputs. For environmental purposes, key

inputs might include energy and other resources consumed, and raw materials and

chemicals used. Outputs might include products or services, air emissions, wastewater

discharges, solid and hazardous wastes. This “as is” map can be analyzed to identify

environmental aspects and key opportunities for improvement.

• Some processes can be extremely complex and might consist of numerous subprocesses. If the team gets bogged down, it might examine and map some of the key

sub-processes first, rather than trying to tackle the entire process at once. As a rule of

thumb: If the process is so complex that it cannot be shown on a single page, then it

might be a good candidate for re-engineering.

• Depending on the purpose of the process mapping exercise, the analysis of the “as is”

map can lead to the preparation of a modified map that defines how the re-engineered

process is intended to function.

• A variety of tools and materials can be used to prepare process maps. For example, a

number of commercial software packages exist. However, you can also employ simpler

methods, such as self-sticking removable (“Post-It”) note pads. These are particularly

useful for moving individual process steps around on a board.

A sample process map for a printing operation is shown at the end of this section.
© 2001 NSF 172

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Conclusion

Process mapping can provide a solid foundation for understanding and continually

improving an organization’s processes.

Viewing processes graphically helps an organization to see things that otherwise might not

be apparent. Once a process map has been prepared, it can be used as training tools as

well as for internal and external communications.

Process mapping has several important benefits for an EMS. First, it allows an organization

to understand its current environmental aspects and impacts as well as the specific

operations and activities from which they arise. Second, it provides a basis for enhancing

an organization’s processes in a manner that can improve both environmental and financial

performance.
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Sample Process Map for Printing Operation

Packaging

 - kraft wraps

- skids & pallets

Raw

Supplies

- spray powder

- shop towels

powder

Materials

 - plates

 - paper & ink

 - water powder

Chemicals

 - cleaning

 solvents

 - ink preservers

 - plate gums

PRINTING PRESS

web dryer

emissions

 thermal

oxidizer

atmosphere

waste ink

waste paper

recycled

recycled

trash

recycled

recycled

sewer

fuel blend

recycled

recycled

waste solvents

waste solutions

waste plates

waste packaging

waste oil & antifreeze

 solvent-containing towels

centrifuge fugitive air

emissions

atmosphere spun shop

towels

commercial laundry

sewer

recovered

solvents

secondary use in

parts washers

distillation

recycled back to company

PRODUCTS

brochures

catalogs

art prints

annuals
© 2001 NSF 174

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Information on Design for Environment

Every product or service has some impact on the environment. Such impacts can occur at

many stages of the product or service’s life cycle, from raw material acquisition to ultimate

disposal or reuse. Just as the quality and performance characteristics of a product are

significantly affected by decisions made at the development stage, so are the product’s

environment attributes. Consideration of potential environmental impacts throughout the

product or service development process can improve both environmental and financial

performance. By looking at each stage of a product or service life cycle, an organization

can better understand and control the potential environmental impacts.

Design for Environment (DFE) is based on techniques for integrating environmental

considerations into an organization’s decisions concerning its products and services, as well

as manner in which these products and services are generated. In involves an

understanding of materials flows (and the environmental effects of such material flows) as

well as the comparison of alternative approaches to producing a product or service.

DFE is grounded in the use of life cycle assessment to evaluate the full range of impacts

associated with a product or service. Such life cycle assessments allow an organization to

evaluate potential environmental impacts and identify opportunities to make improvements.

DFE is based on an assessment of the performance, costs and risks associated with

alternatives. The technique seeks to encourage front-end innovation through product or

service redesign, rather than reliance on “end of pipe” controls in order to manage risks to

the environment. As such, use of the technique might result in redesign of a product

formulation, a manufacturing process, or a management practice, among other possibilities.

In general, the earlier that environmental considerations are taken into account in the

product or service development process, the more effective the results will be with respect to

environmental performance. Organizations can use an approach that includes:

• Evaluating information on the environmental attributes of a product or service,

• Designing specific measures to reduce associated environmental impacts.

• Testing alternatives that seek to reduce impacts, while considering other importance

product characteristics (such as quality and performance), and

• Applying the resulting “lessons learned” to subsequent product or service

development.

While it might be simpler to implement DFE practices on new products or services, an

organization also might find opportunities to apply DFE in their existing products or services.

In conducting such evaluations, an organization could consider a number of goals, such as:

• Minimizing the use of toxic materials • Minimizing energy use

• Minimizing compliance costs • Minimizing use of water, other resources

• Avoiding chemicals that are banned or

restricted by customers / other parties

• Maximizing reuse potential

• Minimizing packaging
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A product or service’s environmental impacts are largely based on the inputs used to make

the product (or provide the service) and the outputs generated at various stages of its life

cycle. An organization can start to apply DFE concepts by using a simple matrix to assess

the environmental impacts associated with a product, such as shown below (1).

Potential Environmental Issues

Product Life

Cycle Stages

Material

Selection

Energy

Use

Air

Emissions

Water

Discharges

Solid

Wastes

Premanufacture

(Product design)

Product

Manufacturing

Product

Packaging &

Delivery

Product

Use

Product Disposal

or Reuse

For many organizations, the effective application of DFE concepts involves working closely

with their suppliers and customers. Effective communications with supply chain partners

can be critical in ensuring that an organization’s products or services satisfy all their

performance needs (i.e., performance, durability, environmental, safety, cost, etc.)

More information on DFE can be obtained from a variety of sources (see Appendix F for

additional information sources). In particular, organizations can access information on DFE

tools and projects on EPA’s DFE web site at www.epa.gov/opptintr/dfe.

(1) Adapted from “Best Current Practices: Design for Environment”, Lucent Technologies,

February 1997.
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Integrated Environmental Management Systems

What is EPA’s DfE Program?

EPA’s Design for the Environment Program partners with stakeholders to help businesses

help the environment. DfE projects help businesses design products, processes, and

management systems that are cost-effective, cleaner, and safer for workers and the public.

The DfE goals are to

< Encourage businesses to incorporate environmental information into their decision

criteria, and

< Effect behavior change to facilitate continuous environmental improvement.

To accomplish these goals DfE and its partners use several approaches including cleaner

technology and life-cycle assessments, environmental management systems (EMS),

formulation improvement, best practices, and green supply chain initiatives.

To date, the DfE Program has brought environmental leadership to over 2 million workers at

over 170,000 facilities. Small- and medium-sized businesses recognize DfE as a unique

source of reliable environmental (as well as performance and cost) information.

DfE’s Approach to EMSs

EPA’s Design for the Environment (DfE) Program has developed an enhanced EMS

approach called Integrated Environmental Management Systems (IEMS) to help companies

achieve continuous environmental improvement. IEMSs emphasize reducing risk to

humans and the environment, pollution prevention, and wise resource management. DfE’s

IEMS combines continuous improvement principles and tools with proven environmental

assessment methodologies.

Key IEMS components that might not be included in traditional EMSs are

‚ Paying close attention to process and material flows,

‚ Obtaining knowledge of chemicals used and their hazards and exposures,

‚ Conducting substitutes assessments that can include full-cost accounting, and

‚ Considering and selecting cleaner technologies.

IEMSs assist companies in making sound environmental decisions as part of daily business

practices. As a result, IEMSs help companies to

‚ Reduce cross-media impacts and Use energy and other resources efficiently,

‚ Better manage the risk associated with using hazardous chemicals (both regulated

and unregulated),

‚ Practice extended product and process responsibility, and

‚ Integrate environmental and worker safety and health requirements.
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DfE’s IEMS approach was piloted with several small and large screen printing companies

and the Screenprinting & Graphic Imaging Association International. The pilots

demonstrated that both small and large companies can develop and implement

sophisticated, action-oriented IEMSs. Several of the pilot companies are applying for ISO

14001 certification.

What IEMS Materials Are Available?

To help organizations create and document their own IEMSs, DfE has developed an IEMS

Implementation Guide (EPA 744-R-00-011), an IEMS Company Manual Template (EPA

744-R-00-012), and a website. The Implementation Guide walks an organization through

the steps of developing an IEMS. It provides simple, thorough directions that are clear even

to those unfamiliar with environmental management planning. The Guide includes

worksheets, examples, and step-by-step guidance on process mapping, environmental

policy development, risk assessment, and evaluating cleaner alternatives.

IEMS information and materials may be obtained by visiting the DfE website at

www.epa.gov/dfe or by contacting EPA’s Pollution Prevention Information Clearinghouse via

email (ppic@epa.gov) or phone (202-260-1023).

Possible IEMS Roles for Lead Organizations, Associations, Technical Assistance

Providers, and Large Companies

A lead organization such as an association, a technical assistance provider, or a large

company can greatly facilitate development of IEMSs among its members, clients, or small

suppliers. DfE’s IEMS experience shows that the IEMS development process can be much

more cost- and time-efficient and more fun if a lead organization takes on common

activities, such as developing a basic process map or providing group training, that each

company would otherwise do separately. Some additional ways in which a lead

organization could help companies with IEMSs include

‚ Adapt the IEMS Implementation Guide and other tools to reflect a given industry

sector’s unique conditions,

‚ Organize and lead participating companies to develop an IEMS,

‚ Develop sector-specific pollution prevention and regulatory information,

‚ Help establish environmental improvement targets and evaluate results, and

‚ Recognize or certify companies that participate and demonstrate results.

Opportunities For IEMS Partnerships With DfE: If you are interested in becoming an

IEMS partner and in leading IEMS efforts for an industry group or supply chain call DfE at

202-260-1678.
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Appendix D:

Registration of Environmental

Management Systems
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Registration of Environmental Management Systems

1st Party Audit

Internal Audit

2nd Party Audit

Customer audit of a

supplier

3rd Party Audit

Audit by another party

independent of a

supplier and its

customer

Registration

vs.

Certification

Both terms refer to

describe the thirdparty audit process.

Technically speaking,

“registration” applies

to management

systems, while

“certification” applies

to products.

However, in common

usage, they are

synonymous.

Scope of

Registration....

..is the activities and

organizations that are

included within the

EMS.

The scope should be

discussed with your

registrar before

Stage 1.

EMS registration in this appendix refers to the process

whereby a non-biased third-party attests that an

organization’s EMS conforms with the requirements of the

ISO 14001 Standard. ISO 14001 was written to describe the

requirements for registration/self declaration and is the only

one of the ISO series of environmental standards (such as

environmental labeling or environmental performance

evaluation) to which an organization may register. The thirdparty organization that performs the registration services is

called the “registrar,” and is selected by the organization that

desires registration services.

An accredited registrar is one whose competence is

evaluated by an independent third-party. Each country of the

world has its own accreditation body established either

nationally or by their government. In the United States, the

accrediting body for both ISO 9000 and ISO 14001 is the

American National Standards Institute/Registrar

Accreditation Board (ANSI/RAB). ANSI/RAB has

established criteria which registrars must meet in order to

achieve accreditation. Accreditation is not a legal

requirement. However, accreditation provides organizations

assurance that their registrar has met ANSI/RAB

requirements for things such as impartiality, confidentiality, a

documented registration system, quality assurance, and

policies to handle complaints and appeals.

The Registration Process

ANSI/RAB has established a two-stage registration approach

for accredited registrars. Registrars may have different

registration processes but must follow the basic two stage

process:

Stage 1 Planning for the Audit

The purpose of Stage 1 is to determine the organization’s

preparedness for the registration audit. This stage includes a

document review as well as on-site visit. A review of the EMS

in light of the possible significant environmental aspects is a

primary objective of Stage 1.
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Stage 2: Evaluating Implementation

Stage 2 always takes place at the organization’s location.

An audit team conducts an on-site audit to evaluate and

verify through objective evidence (interviews, procedures,

records, etc.) that the EMS conforms to the requirements in

the ISO 14001 Standard and is implemented and maintained.

Once you achieve registration, regular surveillance audits by

the registrar are required by ANSI/RAB. These may be

conducted once per year (with a re-audit after three years) or

at least twice per year with all 17 elements audited in a three

year period.

To what do you conform?

The answer may surprise you. Naturally you have to conform to

ISO 14001 Standard requirements but you also have to conform

to:

• Your own organization’s policies and procedures: The

EMS an organization designs often goes above and

beyond ISO 14001 requirements. Did your environmental

policy say your organization would promote sustainable

development? Be an environmental leader? Continually

improve environmental performance? During a

registration audit, your policies and procedures become

criteria to which you will be audited.

• The policies and procedures of the registrar: You will not

be audited to the registrar’s policies and procedures but

they will include your responsibilities (such as timeframes

for corrective actions) and rights within the registration

process (such as auditor approval), and processes you

should be aware of (such as confidentiality and dispute

resolution).

Why Register?

The ISO 14001 Standard does not require third-party

registration. However, for some industries such as

automotive, a registered EMS is a mandated requirement for

thousands of suppliers to the major auto makers. In addition,

organizations that sell their goods or services internationally

may find that EMS registration is a strong selling point in the

global marketplace and may enable them to obtain preferred

supplier status.

Where registration is not a direct market driver, organizations

may pursue registration for many reasons including:

What does registration

really mean?

Registration to ISO 14001

does not mean that your

organization is a “green”

facility, is environmentally

friendly or that you have

demonstrated superior

environmental

performance.

It means that your

organization can claim it

has a documented EMS

that is fully implemented

and consistently followed.

Major Nonconformance

occurs when......

- One or more of the

numbered requirements

of ISO 14001 have not

been addressed and/or;

- One or more of the

numbered requirements

of ISO 14001 have not

been implemented

and/or;

- Several

nonconformances taken

together lead a

reasonable auditor to

conclude that one or

more of the numbered

requirements of ISO

14001 have not been

addressed or

implemented
© 2001 NSF 181

D

“Sufficient data on an

organization’s

compliance with

relevant legislation

and regulations,

gathered during the

registration review

and surveillance, are

relevant and

necessary to

determine whether or

the organization’s

systems conform to

the standard. “

-ANSI/RAB Criteria for

Bodies Operating

Registration of

Environmental

Management Systems

(E3.2)

“...while compliance is

part of the

management system,

the registration audit

is not an audit of full

compliance with all

applicable regulatory

requirements.“

- ANSI/RAB Criteria

for Bodies Operating

Registration of

Environmental

Management Systems

(E3.2).

• Maintenance of current market position;

• Opportunities for a competitive advantage;

• Help ensure regulatory compliance;

• Improve relationships with regulators and/or the

surrounding community; and

• Support state and Federal regulatory incentive programs.

There are also important but often unrecognized internal

benefits to registration. Registration is a way to protect the

investment your organization has made in your EMS.

Knowing that you will be audited regularly by an outside party

helps to keep management’s attention on the EMS and

ensure that it has the resources it needs to improve over

time.

Registration and Compliance

A registration audit is not a compliance audit. Difference in

the two types of audits are highlighted in Table 1. An EMS

auditor will not perform a detailed compliance inspection but

the will gather data on how your organization manages its

compliance program. Pertinent questions may include; How

do you stay informed of new requirements? How are these

communicated to employees? How do you evaluate

compliance with regulations? What process do you have for

resolving any noncompliances identified?

Occasionally, an EMS auditor may identify a regulatory

noncompliance during the registration audit. Does this mean

you automatically fail the audit? No, it does not. The registrar

must verify that the EMS is set up to handle noncompliances

and that taken together, the noncompliances do not indicate

a major nonconformance.

Accredited registrars are required to have a method for

handling and reporting regulatory noncompliance identified

during a registration audit. Ask your registrar for their policy

or procedure for handling this situation.

Table 1. Difference between EMS and Compliance Audits

EMS Audit Compliance Audit

• Focus is on systems • Focus is on details of

regulations

• Information gathered

largely through interviews

and document review

• Observation of activities

is important

• Corrective action involves

individuals outside of the

environmental staff

• Corrective actions

involve only

environmental staff
© 2001 NSF 182

E

Appendix E:

Integration of Environmental Management

Systems and Quality Management Systems
© 2001 NSF 183

E

Integration of Management Systems

Integrating management systems has become an increasingly important competitive issue. A

growing body of information indicates that organizations that integrate their EMS and quality

management systems (QMS) can realize significant benefits, such as streamlined operations and

decision-making, simplified employee training, more efficient of resources and reduction in audit

costs. Systems for managing health & safety and other organizational functions can be similarly

integrated.

The two most common models for QMS and EMS (ISO 9001 and ISO 14001, respectively) share

many common elements. This should be no great surprise, since ISO 9001 was one of the source

documents used by the drafters of ISO 14001. The two standards are very compatible in their

current forms. The ISO committees responsible for the development and maintenance of these two

standards continue to examine potential opportunities to increase the compatibility or alignment of

the two standards.

Organizations that choose to implement both of these standards generally find that they can use

many common processes to conform. In general, the elements of a QMS and an EMS can be

categorized as either (1) essentially the same, (2) similar or (3) unique (see table below). System

elements in both the “essentially the same” and “similar” categories can often be addressed by a

common procedure (or parallel procedures), although some customization may be needed to

address the differing overall purposes of these systems. Unique elements are typically dealt with in

separate (EMS or QMS) procedures. Some of the typical elements for integration include:

document control, corrective/preventive action, training, records management and management

review. However, some organizations have gone much further – for example, some have

developed common (quality and environmental) policies. The degree of system integration varies

widely from organization to organization.

While an EMS can be readily integrated with an existing QMS, the overall purposes of these two

systems must be kept in mind. A QMS is intended primarily to ensure that an organization satisfies

its customers by assuring the quality of its products. An EMS generally has a broader context – the

relationship between an organization and the environment in which it operates. Also, an EMS often

concerns itself with a broader range of stakeholders, such as neighboring communities, customers

and regulatory agencies.

System integration can have environmental benefits. By linking environmental management more

closely with day-to-day planning and operation, some organizations have been able to raise the

visibility of environmental management as a core organizational issue. In addition, these

organizations enhance their abilities to address environmental issues when making modifications to

products or processes for quality purposes.

Organizations that have a QMS in place generally are better off when implementing an EMS for

several reasons. First, employees typically are already familiar with management system concepts

and are involved in making the system work. Second, many of the processes needed for the EMS

might already be in place. Finally (and perhaps most importantly), top management has committed

the use of management systems to achieve organizational goals.
© 2001 NSF 184

E

A Few Tips on System Integration

For organizations that have an existing QMS and wish to integrate an EMS with it, some

suggestions are provided below.

F Understand the existing QMS, its effectiveness and how the workforce perceives the

system. Is the existing QMS documentation clear and workable? Do employees

believe that the system is helping the organization to achieve desired results?

F Ensure that the scope of the two systems will be consistent (i.e., that the systems will

cover the same facilities, products, activities and/or services). In particular, this will be

an important issue if third-party registration will be sought.

F Establish a cross-functional team (including, at a minimum, representatives from the

environmental and quality functions) to determine the optimal approach to system

integration.

F As needed, manage resistance to change. Some employees and managers may be

reluctant to change a system that they are already familiar with and/or in which they

have important roles.

F Understand how QMS and EMS differ in purpose. While there are many common

management system elements, there are elements of each system that are unique (see

below). In the case of EMS, these include for example, environmental aspects,

communications, emergency preparedness and response. These differences must be

acknowledged and accommodated within the integrated management system.

Relationship of EMS Elements to QMS (based on ISO 9001: 1994)

Elements that are Essentially the Same

F Training, Awareness & Competence

F Document Control

F Nonconformance, Corrective & Preventive

Action

F Calibration (part of the Monitoring &

Measurement element)

F Records

Elements that are Similar

F Environmental Policy

F Structure and Responsibility

F EMS Documentation

F Operational Control

F Monitoring & Measurement

F EMS Audit

F Management Review

Elements that are Unique

Environmental Aspects

Legal and Other Requirements

Objectives & Targets

Environmental Management Program(s)

Communications

Emergency Preparedness & Response
© 2001 NSF 185

E

• Modify system documentation as required. Keep procedures simple and clear for

users. Review proposed changes with affected managers and employees.

• On a procedure-by-procedure basis, consider whether to integrate procedures or keep

them separate. While integration can reduce the total number of procedures or work

instructions, it also can confuse the overall purpose of such procedures in some cases.

• Once the integrated system documentation has been prepared, train managers and

employees on the integrated system.

• Audit the integrated system and take actions as necessary.

A few final thoughts on system integration:

• Can your organization afford to have two or more separate systems?

• Are there compelling reasons to keep these systems separate?

• What is the optimal approach from a strategic and operational standpoint?

• What approach is best suited for the organization’s change and growth?
© 2001 NSF 186

F

Appendix F:

Additional Sources of Information and

Contacts
© 2001 NSF 187

F

Appendix F: Additional Sources of Assistance

There are many resources available to help your organization develop and implement an EMS that are

free of charge or relatively inexpensive. The following is a description of some of these resources.

Federal Government Agencies

The U.S. Environmental Protection Agency (USEPA) provides information on a number of topics

that can be useful in the development and implementation of an EMS. Some of these resources

include: assistance with interpretation of environmental laws and regulations; information on pollution

prevention technologies (case studies and fact sheets); and hotlines to answer questions about

environmental issues. The Agency also has web sites for information on EMS’s and Design for

Environment. The USEPA’s Office of Compliance has established national Compliance Assistance

Centers for various industry sectors.

The Small Business Administration (SBA) provides assistance to small and medium-sized

organizations. The SBA can provide information and assistance related to: operation and

management of a business; sources of financial assistance; international trade; as well as laws and

regulations.

State Agencies

Your state environmental regulatory agency can provide assistance with the development of an EMS.

Contact your state environmental agency and inquire about education and outreach programs for

organizations that are developing an EMS. Many state environmental agencies also can provide

publications, pamphlets, and on-line help related to state environmental laws, innovative pollution

prevention technologies, waste reduction, and permitting. Some states (such as North Carolina,

Wisconsin and Virginia) have developed programs to help organizations implement and EMS and/or

seek ISO 14001 registration. Recently, several states (including Texas and Virginia) established

“EnviroMentor” programs within their Small Business Assistance Offices. These mentoring programs

are intended to help small companies comply with regulations.

Associations

Industry trade associations can provide assistance with the development of an EMS. These

organizations can provide information on industry-specific environmental management issues, and can

put you in contact with other organizations that can share their experience and expertise in EMS

implementation.

Colleges and Universities

Some colleges and universities provide EMS-related training or manage EMS demonstration projects.

Chambers of Commerce

Your local or state chamber of commerce might be helpful in providing information about legislative

and regulatory issues that affect environmental management for small and medium- sized

organizations. Other services that are commonly offered include handbooks, workshops, conferences

and seminars.
© 2001 NSF 188

F

Non-Profit Organizations

Another resource to consider is the Manufacturing Extension Partnership (MEP), which is a growing

nationwide system of services that provide technical support to businesses interested in assessing and

improving their current manufacturing processes. The MEP is a partnership of local manufacturing

extension centers which typically involve federal, state, and local governments, educational

institutions, and other sources of information and funding support. The MEP can also often provide

assistance with quality management, development of training programs and business systems.

The Industrial Technology Institute (ITI) is a non-profit organization dedicated to expanding technology

access and technology management among U.S. manufacturers. ITI provides technical assistance to

small and medium-sized organizations through the Michigan Manufacturing Technology Center. ITI

also has experience with the development of business performance tools and provides services for

energy, environment, and manufacturing assessments; as well as, QS 9000 and ISO 14000 training

and implementation.

Other Organizations

Another recommended source of information and expertise is the organizations with which you do

business. It is likely that your suppliers and customers have experience with many of the aspects of

an EMS, and might be willing to share their experiences and provide advice to your organization.

On-line Resources

There is a wealth of information related to EMS implementation available electronically via the Internet.

Many state, federal, and local agencies have home pages on the Internet containing information that

can be useful to your organization. Numerous non-governmental organizations have home pages that

contain information on topics such as ISO 14000, pollution prevention, recycling and waste

minimization, environmental laws and regulations, innovative manufacturing technologies, and

materials substitution. If your organization does not have Internet access, contact your local library to

see if it provides Internet access to users.

*******************

Additional EMS resources and contacts are described on the following table.
© 2001 NSF 189

F

Appendix F (cont’d.)

Additional Sources of Information and Contacts

Note: This list is not intended to be comprehensive. Appearance on this list should not be construed as an endorsement by NSF of any products/service.

FEDERAL AGENCIES

Organization Resource Telephone Number / Internet Address Description

US Environmental

Protection Agency Small Business Compliance

Assistance Centers:

202/564-7066 (general information) Centers are Internet Web Sites with

comprehensive environmental compliance,

technical assistance, & pollution prevention

information for various industry sectors.

Design for Environment Guide,

Fact Sheets and DFE EMS

Template

www.epa.gov/opptintr/dfe/tools/ems/

ems.html

Website contains information on EMS and

how to incorporate DFE into an EMS.

Provides a how-to manual for implementing

a DFE-based EMS and a set of integration

tools for companies that already have an

EMS.

Small Business Compliance

Policy

202/564-7072

www.epa.gov/oeca/smbusi.html

Effective May 11, 2000, this policy

supercedes the June 1996 version.

Published in the Federal Register on April

11, 2000 (65FR19630).

Compliance-Focused EMS –

Enforcement Agreement

Guidance

http://es.epa.gov/oeca/oceft/neic/

12elemnr.pdf

Presents the key elements of a compliance

focused EMS model.

Environmental Compliance

Auditing Protocols

EPA National Service Center

1-800-490-9198

www.epa.gov/oeca/ccsmd/profile.html

These protocols are intended to guide

regulated entities in the conduct of

compliance audits and to ensure that audits

are conducted in a thorough manner.

Code of Environmental

Management Principles

www.epa.gov/oeca/cemp/cemptoc.html Collection of five broad principles and

performance objectives that provide a basis

for environmental management among

Federal agencies.

Pollution Prevention

Clearinghouse

202/260-1023 Technical Information on materials and

processes, including publications related to

waste minimization and pollution prevention.
© 2001 NSF 190

F

FEDERAL AGENCIES

Office of Wastewater

Management

www.epa.gov/owm/iso2/htm Provides information on various EPAsponsored EMS projects.

Public Information Center 202/260-7751 General information about EPA programs.

RCRA / Superfund Hotline 800/424-9346

202/382-3000

Provides information about hazardous waste

regulations and handles requests for federal

documents and laws.

Small Business and Asbestos

Ombudsman

800/368-5888

202/557-1938

Information and advice on compliance

issues for small quantity generators of

hazardous waste.

Technology Transfer and

Support Division

513/569-7562 Access to the ORD research information and

publications.

TSCA Hotline 202/554-1404 Assistance and guidance on TSCA

regulations.

Enviro$en$e http://es.inel.gov Solvent alternatives, international, federal

and state programs, other research and

development. Also, environmental profiles

of various industrial categories.

US EPA Home Page http://www.epa.gov Information about EPA regulations,

initiatives, and links to the home pages of

other agencies and EPA regional offices.

U.S. Small Business

Administration

SBA Answer Desk 1-800-8-ASK-SBA Information about SBA programs, and

telephone numbers for local offices.

SBA Home Page http://www.sbaonline.sba.gov Information about business services

available to your organization, with links to

other related sites.

Government Printing

Office

GPO Superintendent of

Documents

202/512-1800 Information about available documents and

instructions on ordering GPO publications.

US Department of

Energy

Pollution Prevention Information

Clearinghouse

http://www.er.doe.gov/production/esh/

epic.html

Pollution prevention and environmental

design information.
© 2001 NSF 191

F

STATE AGENCIES

Organization Resource Telephone Number / Internet Address Description

State Environmental

Protection Agencies

Environmental Assistance

Programs

Contact your state’s Environmental

Protection Agency

Many state environmental protection

agencies provide publications, technical

assistance, and information on pollution

prevention technologies, waste reduction,

and regulatory compliance, at little or no

charge.

Small Business Assistance

Programs (Mandated under Title

V of the Federal Clean Air Act).

Call the EPA Small Business

Ombudsman (800/368-5888) for the

phone number and address of the Small

Business Assistance Program in your

state.

Provides information and technical

assistance to small businesses regulated

under the Clean Air Act.

State and Local Pollution

Prevention Programs

Contact the National Pollution Prevention

Roundtable (202/466-7272) for the phone

number and address of the pollution

prevention program in your state.

Provides information and technical

assistance on pollution prevention.

State Environmental

Protection Agencies

(cont'd)

Michigan Department of

Environmental Quality

http://www.deq.state.mi.us Fact sheets, training, and technical

assistance.

Minnesota Technical Assistance

Program

http://es.inel.gov/techinfo/facts/mpca/mpc

a.html

Fact sheets on pollution prevention,

materials substitution.

Ohio Department of

Environmental Protection

http://arcboy.epa.ohio.gov Fact sheets on pollution prevention,

materials substitution.

Wisconsin Department of

Natural Resources

http://es.inel.gov/techinfo/facts Fact sheets on pollution prevention,

materials substitution.

Note: The list shown above represents only a sample of the resources that may be available from state agencies. Contact your state

agency for details of existing programs and other forms of assistance available
© 2001 NSF 192

F

EMS SOFTWARE PACKAGES

Organization Contact Info Description

Greenware 1-800-474-0627

www.greenware.com

Provides ISO 14001 assessment, implementation and audit

software

EMSoft2000 1-800-241-3618

www.rmtinc.com

Software package based on LotusNotes to support EMS

implementation

ISOXpert 1-800-ISO-EASY Built on LotusNotes platform. Customizable document formats.

ISOSoft 14001 416-679-0119

www.isogroup.simplenet.com/soft14k

Provides ISO 14001 assessment, implementation and audit

software. Co-developed with BSI.

NON-PROFIT ORGANIZATIONS

Organization Address Phone Number Description

Industrial Technology Institute (ITI) 2901 Hubbard Road

P.O. Box 1485

Ann Arbor, Michigan 48106-1485

1-800-292-4484

Fax: 1-313-769-

4064

Technical assistance to small and mid-sized

manufacturers. Energy, environment, and

manufacturing assessments, as well as

performance benchmarking, and QS 9000

and ISO 14000 implementation assistance.

Manufacturing Extension Partnership

(MEP)

Building 301, Room C121

National Institute of Standards and

Technology

Gaithersburg, Maryland 20899-

0001

1-301-975-5020

1-800-MEP-4MFG

Fax: 1-301-963-

6556

Assists manufacturers with assessing

technological needs, and works to help small

manufacturers solve environmental problems

with cost-effective solutions.

North American Commission on

Environmental Cooperation

“Improving Environmental Performance

and Compliance: 10 Elements of Effective

Environmental Management Systems”

www.cec.org/pubs_info_resources/

publications/enforce_coop_law/ems

.cfm?varlan=english

514/350-4334

(Commission)

202/564-7048

(USEPA)

Joint expression from three North American

governments regarding how voluntary EMS’s

designed for internal management purposes

can also serve broader public policy goals,

such as compliance assurance and improved

environmental performance.
© 2001 NSF 193

F

INTERNET RESOURCES

Resource Internet Address Description

ANSI Online http://www.ansi.org Contains information related to the

American National Standards

Institute, including meetings, events,

and standards information databases.

Business Resource Center http://www.kciLink.com/brc Provides information on a variety of

topics, including tips on management,

recycling, and financing.

Canadian Standards Association http://www.csa.ca/isotcs A center for information and services

related to ISO 9000 and ISO 14000,

maintained by the Canadian

Standards Association.

Clean Technologies Center (UCLA) http://cct.seas.ucla.edu Innovative technologies for pollution

prevention.

Consortium on Green Design and Manufacturing (UC-Berkeley) http://euler.berkeley.edu/green/cgdm.html Environmental design and

sustainable development.

Environmental Technology Gateway http://iridium.nttc.edu/environmental.html Access to other environmental links

and information, environmental

technologies.

International Corporate Environmental Reporting Site www.enviroreporting.com International news about

environmental issues and resources

for environmental reporting.

Industrial Technology Institute Home Page http://www.iti.org Information about ITI, how to find

environmental information on the

Internet, and links to other

organizations.

International Network for Environmental Management www.inem.org Case studies, publications and howto information on environmental

management. Interactive tools for

assessing environmental policies and

reports.

ISO 14000 Information Center http://www.iso14000.com Answers to questions on ISO 14000
© 2001 NSF 194

F

INTERNET RESOURCES

Resource Internet Address Description

standards.

ISO 14000 Integrated Solutions (ANSI/GETF) http://www.gnet.org Will provide training, conferencing,

on-line information services and

publications on a fee basis.

ISO Online http://www.iso.ch The ISO homepage provides

information on ISO, its structure,

members, technical committees,

meetings, and events.

Multi-State Working Group www.mswg.org Describes the activities of this group

regarding EMS and ISO 14001.

National Environmental Information Resources Center (NEIRC) http://www.gwu.edu/~greenu/ Provides access to a wide variety of

information about environmental

matters, with links to hundreds of

organizations.

NSF-ISR Home Page http://www.nsf-isr.org Contains information on NSF

International and its pilot projects in

EMS implementation.

AUTHORIZED SOURCES OF THE ISO 14000 STANDARDS

NSF International (NSF) Phone: 1-888-NSF-9000

Fax: 1-734-827-6801

789 N. Dixboro Road

Ann Arbor, MI 48105

American National Standards Institute (ANSI) Phone: 1-212-642-4900

Fax: 1-212-398-0023

11 West 42nd Street

New York, NY 10036

American Society for Quality (ASQ) Phone: 1-414-272-8575

Fax: 1-414-272-1734

Milwaukee, WI

American Society for Testing and Materials (ASTM) Phone: 1-610-832-9585

Fax: 1-610-832-9555

West Conshohocken, PA
© 2001 NSF 195

Glossary of Acronyms

ACC American Chemistry Council

ANSI American National Standards Institute

API STEP American Petroleum Institute’s “Strategies for Today’s Environmental Partnership”

CAA Clean Air Act

CEC Commission for Environmental Cooperation

CERCLA Comprehensive Environmental Response, Compensation and Liability Act

CERES Coalition for Environmentally Responsible Economies

CFCs Chlorofluorocarbons

CMA Chemical Manufacturers Association

CWA Clean Water Act

DFE Design for Environment

EHS Environment, Health and Safety

EMAS Eco-Management and Audit Scheme

EMS Environmental Management System

EPA (Also USEPA) U.S. Environmental Protection Agency

EPCRA Emergency Planning and Community Right-to-Know Act

FIFRA Federal Insecticide, Fungicide and Rodenticide Act

HMTA Hazardous Materials Transportation Act

ICC International Chamber of Commerce

ISO International Organization for Standardization

ITI Industrial Technology Institute

MEP Manufacturing Extension Partnership

OSHA Occupational Safety and Health Administration

PCBs Polychlorinated Biphenyls

P2 Pollution Prevention

QMS Quality Management System

RCRA Resource Conservation and Recovery Act

SBA U.S. Small Business Administration

SPCC Spill Prevention Control and Countermeasure

TC 207 Technical Committee 207 (of ISO)

TSCA Toxic Substances Control Act

TQM Total Quality Management

USTAG U.S. Technical Advisory Group (to TC 207)

VOCs Volatile Organic Compounds
© 2001 NSF 196

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