Company Manual Template for

Small Business

Integrated

Environmental

Management Systems

Company Manual Template

for Small Business

Office of

Pollution

Prevention

and Toxics

United States

Environmental Protection

Agency

Office of Pollution

Prevention and Toxics

(7406)

EPA 744-R-00-012

December 2000
EPA 744-R-00-012

December 2000

Integrated

Environmental

Management

Systems

A Company Manual Template

for Small Business

U.S. Environmental Protection Agency

Office of Pollution Prevention and Toxics
Acknowledgments

This document was prepared by Eastern Research Group, Inc. of Lexington, MA, as part of an

effort to show how Design for the Environment (DfE) technical work could be used to support

development of an Integrated Environmental Management System (IEMS). The ERG project

team included David Galbraith, Owen Davis, and Jeff Cantin.

The EPA Project Officer is Karen Chu, with the DfE Program in the Office of Pollution

Prevention and Toxics. Bill Hanson is Director of the DfE Program. Important contributions

were made by Ted Cochin and Jenny Fisher of the DfE Program staff. Additional support was

provided by Abt Associates, Cambridge, MA and from the University of Tennessee, Knoxville

Center for Clean Products and Clean Technologies. The Abt project team included Cheryl

Keenan and Libby Parker. The University of Tennessee project team included Kerry Kelly, Lori

Kincaid and Mary Swanson.

We would also like to acknowledge insights and expertise received from Marci Kinter of the

Screen Printing and Graphic Imaging Association International (SGIA), Fairfax, VA, and from

Foster Knight of The Lexington Group, Lexington, MA.
Foreword

Why Have an IEMS Manual For Your Company?

For a small or medium-sized company developing an IEMS, the question of how to document

the system itself can be challenging. Many smaller companies lack experience in developing

documentation for their business processes and worry about having to develop extensive

documentation for their IEMS. In the course of a pilot project sponsored by EPA’s Design for

the Environment (DfE) Program and a trade association, the small and medium-sized companies

participating in the project requested additional guidance on how to document their IEMSs in a

concise, user-friendly manual. They wanted to achieve the following benefits from effective

documentation:

• Ability to maintain and improve their IEMSs as personnel and responsibilities change (i.e.,

the system is less dependent on a single person).

• Improved system implementation: procedures are clear and easy to follow, and employees

know where to look to find the procedures and records they need.

• Quality improvement and systematization across other company management systems.

To meet this request and to help other small and mid-sized companies document their IEMSs, the

DfE Program has developed the following company manual template. The company manual

template contains procedures and associated formats for an IEMS that is designed according to

the principles set forth in Integrated Environmental Management Systems: Implementation

Guide (EPA 744-R-00-011). This guide is available on DfE’s website at http://www.epa.gov/dfe

or through EPA’s Pollution Prevention Information Clearinghouse at ppic@epa.gov.

The template itself contains a cover page, table of contents, and complete documentation for the

fictional Smith Corporation’s IEMS. As you work through the template you will see instructions

(in italics) on how to tailor each section to the specific requirements of your own small- to

medium-sized company.

Using This Company Manual Template

Please keep the following points in mind as you make use of this company manual template:

• Adapt this manual template to your particular company and its IEMS. The template itself

contains a cover page, table of contents, and complete documentation for the fictional Smith

Corporation’s IEMS. As you work through the template you will see instructions (in italics)

on how to tailor each section to the specific requirements of your own small- to mediumsized company. Bracketed and italic text is also used to refer you to the related section in the

IEMS Implementation Guide (see above). You will probably want to add, eliminate, and/or

modify the procedures and other manual elements to fit your company’s IEMS.
• This manual template contains a good base set of procedures. The IEMS procedures

contained in this template represent the core set of procedures normally documented as part

of an ISO 14001-compliant EMS. You may choose to include all of these procedures

(regardless of whether you eventually will seek certification of your EMS to ISO 14001), or

to add, remove, or modify procedures so that the documentation reflects your organization

and your EMS.

• If it won’t be useful, it’s not worth your time. As you are adapting this company manual

template, design it so that it will be used (and further adapted) over time. It is much more

important to have a living manual than a perfect manual that just sits on the shelf.

• Pick an appropriate level of detail for your company. In general, the larger a company is, the

more detailed its procedures are—but even this may vary according to your company’s

culture.

• If you already have a system for documentation and document control, develop your IEMS

manual to fit that system. There are no specifications or criteria for the system used to

document your IEMS. It makes sense to use whatever system you normally use for

developing and maintaining similar documentation.

• Your manual should reference worksheets, templates, or company records, where applicable.

This manual makes reference to numbered templates that directly follow the corresponding

procedures, as well as to other records maintained elsewhere n the company. (To help locate

these tools within the manual, see the index that follows.) If you use additional formats or

worksheets (i.e., such as the supporting worksheets presented in the IEMS Implementation

Guide), include those as well.
Integrated Environmental Management System (IEMS)

Manual

Smith Corporation

January 4, 2001

Revision 1.0

Prepared by: _______________________________________

(IEMS Management Representative)

Approved and Authorized by: _______________________________________

(President)
Smith Corp. - IEMS Manual

Rev. 1.0 (January 4, 2001) Page i

Table of Contents

Table of Contents...................................................................................................................... i

Purpose of This Manual ........................................................................................................... 1

Definitions, Abbreviations, and List of Procedures................................................................... 2

Company Description: Smith Corporation................................................................................ 4

Smith Corporation’s IEMS: Introduction and Scope................................................................. 5

Environmental Policy............................................................................................................... 6

IEMS Responsibilities.............................................................................................................. 7

Documentation

RESP-01: IEMS Responsibilities...................................................................... 8

IEMS Components, Procedures, and Documentation................................................................ 9

Identification of Environmental Aspects (P-EA).......................................................... 10

Documentation

EA-01a: Basic and Supporting Operations ...................................................... 11

EA-01b: Basic and Supporting Operations—Material Flow Diagrams ............ 12

EA-02: Environmental Aspects....................................................................... 13

EA-03: Health, Safety, and Potential Environmental Concerns........................ 14

EA-04: Exposure to Chemicals and Materials ................................................. 15

Identification of Legal Requirements (P-LR)............................................................... 16

Documentation

LR-01: Applicable Legal Requirements.......................................................... 17

Identification of Significant Environmental Aspects (P-SEA)...................................... 18

Documentation

SEA-01: Determining Significant Environmental Aspects............................... 20

Development of Objectives, Targets, and Action Plans (P-OTP).................................. 21

Documentation

OTP-01: Environmental Objectives................................................................. 23

OTP-02: Environmental Management Plan ..................................................... 24

Conducting an Alternatives Evaluation (P-AE)............................................................ 25

Documentation

AE-01: Alternatives Identification .................................................................. 27

AE-02: Evaluation of Alternatives .................................................................. 28

AE-03: Evaluation of Environmental Effects .................................................. 29

AE-04: Evaluation of Performance.................................................................. 30
Smith Corp. - IEMS Manual

Rev. 1.0 (January 4, 2001) Page i

AE-05: Evaluation of Regulatory Concerns..................................................... 31

AE-06: Evaluation of Costs............................................................................. 32

Development of Operational Controls (P-OC) ............................................................. 33

Documentation

OC-01: IEMS Operational Control Procedures................................................ 35

Environmental Training (Awareness and Task-Specific) (P-ET).................................. 36

Emergency Preparedness (P-EP).................................................................................. 38

Review of New Purchases, Processes, and Products (P-NPPP) .................................... 39

Documentation and Document Control (P-D).............................................................. 41

Conducting a Compliance Assessment (P-CA) ............................................................ 43

Documentation

CA-01: Compliance Tracking Log .................................................................. 44

Conducting an Internal Assessment (P-IA) .................................................................. 45

Documentation

IA-01: Internal Assessment Checklist ............................................................. 47

IA-02: Internal Assessment Record................................................................. 48

Taking Corrective Action (P-TCA).............................................................................. 49

Documentation

TCA-01: Corrective Action Form ................................................................... 50

Communication with Stakeholders (P-CS)................................................................... 51

Documentation

CS-01: Stakeholders and Environmental Issues............................................... 53

CS-02: Stakeholder Communication Record ................................................... 54

Management Review (P-MR)...................................................................................... 55

Documentation

MR-01: Management Review Record ............................................................. 57
Smith Corp. - IEMS Manual

Rev. 1.0 (January 4, 2001) Page 1

Purpose of This Manual

[One or more paragraphs describing the purpose of this manual within your company’s IEMS.]

The purpose of this manual is to serve as a high-level “road map” to Smith Corporation’s IEMS

and to house the procedures which Smith Corporation follows in implementing and maintaining

its IEMS.

This manual, and subsequent revisions, is distributed by the IEMS coordinator to senior plant

management (including the IEMS management representative), and the IEMS committee. It will

be made available to all Smith Corporation employees, especially those involved in performing

work related to the IEMS.

This manual also serves as the basis for Smith Corporation’s internal assessment of its IEMS.
Smith Corp. - IEMS Manual

Rev. 1.0 (January 4, 2001) Page 2

Definitions, Abbreviations, and List of Procedures

[List of all abbreviations used in the manual and definitions of relevant terms.]

Definitions

Design for the Environment (DfE): An approach to incorporating opportunities for risk reduction

and wise resource use into business decision-making, developed through partnerships between

the U.S. Environmental Protection Agency and industry, academic, and other stakeholders

Environmental aspect (EA): An element of Smith Corporation’s activities, products, or services

that can or does interact with the environment (create an environmental impact)

Environmental impact: Any change to the environment, whether adverse or beneficial, resulting

from Smith Corporation’s activities, products, or services

Significant environmental aspect (SEA): An environmental aspect deemed by the Smith

Corporation as having, or potentially having, a significant impact on the environment

Alternatives evaluation: Process by which alternative methods for completing a particular

function are evaluated using business and environmental criteria

Non-conformity: Discrepancy between Smith Corporation’s actual IEMS activities and the

procedures laid out in this manual (i.e., where the actual activities do not follow the procedures)

Indicator: A measurable parameter or predictor of performance (in this case, of environmental

performance)

Root cause analysis: Systematic process to uncover underlying causes of a particular issue or

problem

Abbreviations

DfE Design for the Environment

EA Environmental Aspect

EMS Environmental Management System

SEA Significant Environmental Aspect

List of Procedures

(Alphabetical)

P-AE Conducting an Alternatives Evaluation

P-CA Conducting a Compliance Assessment

P-CS Communication with Stakeholders
Smith Corp. - IEMS Manual

Rev. 1.0 (January 4, 2001) Page 3

P-D Documentation and Document Control

P-EA Identification of Environmental Aspects

P-EP Emergency Preparedness

P-ET Environmental Training (Awareness and Task-Specific)

P-IA Conducting an Internal Assessment

P-LR Identification of Legal Requirements

P-MR Management Review

P-NPP Review of New Purchases, Processes, and Products

P-OC Development of Operational Controls

P-OTP Development of Objectives, Targets, and Action Plans

P-SEA Identification of Significant Environmental Aspects

P-TCA Taking Corrective Action
Smith Corp. - IEMS Manual

Rev. 1.0 (January 4, 2001) Page 4

Company Description: Smith Corporation

[Several paragraphs describing the activities of your company, its location(s), and its mission

and/or values.]

Smith Corporation is a medium-sized business dedicated to the manufacture of high quality

widgets for a variety of large industrial customers. Smith Corporation owns and operates two

plants, one in Jonesville, Kentucky, and one in Johnsville, Tennessee.

Smith Corporation was founded in 1956 and has since built and maintained the reputation of

being a responsive supplier of high quality products, a good employer, and a good community

member.
Smith Corp. - IEMS Manual

Rev. 1.0 (January 4, 2001) Page 5

Smith Corporation’s IEMS: Introduction and Scope

[Two or three paragraphs that introduce your IEMS and describe its purpose and scope.]

Smith Corporation has developed and is maintaining an IEMS in order to ensure that we

continue to supply a high quality product to our customers while providing a safe, healthy

workplace for our employees and acting as a responsible member of our community. The Smith

Corporation’s IEMS is designed to help us understand our environmental impacts and, through

proactive management, reduce the risks that our productive operations pose to our employees

and to the environment. The IEMS is also the means through which we follow through on the

commitments expressed in our environmental policy.

Scope of Smith Corporation’s IEMS

Smith Corporation’s IEMS presently covers only the Jonesville, KY plant. More specifically,

the IEMS covers all operations occurring on-site at the plant, from the point of entry of raw

materials and energy to the point of exit of finished manufactured products. In addition to

manufacturing processes and activities, all on-site ancillary operations fall within the scope of

the IEMS, including maintenance, groundskeeping, offices, and the activities of on-site

contractors. The IEMS excludes the environmental aspects of products to the extent that Smith

Corporation does not have influence over their design or disposition. The IEMS does take waste

disposal into account in evaluating the environmental impacts of on-site activities, even though

Smith Corporation may not ultimately be the final disposer of its waste.

Smith Corporation plans to extend the IEMS to the Johnsville, TN plant after it has been in place

for several years at the Jonesville plant.
Smith Corp. - IEMS Manual

Rev. 1.0 (January 4, 2001) Page 6

Environmental Policy

[One or two paragraphs about the importance of the environmental policy in your company’s

IEMS. See Module 2 in the IEMS Implementation Guide.]

The core of Smith Corporation’s IEMS is our environmental policy. The environmental policy

states in broad terms the principal environmental commitments of Smith Corporation. It is

signed by our President and has been communicated to all employees. The environmental policy

is posted on bulletin boards throughout the plant and is available on request to the public,

customers, and authorities. The IEMS coordinator is responsible for ensuring that only the most

recent version of the environmental policy is posted and available.

The environmental policy of Smith Corporation is reproduced below.

[Insert environmental policy]
Smith Corp. - IEMS Manual

Rev. 1.0 (January 4, 2001) Page 7

IEMS Responsibilities

[Several paragraphs describing how the overall responsibility for maintaining the IEMS is

distributed within your company. See Module 1 in the IEMS Implementation Guide.]

Smith Corporation has established an IEMS management representative, coordinator, and

committee with the following responsibilities:

• Management representative. The IEMS management representative is the member of Smith

Corporation’s top plant management group responsible for the functioning of the IEMS. It is

his or her job to ensure that all tasks relating to the IEMS are identified and completed in a

timely manner. He or she is also responsible for reporting periodically to the top plant

management group on the progress and results of the IEMS.

• Coordinator. The IEMS coordinator’s responsibility is to identify, assign, schedule, provide

the necessary support for, and ensure completion of all tasks relating to the IEMS. The

coordinator works closely with the management representative and with the committee. The

IEMS coordinator is also responsible for maintaining this manual, under the leadership of the

management representative. The functions of coordinator and management representative

may be filled by the same person.

• Committee. The IEMS committee (which also serves as the plant’s safety committee) is

comprised of 6-8 supervisors and employees from major groups or areas within the plant.

The committee is responsible for ensuring that IEMS activities in their areas are carried out

and for reporting the results of these activities to the committee as a whole. In addition, the

committee itself undertakes certain IEMS activities such as the selection of significant

environmental aspects. The committee meets to discuss the IEMS on at least a monthly

basis.

Records

The IEMS coordinator maintains an updated list of management representative, coordinator, and

committee members using format RESP-01 (IEMS Responsibilities).
Smith Corp. - IEMS Manual

Rev. 1.0 (January 4, 2001) Page 8

RESP-01: IEMS Responsibilities

The following table lists the Smith Corporation’s IEMS management representative, coordinator,

and committee:

IEMS Function Name Regular Position

Management Representative

IEMS Coordinator

IEMS Committee

Contact Person: Date Completed:
Smith Corp. - IEMS Manual

Rev. 1.0 (January 4, 2001) Page 9

IEMS Components, Procedures, and Documentation

The following pages of this manual present the components of Smith Corporation’s IEMS and

procedures by which these components are carried out. The following elements are included for

each component:

• A statement of the purpose of the component—in other words, how the activity fits into the

IEMS.

• Chronologically ordered and numbered steps that make up the procedure for carrying out the

component. These steps describe what actions are taken and who is responsible and make

reference to records or documentation (e.g., formats) where appropriate.

• Mention of the frequency with which the procedure is carried out.

• Summary list of records referenced in the procedure and person(s) responsible for

maintaining them.
Smith Corp. - IEMS Manual

Rev. 1.0 (January 4, 2001) Page 10

Identification of Environmental Aspects (P-EA)

[See Modules 1 and 3 in the IEMS Implementation Guide.]

Purpose

In order to understand and manage its actual and potential environmental impacts, Smith

Corporation identifies the environmental aspects of its activities, products, and services as they

fall within the scope of the IEMS. As a subset of this activity, Smith Corporation identifies the

health and environmental concerns related to particular chemicals used in the plant.

Procedure

1. Using processing mapping (or input/ouput flow charts), the IEMS committee identifies

the basic manufacturing and supporting operations that fall within the scope of the IEMS.

These are recorded using format EA-01, with supporting material flow diagrams and

table using format EA-01b.

2. The IEMS coordinator arranges for the environmental aspects of these operations to be

identified by a team of several employees from the operation in question, using the

process mapping approach where feasible and under the oversight of the IEMS

coordinator or a committee member where appropriate.

3. Environmental aspects, and their actual or potential impacts (quantified to the extent

possible), are listed by operation using format EA-02 (similar to Worksheet 1-5 in the

IEMS Implementation Guide).

4. If the environmental aspect involves use of a potentially harmful chemical, the IEMS

committee is responsible for researching the known health and environmental concerns

and listing these using format EA-03 (similar to Worksheet 3-1 in the IEMS

Implementation Guide).

Frequency

This procedure is repeated annually to ensure that any new environmental aspects are identified.

Records

Formats EA-01a and EA-01b (Basic and Supporting Operations, Flow Diagrams), EA-02

(Environmental Aspects), and EA-03 (Health and Environmental Concerns) are maintained by

the IEMS coordinator.
Smith Corp. - IEMS Manual

Rev. 1.0 (January 4, 2001) Page 11

EA-01a: Basic and Supporting Operations

The following are the basic (manufacturing) and supporting operations that fall within the scope

of Smith Corporation’s IEMS:

1.

2.

3.

4.

5.

6.

7.

8.

9.

10.

Contact Person: Date Completed:
Smith Corp. - IEMS Manual

Rev. 1.0 (January 4, 2001) Page 12

EA-01b: Basic and Supporting Operations – Material Flow Diagrams

[Sample diagrams]

Product or Service Component Parts

Generic Input-Output Diagram for Office Operations

Copying

Paper

Toner

Printed Documents

Waste Paper

Used Toner

Odors

Energy

Generic Input/Output Diagram for a Manufacturing Operation

Manufacturing

Step

Chemicals

Water

Chemical Waste

Materials Waste

Waste Water

Air Releases

Materials

Energy

Product for

Next Step
Smith Corp. - IEMS Manual

Rev. 1.0 (January 4, 2001) Page 13

EA-02: Environmental Aspects

The environmental aspects of the basic and supporting operations identified in format EA-01 are listed in the following table.

Operation Input/Output

Environmental Aspect

(quantify if readily possible) Environmental Impact

Contact Person: Date Completed:
Smith Corp. - IEMS Manual

Rev. 1.0 (January 4, 2001) Page 14

EA-03: Health, Safety, and Potential Environmental Concerns

Regulatory Data

Human Health Effects

by Pathways

Acute and Chronic

Effects on Wildlife or

Other Environmental

Effects Rank

Work Activity/

Chemical

EnvironmentalAspectInformationSourceCarcinogen?OSHA PermissibleExposure Limit(PEL)?Volatile OrganicCompound (VOC)?Toxic ReleaseInventory (TRI)?InhalationDermalIngestionAirWaterLandSafetyConcernsHumanEnvironment

Contact Person: Date Completed:
Smith Corporation IEMS Manual

Re v 1.0 (January 4, 2001) Page 15

EA-04: Exposure to Chemicals and Materials

Exposure Time Pathway Rank Exposed Groups

Operation Aspect

Quantity

Used per

Time

Period Duration Frequency

Personal

Protective

Equipment

(PPE)

Human

(inhalation,

dermal,

oral)

Environmental

(air, water,

land) Workers Community

Environment

Contact Person: Date Completed:
Smith Corporation IEMS Manual

Re v 1.0 (January 4, 2001) Page 16

Identification of Legal Requirements (P-LR)

[See Module 1 in the IEMS Implementation Guide.]

Purpose

Smith Corporation is committed to complying with all applicable environmental regulations.

This procedure describes how Smith Corporation identifies applicable regulations.

Procedure

1. The IEMS management representative is responsible for tracking applicable

environmental laws and regulations and evaluating their potential impact on the

company’s operations. He or she employs several techniques to track, identify, and

evaluate applicable laws and regulations. These techniques include commercial

databases, information from the trade association, direct communication with national

and state regulatory agencies, and periodic refresher training on environmental laws.

2. As necessary, the management representative may call upon off-site resources such as

consultants or attorneys.

3. The management representative compiles and maintains updated copies of applicable

environmental laws and regulations.

4. The management representative, working with the IEMS coordinator and committee,

correlate these regulations to the business activities and environmental aspects associated

with them using format LR-01 (similar to Worksheet 1-6 in the IEMS Implementation

Guide).

Frequency

Periodic: depends on information source.

Records

Format LR-01 (Applicable Legal Requirements) is maintained by the IEMS coordinator. The

IEMS management representative maintains copies of the applicable regulations.
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 17

LR-01: Applicable Legal Requirements

The following table provides a list of environmental regulations that apply to Smith Corporation’s activities. The specific operation(s)

to which each regulation applies are also shown. The operations are a subset of those listed on format EA-02.

Regulatory Agency Regulation and Specific Provision

Operation(s) to which Provision

Applies

Contact Person: Date Completed:
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 18

Identification of Significant Environmental Aspects (P-SEA)

[See Module 3 in the IEMS Implementation Guide.]

Purpose

Smith Corporation focuses its management efforts on the most significant of its environmental

aspects. To determine its SEAs, Smith Corporation systematically evaluates its environmental

aspects using environmental and business criteria.

Procedure

1. The IEMS coordinator compiles a master list of environmental aspects onto format SEA01 based on the lists submitted from each area (which are compiled on format EA-02).

Where appropriate, individual aspects are grouped. (For example, if consumption of

energy is listed as an environmental aspect in several areas, the coordinator could choose

to group these listings such that consumption of energy appears just once on the master

list.)

2. The IEMS committee then rates each aspect according to the following criteria:

• Regulatory concerns

• Pollution

• Risk, including effects of chemicals and materials, impact on workers, impact on the

surrounding community, impact on the environment, safety, and noise

• Natural resource use

3. Using format SEA-01 (similar to Worksheets 3-5a and 3-5b in the IEMS Implementation

Guide), aspects are assigned a relative value of L, M-L, M, M-H, or H in each category,

where L stands for low impact (or risk, or potential for regulatory issues), M for

medium, and H for high. Information recorded on formats EA-03 and LR-01 are used to

assist the committee in rating each aspect in the categories of risk and regulatory

concerns, respectively.

4. A “Total Ranking” is developed for each aspect by adding the scores for each category

using the following values: L = 1; M-L = 2; M = 3; M-H = 4; H = 5.

5. With all but the last column of format SEA-01 complete, the committee makes a final

determination as to which aspects are significant. As a general guide, the aspects that

score the highest number of points are considered significant. The committee, however,

should use its best judgement in determining significance.
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 19

6. Aspects identified as significant are indicated on format SEA-01.

7. At this point, the IEMS committee may take an initial cut at developing indicators for

the SEAs (at least one indicator per SEA). These preliminary indicators, which will be

reviewed later (see the procedure on operational controls, P-OC), can be noted using

format OC-01.

Frequency

This procedure is repeated on an annual basis.

Records

Format SEA-01 (Determining Significant Environmental Aspects) is maintained by the IEMS

coordinator.
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 20

SEA-01: Determining Significant Environmental Aspects

The following table shows the IEMS committee’s evaluation of the Smith Corporation’s environmental aspects based on selected

criteria. Those aspects chosen as significant are indicated in the final column.

Chemical and Material Risk—

Effects and Exposure

Operation Aspect

RegulatoryConcernWorkerCommunityEnvironmentalWorker SafetyOtherCommunityIssuesNaturalResourcesOverallRankingSignificant?

Contact Person: Date Completed:
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 21

Development of Objectives, Targets, and Action Plans (P-OTP)

[See Modules 3 and 5 in the IEMS Implementation Guide.]

Purpose

The Smith Corporation sets objectives for environmental improvement and develops targets

and action plans to meet those objectives. These objectives are generally directly related to the

company’s significant environmental aspects and follow from its environmental policy

commitments.

Procedure

1. Top plant management sets environmental objectives for the Smith Corporation such

that the plant has one or more environmental objectives at any one time. The current

environmental objectives are recorded using format OTP-01. Where possible,

environmental objectives are quantified and at least one indicator developed.

2. The IEMS committee is responsible for developing and recommending potential new

environmental objectives to top plant management. In identifying potential new

objectives, the committee considers the following:

• Environmental policy

• The SEAs of the company, considering especially those SEAs that pose chemical

risk

• Applicable laws and regulations and potential future laws and regulations

• Practical business criteria, such as the potential costs and benefits of pursuing a

particular environmental objective

• The views of employees and other interested parties

3. Once environmental objectives are established by top plant management, the IEMS

coordinator assigns responsibility (to the manager of the operations in question, where

appropriate) for developing targets and action plans to realize the objectives. The

targets and action plan that correspond to each objective are recorded by the responsible

person using format OTP-02 (similar to Figures 7-a and 7-b of the IEMS

Implementation Guide). Sometimes, this may require an alternatives evaluation as the

first target (or action item). See P-AE, “Conducting an Alternatives Evaluation,” for

more detail.
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 22

Frequency

Environmental objectives are reviewed on a yearly basis. The targets and action plans are

developed and revised as needed by the committee.

Records

Environmental objectives are recorded using format OTP-01 (Environmental Objectives), and

the targets and action plans that correspond to each objective are recorded using format OTP02 (Action Plan). The IEMS coordinator is responsible for maintaining these records.
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 23

OTP-01: Environmental Objectives

The following is a list of Smith Corporation’s current environmental objectives.

Objective Related SEA

Related Environmental Policy

Provision

Performance Measurement

Indicator(s)

Contact Person: Date Completed:
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 24

OTP-02: Environmental Management Plan

Objective

Indicator(s)

Target # 1

Action Plan

Person(s) responsible:

Budget

Schedule

Review cycle

Target # 2

Action Plan

Person(s) responsible

Budget

Schedule

Review cycle

Target # 3

Action Plan

Person(s) responsible

Budget

Schedule

Review cycle

Contact Person: Date Completed:
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 25

Conducting an Alternatives Evaluation (P-AE)

[See Module 4 in the IEMS Implementation Guide.]

Purpose

Smith Corporation periodically conducts an alternatives evaluation to identify viable approaches

to reaching an environmental objective. An alternatives evaluation is a tool for identifying

alternative products and/or processes and evaluating them compared to the baseline based on

business and environmental criteria.

Procedure

1. The IEMS coordinator appoints a small group, overseen by a committee member or by

the relevant operations manager, to identify and evaluate alternatives to a particular

activity or process where an alternatives evaluation is required for meeting an

environmental objective.

2. The group first identifies the function that this activity or process performs in Smith

Corporation’s operations. The group also characterizes the baseline, or the current

manner in which the function is being carried out.

3. The group then brainstorms alternative ways of accomplishing this function. Potential

alternatives include using a different material or chemical, changing work practices,

and/or changing process technologies. Alternatives are recorded using format AE-01

(similar to Worksheet 4-1 of the IEMS Implementation Guide), and the most promising

alternatives are assigned to individual members of the group for further research.

4. The group then evaluates the baseline and alternatives based on the following

considerations: operational performance, cost, regulatory implications, and

environmental impact. The group uses formats AE-02 (similar to Worksheet 4-10 of the

IEMS Implementation Guide) to record its findings (and formats AE-03 to AE-06, as

needed).

5. The group makes a recommendation and presents its recommendation to the IEMS

committee and appropriate operations managers.

Frequency

As often as necessary in the context of developing targets and action plans to meet

environmental objectives.
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 26

Records

Formats AE-01 (Alternatives Identification) and AE-02 (Evaluation of Alternatives) are

maintained by the IEMS coordinator, as well as AE-03 to AE-06 to provide, as necessary,

supporting documentation.
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 27

AE-01: Alternatives Identification

Significant Environmental Aspect(s):

Function:

Baseline Potential Alternatives

Products

Technologies

Work Practices

Recycling/Reuse

Treatment

Disposal

Contact Person: Date Completed:
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 28

AE-02: Evaluation of Alternatives

Significant Environmental Aspect(s):

Function:

Alternative Performance

Regulatory

Considerations Cost

Environmental

Effects Overall Evaluation

Baseline

Contact Person: Date Completed:
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 29

AE-03: Evaluation of Environmental Effects

Significant Environmental Aspect(s):

Function:

Chemical and Material Risk—

Effects and Exposure

Alternative

Regul

atory

Conce

rn

WorkersCommunityEnvironment

Wor

ker

Safe

ty

Other

Communi

ty

Issues

Natural

Resources

Overall

Ranking

Preferred

Alternative?

(Y/N)

Baseline

Contact Person: Date Completed:
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 30

AE-04: Evaluation of Performance

Significant Environmental Aspect(s):

Function:

Alternative How Well it Works Time Ease of Use

Overall Performance

Evaluation

Baseline

Contact Person: Date Completed:
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 31

AE-05: Evaluation of Regulatory Concerns

Significant Environmental Aspect(s):

Function:

Alternative

Applicable Regulations

Required Controls Cost of Compliance

Overall Regulatory

Concerns Evaluation

Baseline

Contact Person: Date Completed:
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 32

AE-06: Evaluation of Costs

Significant Environmental Aspect(s):

Function:

Alternative Raw Material Labor Disposal Total Cost Savings Net Cost

Baseline

Contact Person: Date Completed:
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 33

Development of Operational Controls (P-OC)

[See Module 6 in IEMS Implementation Guide. Make sure to integrate your process for

developing and documenting operational controls for SEAs into whatever process your

company already has in place for operational controls.]

Purpose

By developing operational control procedures for critical activities (i.e., those activities

associated with SEAs), Smith Corporation intends to mitigate and control, to the extent

possible, the environmental impacts associated with its SEAs.

Procedure

1. The IEMS committee, with additional input from other employees as needed, carries

out a root cause analysis of each SEA to determine the underlying cause(s) of the

environmental impact. As part of the root cause analysis, the committee will

determine the need for (and adequacy of, if already existing) operational control

procedures to control the critical activities related to the SEA in question and record

its findings on format OC-01 (similar to Worksheet 6-1 in the IEMS Implementation

Guide). The committee, with input from operations managers as needed, will also

select one or more indicators per SEA for purposes of monitoring Smith Corporation’s

environmental performance as related to the SEAs.

2. Where there is a need to create or modify an operational control procedure, the IEMS

committee assigns a member of the committee to draft an operational control

procedure, based on consultation with the employees who undertake that procedure.

In many cases, a separate operational control procedure may not be required, rather

the integration of environmental control procedures into an existing procedure. The

operational control procedure should take the form of a “Work Instruction,” namely a

summary list of required steps or measures. In addition to describing the steps

necessary to carry out the particular activity in an environmentally sound manner, the

work instruction should also include steps to conduct monitoring, where applicable.

3. After the operational control procedure has been developed and implemented, its

status is recorded as such on format OC-01. The procedure itself enters into the

relevant Smith Corporation operator’s handbook and/or is posted at the site of the

activity in question.
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 34

Frequency

As new SEAs are identified. For existing SEAs, a review of the associated root cause

analysis and operational control procedures is conducted yearly.

Records

Format OC-01 (IEMS Operational Control Procedures) is maintained by the IEMS

coordinator. The procedures themselves are maintained in the relevant Smith Corporation

operator’s handbook and/or posted at the site of the activity in question.
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 35

OC-01: IEMS Operational Control Procedures

SEA Indicator(s)

Associated Job

Functions

Existing Operational

Control Procedures

Operational Control

Procedures Development/

Modification Needed

Responsible/

Status

Location

Posted

Contact Person: Date Completed
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 36

Environmental Training (Awareness and Task-Specific) (P-ET)

[See Modules 6 and 8 in the IEMS Implementation Guide; Module 8 offers a sample format for

tracking training in case your HR staff does not do this already.]

Purpose

To ensure that its employees carry out their duties in as environmentally responsible a manner as

possible, Smith Corporation provides all employees with environmental awareness training on

environmental issues and provides task-specific training to those employees whose jobs are

associated with significant environmental aspects.

Procedure

Awareness Training

1. All new employees receive a 15-minute introduction to the Smith Corporation’s IEMS,

specifically its environmental policy, significant environmental aspects, and

environmental objectives. This introduction, which includes an opportunity for the new

employees to ask questions about the IEMS, is given by the human resources (HR)

manager as part of his general orientation for new employees. Records of employees

who have received this introduction are maintained by the HR department.

2. Each year employees are invited to a company picnic. One of the scheduled events for

this picnic is a 15 minute talk by a member of Smith Corporation’s IEMS implementation

committee. This person speaks about the environmental accomplishments of the Smith

Corporation, the state of its IEMS, and the goals for the coming year. These remarks

provide an update to the initial IEMS awareness training received by employees.

Task-Specific Training

3. Using the root cause analysis as a tool (see P-OC and format OC-01), the IEMS

committee, working in coordination with the appropriate operations managers, identifies

the job functions that are associated significantly with each SEA.

4. The IEMS committee, in conjunction with the relevant operations manager, then

determines what training employees performing each of these job functions should

receive in order to control actual environmental impacts to the greatest possible extent.
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 37

5. Operations managers are responsible for ensuring that their employees receive the

appropriate task-specific environmental training. Where possible, environmental training

is integrated with other types of training (e.g., operational) that employees are receiving.

The HR manager keeps records of the training received by each employee.

Frequency

Awareness training is given to new employees during their first week at Smith Corporation.

Task-specific training is given to relevant employees as they take on a new function that is

associated with a SEA. Task-specific training is updated, as necessary.

Records

Records of the awareness and task-specific training received by each employee are kept by the

HR manager. The job functions associated with environmentally critical activities (i.e., those

functions that should receive task-specific training) are listed on format OC-01.
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 38

Emergency Preparedness (P-EP)

[Note: this procedure assumes that your company has a general emergency response plan in

place, into which environmental considerations can be integrated.]

Purpose

As part of its IEMS, Smith Corporation strives to ensure that the environmental impacts

associated with any emergency situations are minimized to the greatest extent possible.

Procedure

1. Smith Corporation has an Emergency Response Committee charged with identifying

potential emergency scenarios and developing and ensuring the implementation of

appropriate procedures, should an emergency situation develop.

2. With the assistance of the IEMS coordinator, the Emergency Response Committee a)

identifies the potential negative significant environmental impacts associated with

potential emergency scenarios, b) incorporates measures to minimize these impacts into

emergency response procedures, and c) ensures that adequate training (including

simulations) is provided to appropriate Smith Corporation staff to implement these

procedures.

3. The Emergency Response Committee maintains records of the potential emergency

scenarios it is prepared for, the potential environmental impacts associated with each

scenario, and the procedures established to minimize these impacts. The HR manager

keeps records of training received by staff on implementation of emergency response

procedures.

Frequency

The Emergency Response Committee meets quarterly to review the status of its work.

Records

Records of emergency scenarios, associated potential environmental impacts, and procedures to

mitigate these impacts are kept by the Emergency Response Committee. Training records are

kept by the HR manager.
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 39

Review of New Purchases, Processes, and Products (P-NPPP)

[Note: This procedure will almost certainly need to be substantially modified in order to fit the

situation of your company. Smaller companies may not have a formal new product design or

facilities engineering group, for example. The key is to find a way (that can be documented and

verified, if possible) of ensuring that when new chemicals are being purchased, when new

products are being developed, or when a facility is being substantially modified, environmental

considerations are taken into account. See Module 7, Worksheet 7-1 in the IEMS Implementation

Guide.]

Purpose

When purchasing new chemical supplies, modifying its processes, and making new products,

Smith Corporation strives to ensure that environmental considerations, particularly those related

to SEAs, are taken into account.

Procedure

1. When processing an order for a new chemical or other potentially harmful input, the

purchasing manager clears the purchase with a member of the IEMS committee. The

IEMS committee member initials the box marked “environmental approval” in the New

Purchase Approval Form to signify his or her approval of the purchase.

2. Smith Corporation has a product development group and facilities engineering group.

The product development group develops potential new products that Smith Corporation

could offer (sometimes these are identified by the sales and marketing group, sometimes

they are identified internally). The facilities engineering group is responsible for

reconfiguring (or, in some cases, expanding) the facility’s production lines to produce

new products.

3. The product development group notifies a member of the IEMS committee before final

approval of a new product design. The IEMS committee member reviews the design in

light of the facility’s SEAs and environmental objectives and targets. When the

committee member is satisfied that the new design is in accordance with the plant’s

environmental goals, he initials the appropriate box in the Design Approval Form that is

sent to the president for approval.
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 40

4. The facilities engineering group is responsible for notifying a member of the IEMS

committee before final approval of any Facility Modification or Expansion Plan. (The

Facility Modification or Expansion Plan is required for any facilities engineering job that

costs more than $20,000.) The IEMS committee member reviews the plan in light of the

facility’s SEAs and environmental objectives and targets. When the committee member

is satisfied that the new design is in accordance with the plant’s environmental

management goals, he initials the appropriate box in the Facility Modification or

Expansion Plan form that is sent to the operations manager for ultimate approval.

Frequency

As new chemicals are purchased, new products are developed, and/or production lines are

modified.

Records

The New Purchase Approval Forms are maintained by the purchasing manager. The Design

Approval Forms are maintained by the product development group. The Facility Modification or

Expansion Plans are maintained by the facilities engineering group.
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 41

Documentation and Document Control (P-D)

[See Module 8 in the IEMS Implementation Guide.]

Purpose

To ensure effective operation of the IEMS, Smith Corporation documents the procedures of its

IEMS and keeps records of the outcomes of IEMS processes, and of the important environmental

issues facing the plant. This IEMS manual comprises this documentation. Documentation is kept

up-to-date.

Procedure

1. The IEMS coordinator documents the procedures that define Smith Corporation’s IEMS

in this manual. The IEMS committee formally reviews and, if necessary, revises this

manual on an annual basis. Revised manuals are assigned a new revision number (a

minor set of revisions would change the number from, say, 1.1 to 1.2; a major revision

would change the number from, say, 1.1 to 2.0). Finally, the IEMS coordinator ensures

that no employees or managers use outdated revisions of this manual.

2. The IEMS coordinator maintains updated records of the following outcomes, or results,

of the functioning of the IEMS:

• Environmental policy

• Environmental aspects (EA-01, EA-02, EA-03)

• Applicability of legal requirements to EAs (LR-01); note that copies of the

regulations themselves are maintained by the IEMS management representative

• Significant environmental aspects (SEA-01)

• Objectives, targets, and action plans for environmental management programs (OTP01, OTP-02)

• Results of alternatives evaluations (AE-01, AE-02, AE-03 - AE-06)

• List of operational control procedures related to SEAs (OC-01)

• Results of internal assessments (IA-01 and IA-02)

• Corrective actions taken (TCA-01)

• Management reviews (MR-01)

These items are described in more detail in the relevant procedures in this manual.

3. The IEMS coordinator is not responsible for maintaining records of environmental

training and emergency response preparations; the operational control procedures

themselves; or the New Purchase Approval Forms, the Design Approval Forms, or the
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 42

4. Facility Expansion or Modification Plans. These records are maintained by the

appropriate person or group, as specified in the relevant procedures of this manual.

Frequency

Manual review and revision on an annual basis.

Records

Maintained as outlined in the procedure.
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 43

Conducting a Compliance Assessment (P-CA)

[See Module 7 in the IEMS Implementation Guide.]

Purpose

Smith Corporation conducts a periodic compliance assessment to ensure that it complies

with all applicable local, state, and federal environmental regulations.

Procedure

1. The IEMS management representative maintains copies of applicable legal

regulations, which are summarized on format LR-01. Based on these regulations, the

IEMS management representative and coordinator compile a list of questions as an

compliance assessment protocol. These questions are intended to be sufficient to the

compliance status of Smith Corporation with respect to applicable environmental

regulations (both the paperwork and the performance-related components).

2. The IEMS coordinator and another operations manager carry out the assessment by

determining and recording the answers to the compliance assessment protocol.

When they are done with the compliance assessment, they note any actual or

potential compliance issues on format CA-01 (Compliance Tracking Log). Each

actual and potential compliance issue is immediately referred to corrective action

(see the Taking Corrective Action procedure, P-TCA).

Frequency

Monthly.

Records

Compliance assessment results are recorded by the internal assessment team using the

compliance assessment protocol and using format CA-01. Records are maintained by the

IEMS coordinator.
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 44

CA-01: Compliance Tracking Log

Person

Responsible Regulation Root Cause

Compliance

Check Date Results

Corrective

Action/Date

(see: TCA-01)

Compliance

Verified/Date
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 45

Conducting an Internal Assessment (P-IA)

[See Module 9 in the IEMS Implementation Guide.]

Purpose

Smith Corporation conducts periodic internal assessments of its IEMS to ensure that it is being

implemented and operated according to the procedures laid out in this manual.

Procedure

1. At intervals, a team of two or three operations managers or employees, who are not on

the IEMS committee, conducts an internal assessment of Smith Corporation’s IEMS.

The assessment team uses this manual as the basis for its assessment. In particular, the

assessment team checks to make sure that:

• Each procedure is being carried out as stated in this manual

• Smith Corporation’s environmental policy is being upheld

• Progress is being made in meeting the environmental objectives

The assessment team bases its evaluation on objective evidence, including documentation

and records (e.g., those cited in this manual), interviews with key employees, and

observations. Note that this is not a compliance audited

2. The assessment team completes the checklist on format IA-01 and writes up its findings

using format IA-02. A “major non-conformity” occurs when an IEMS procedure is

clearly not being implemented, when one of the commitments in the policy is not being

upheld, or when no progress is being made in achieving an environmental objective; a

“minor nonconformity” occurs when a procedure is being implemented inconsistently,

yet without causing major failings in the IEMS as a whole.
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 46

3. Each non-conformity is immediately referred to corrective action (see the Taking

Corrective Action procedure, P-TCA).

4. Records of each assessment (i.e., formats IA-01 and IA-02) are maintained by the IEMS

coordinator.

Frequency

At least two times per year.

Records

Assessment results are recorded by the internal assessment team using formats IA-01 and IA-02

(Internal Assessment Checklist and Internal Assessment Record). Records are maintained by the

IEMS coordinator.
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 47

IA-01: Internal Assessment Checklist

Internal Assessment Team:

Date of Internal Assessment:

Signed: _____________________

IEMS Procedures:

Check each item assessed (includes auditing of records, where applicable):

__ Environmental policy (adherence to policy commitments)

__ Environmental objectives (progress; implementation of action plans)

__ IEMS responsibilities (RESP-01)

__ Identification of Environmental Aspects (P-EA)

__ Identification of Legal Requirements (P-LR)

__ Identification of Significant Environmental Aspects (P-SEA)

__ Development of Objectives, Targets, and Action Plans (P-OTP)

__ Conducting an Alternatives Evaluation (P-AE)

__ Development of Operational Controls (P-OC)

__ Environmental Training (Awareness and Task-Specific) (P-ET)

__ Emergency Preparedness (P-EP)

__ Review of New Products and Processes (P-NPP)

__ Documentation (P-D)

__ Conducting a Compliance Assessment (P-CA)

__ Conducting an Internal Assessment (P-IA)

__ Taking Corrective Action (P-TCA)

__ Management Review (P-MR)

IEMS Performance

__ Achieved objective #1

__ Achieved objective #2

__ Achieved objective #3

Contact Person: Date Completed
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 48

IA-02: Internal Assessment Record

Internal Assessment Team

Date of Internal Assessment

Signed

Major Non-Conformities Observed

1.

2.

3.

Minor Non-Conformities Observed

1.

2.

3.

Is Smith Corporation making progress in meeting its IEMS objectives?

Is Smith Corporation adhering to the commitments in its environmental policy?

Suggestions for Improving the IEMS

Contact Person: Date Completed:
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 49

Taking Corrective Action (P-TCA)

[See Module 9 in the IEMS Implementation Guide.]

Purpose

Smith Corporation uses a formal corrective action process to ensure that actual or potential

compliance issues and IEMS non-conformities are addressed quickly and effectively.

Procedure

1. The management representative assigns responsibility for taking action to correct each

actual or potential compliance issue or non-conformity identified in a compliance

assessment or an internal assessment (see P-CA and P-IA, respectively) to an appropriate

manager or employee. Together they fill out the “Statement of the Problem” part of the

Corrective Action Notice (format TCA-01; similar to Worksheet 7-7 in the IEMS

Implementation Guide).

2. The person responsible then undertakes the corrective action required, calling upon the

management representative, the IEMS committee, and others for assistance as necessary.

3. The responsible person and the management representative fill out the “Completion of

Corrective Action” part of the Corrective Action Notice when corrective action is

complete.

Frequency

Whenever significant problems in the functioning of the IEMS are identified, primarily through

the internal assessment process.

Records

Corrective action is recorded using format TCA-01; records are maintained by the IEMS

coordinator.
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 50

TCA-01: Corrective Action Form

Statement of the Problem

Date

Description of non-conformity or actual or potential compliance issue

Description of potential solution

Person responsible for corrective action

Deadline for completion of corrective action

Completion of Corrective Action

Actions taken

Results

Date

Signed: _______________________ __________________________

 Management Representative Person Responsible
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 51

Communication with Stakeholders (P-CS)

[See Module 8 in IEMS Implementation Guide.]

Purpose

To ensure that interested external stakeholders receive appropriate information about the

company’s environmental activities, Smith Corporation has developed a company policy for

considering and, where appropriate, responding to queries, comments, or complaints from

stakeholders.

Procedure

1. The IEMS committee identifies stakeholders and their potential interests in the

environmental performance of Smith Corporation using format CS-01, Stakeholders and

Environmental Issues. If the committee decides that proactive communication on

environmental issues is necessary with any group, that decision is recorded on CS-01 and

responsibility is designated.

2. When any form of communication is received regarding Smith Corporation’s

environmental performance or management from a stakeholder, that communication is

immediately forwarded to the IEMS management representative.

3. The IEMS management representative considers the nature of the communication and

makes a decision on whether and how to respond to it based on the guidance below and

on the more specific guidance in CS-01. The IEMS management representative is

responsible for maintaining records of each such communication and response using

format CS-02, Stakeholder Communication Record. Where internal actions are necessary

to address the communication, this is noted on CS-02 and a Corrective Action Form

(TCA-01) is initiated.

Guidance for Communicating with Stakeholders on Environmental Issues: Smith

Corporation’s environmental policy is available to all stakeholders upon request. Smith

Corporation will do its best, however, to respond in kind to all good-faith

communications from stakeholders about environmental issues, including complaints,

comments, and information requests. However, Smith Corporation may not choose to

respond in all cases, particularly if the request is made in bad faith or if sensitive

information is requested.
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 52

Frequency

As per environmental communication.

Records

Records of environmental communications from stakeholders and Smith Corporation’s responses

are kept by the IEMS management representative and are tracked using format CS-02. An

updated version of CS-01, Stakeholders and Environmental Issues, is kept in this manual.
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 53

CS-01: Stakeholders and Environmental Issues

Stakeholder

Potential Environmental Interest Proactive Communication Plan

(if desired)

Person

Responsible

Contact Person: Date Completed:
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 54

CS-02: Stakeholder Communication Record

Date Communication Received

Type of Communication

Received From

Address/Telephone Number/

E-Mail

Content of Communication (attach copy if possible)

Will Smith Corporation Respond? YES NO

Date of Response

Person Responding

Position

Nature of Response (attach copy if possible)

Are Internal Actions Necessary?(If Yes, fill out a Corrective Action Form.)

Contact Person: Date Completed:
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 55

Management Review (P-MR)

[See Module 9 in the IEMS Implementation Guide.]

Purpose

To ensure the effectiveness of the IEMS and its continual improvement, Smith Corporation top

management periodically reviews the important elements and outcomes of the IEMS.

Procedure

1. In preparation for the management review, the IEMS management representative gathers

the following information and makes it available to top plant management, including the

owner and President of Smith Corporation and the plant manager:

• Environmental policy

• List of IEMS committee and others responsible for major parts of the IEMS (RESP01)

• List of significant environmental aspects and criteria of significance (SEA-01)

• Update on compliance status of the plant and on any potential upcoming regulations

that might require an advance strategy

• List of environmental objectives and targets (OTP-01 and OTP-02)

• Environmental performance results (from monitoring and measuring SEA indicators

and indicators of progress toward environmental objectives and targets)

• Bullet-point description of other accomplishments of the IEMS (e.g., number of

people trained, etc.)

• Results of most recent IEMS internal assessment (IA-02), compliance assessment

(CA-01), and corrective actions taken

• Description and documentation of feedback from stakeholders (if received)

• Analysis of the costs and benefits of the IEMS (as quantitative as possible)

2. Top plant management meets to review and discuss the information presented. The IEMS

management representative and coordinator will also be present. Depending on its

review, top management may direct specific and/or significant changes in the scale and

direction of the IEMS in order to improve its effectiveness and business value. The

conclusions and directives that result from the management review are recorded using

format MR-01 and kept by the IEMS coordinator.
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 56

Frequency

Quarterly.

Records

Results of management reviews are recorded using format MR-01. Records are kept by the

IEMS coordinator.
Smith Corporation IEMS Manual

Rev 1.0 (January 4, 2001) Page 57

MR-01: Management Review Record

Date of review meeting

Persons present at meeting

Name Position

Conclusions

Actions to be taken Person(s) responsible

Signed: _______________________ __________________________

 Management Representative Plant Manager