Environmental Management Environmental Management SystemsSystems

An OverviewAn Overview

With Practical With Practical ApplicationsApplications

Presentation Presentation OutlineOutline

The EMS Continuum

The Link Between Quality Assurance & EMS Program

Key Principals

Key Elements

EMS Benefits & Costs

Compliance Focused EMS

EMS Future Directions

Comm-TracTM (EMS Management Software)

Where is your organization on Where is your organization on the continuum of EMS the continuum of EMS

development?development?Ask yourself the following questions: Ask yourself the following questions:

Are you looking for ways to improve EH&S Are you looking for ways to improve EH&S performance?performance?

Is the state of your EH&S affairs exposing added Is the state of your EH&S affairs exposing added

liability?liability?

Does a lack of time or resources prevent effective Does a lack of time or resources prevent effective EH&S management?EH&S management?

Are your organization’s EH&S goals linked to other Are your organization’s EH&S goals linked to other corporate goals?corporate goals?

If you answered YES to one or more of the above questions, If you answered YES to one or more of the above questions, enhancing your EMS can help your organization.enhancing your EMS can help your organization.

Quality Systems vs. Quality Systems vs. EMS EMS

Quality Quality

Management SystemManagement SystemEnvironmental Environmental

Management SystemManagement System Quality Policy Quality Policy Adequate Resources Adequate Resources Responsibilities and Responsibilities and

Authorities Authorities Training Training System Documentation System Documentation Process Controls Process Controls Document Control Document Control System Audits System Audits Management Review Management Review

Environmental Policy Environmental Policy Adequate Resources Adequate Resources Responsibilities and Responsibilities and

Authorities Authorities Training Training System Documentation System Documentation Operational Controls Operational Controls Document Control Document Control System Audits System Audits Management Review Management Review

EMS - Key PrinciplesEMS - Key Principles

Top Management CommitmentTop Management Commitment

Focus on Continual ImprovementFocus on Continual Improvement

FlexibilityFlexibility

Compatibility with Organizational CultureCompatibility with Organizational Culture

Employee Awareness and InvolvementEmployee Awareness and Involvement

Key BenefitsKey Benefits

Improve environmental performance - Improve environmental performance - Enhanced Compliance Enhanced Compliance

Prevent pollution and conserve resources Prevent pollution and conserve resources

Reduce/mitigate risks Reduce/mitigate risks

Increase efficiency Increase efficiency

Reduce costs Reduce costs

Enhance image with public, regulators, lenders, Enhance image with public, regulators, lenders, investors investors

EMS CostsEMS Costs

TimeTime

TrainingTraining

Consulting Assistance, if neededConsulting Assistance, if needed

Costs for technical resources & improvements, if Costs for technical resources & improvements, if needed. needed.

Compliance-Focused Compliance-Focused EMS’sEMS’s

EMS’s as part of settlement agreements:

Compliance investigations conducted by EPA have increasingly involved identifying causes of observed noncompliance..

Causes arise from inadequate environmental management systems..

EPA has developed key elements for a compliance-focused EMS model..

Used as the basis for EMS requirements in several settlement agreements..

An EMS Under settlement agreements Should Contain:

Formal review of the firm’s current EMS.Formal review of the firm’s current EMS.

Development of a comprehensive, documented, Development of a comprehensive, documented, compliance-focused EMS.compliance-focused EMS.

Development of policies, procedures, and standards Development of policies, procedures, and standards for 12 key elements listed by EPA.for 12 key elements listed by EPA.

After 2-3 years of implementation and refinement at After 2-3 years of implementation and refinement at least one EMS audit, with results reported to the least one EMS audit, with results reported to the organization and EPA.organization and EPA.

Key Elements of aKey Elements of a

Compliance-Focused EMSCompliance-Focused EMS Environmental policyEnvironmental policy Organization, personnel, and oversight of EMSOrganization, personnel, and oversight of EMS Accountability and responsibilityAccountability and responsibility Environmental requirementsEnvironmental requirements Assessment, prevention, and controlAssessment, prevention, and control Environmental incident and noncompliance Environmental incident and noncompliance

investigationsinvestigations Environmental training, awareness, and competenceEnvironmental training, awareness, and competence Environmental planning and decision-makingEnvironmental planning and decision-making Maintenance of records and documentationMaintenance of records and documentation Pollution prevention programPollution prevention program Continuing program evaluation and improvementContinuing program evaluation and improvement Public involvement / community outreachPublic involvement / community outreach

Key Elements of aKey Elements of aCompliance-Focused EMS Compliance-Focused EMS (cont’d)(cont’d)

Environmental policy: Environmental policy:

Management commitment to achieving compliance Management commitment to achieving compliance with applicable federal, state, and local environmental with applicable federal, state, and local environmental statutes, regulations, enforceable agreements, and statutes, regulations, enforceable agreements, and permitspermits

Management’s commitment to continuous Management’s commitment to continuous improvement in environmental performance. improvement in environmental performance.

Management’s intent to provide adequate personnel Management’s intent to provide adequate personnel and other resources for the EMSand other resources for the EMS..

Key Elements of aKey Elements of aCompliance-Focused EMS Compliance-Focused EMS (cont’d)(cont’d)

Organization, personnel, and Organization, personnel, and oversight:oversight:

EMS Organization including charts that identify units, EMS Organization including charts that identify units, line management, and other individuals having line management, and other individuals having environmental performance and regulatory environmental performance and regulatory compliance responsibilities.compliance responsibilities.

duties, roles, responsibilities, and authorities of key duties, roles, responsibilities, and authorities of key environmental program personnel environmental program personnel

Ongoing means of communicating environmental Ongoing means of communicating environmental issues and informationissues and information

Key Elements of aKey Elements of aCompliance-Focused EMS Compliance-Focused EMS (cont’d)(cont’d)

Accountability and responsibility:Accountability and responsibility:

Responsibilities of management, on-site service Responsibilities of management, on-site service providers, and contractorsproviders, and contractors

required reporting to regulatory agencies, and required reporting to regulatory agencies, and corrective actionscorrective actions

Incentive programs for managers and employeesIncentive programs for managers and employees

Potential consequences for departure from specified Potential consequences for departure from specified operating procedures, including liability for operating procedures, including liability for civil/administrative penalties imposed as a result of civil/administrative penalties imposed as a result of noncompliance.noncompliance.

Key Elements of aKey Elements of aCompliance-Focused EMS Compliance-Focused EMS (cont’d)(cont’d)

Environmental requirements:Environmental requirements:

Process for identifying, interpreting, and effectively Process for identifying, interpreting, and effectively communicating environmental requirementscommunicating environmental requirements

Procedures for prospectively identifying and obtaining Procedures for prospectively identifying and obtaining information about changes and proposed changes in information about changes and proposed changes in environmental requirements, and incorporating those environmental requirements, and incorporating those changes into the EMS.changes into the EMS.

Processes to ensure communication with regulatory Processes to ensure communication with regulatory agencies regarding environmental requirements and agencies regarding environmental requirements and regulatory compliance.regulatory compliance.

Key Elements of aKey Elements of aCompliance-Focused EMS Compliance-Focused EMS (cont’d)(cont’d)

Assessment, prevention, and Assessment, prevention, and control:control:

Process for assessing operations, for the purposes of preventing and Process for assessing operations, for the purposes of preventing and controlling releases, ensuring environmental protection, and controlling releases, ensuring environmental protection, and maintaining compliance with statutory and regulatory requirements.maintaining compliance with statutory and regulatory requirements.

Process for identifying operations and activities where documented Process for identifying operations and activities where documented standard operating practices (SOPs) are needed to prevent potential standard operating practices (SOPs) are needed to prevent potential violations or pollutant releases, and defines a uniform process for violations or pollutant releases, and defines a uniform process for developing, approving, and implementing the SOPs.developing, approving, and implementing the SOPs.

System for conducting and documenting routine, objective self-System for conducting and documenting routine, objective self-inspections by department supervisors and trained staff, especially inspections by department supervisors and trained staff, especially at locations identified by the process described above.at locations identified by the process described above.

Process for ensuring input of environmental requirements (or Process for ensuring input of environmental requirements (or concerns) in planning, design, and operation of ongoing, new, and/or concerns) in planning, design, and operation of ongoing, new, and/or changing changing buildings, processes, maintenance activities, and products.buildings, processes, maintenance activities, and products.

Key Elements of aKey Elements of aCompliance-Focused EMS Compliance-Focused EMS (cont’d)(cont’d)

Environmental investigations: Environmental investigations:

Standard procedures and requirements for internal and Standard procedures and requirements for internal and external reporting of potential violations and release external reporting of potential violations and release incidents.incidents.

Procedures for investigation, and prompt and appropriate Procedures for investigation, and prompt and appropriate correction of potential violations. The investigation correction of potential violations. The investigation process includes root-cause analysis of identified process includes root-cause analysis of identified problems to aid in developing the corrective actions.problems to aid in developing the corrective actions.

System for development, tracking, and effectiveness System for development, tracking, and effectiveness verification of corrective and preventive actions.verification of corrective and preventive actions.

Key Elements of aKey Elements of aCompliance-Focused EMS Compliance-Focused EMS (cont’d)(cont’d)

Training, awareness, & competence: Training, awareness, & competence:

Specific education and training required for organization Specific education and training required for organization personnel, as well as process for documenting training provided.personnel, as well as process for documenting training provided.

Program to ensure that organization employees are aware of its Program to ensure that organization employees are aware of its environmental policies and procedures, environmental environmental policies and procedures, environmental requirements, and their roles and responsibilities within the requirements, and their roles and responsibilities within the environmental management system.environmental management system.

Program for ensuring that personnel responsible for meeting and Program for ensuring that personnel responsible for meeting and maintaining compliance with environmental requirements are maintaining compliance with environmental requirements are competent on the basis of appropriate education, training, competent on the basis of appropriate education, training, and/or experience.and/or experience.

Key Elements of aKey Elements of aCompliance-Focused EMS Compliance-Focused EMS (cont’d)(cont’d)

Planning and decision-making:Planning and decision-making:

Process to integrate environmental planning into Process to integrate environmental planning into organizational decision makingorganizational decision making

Established written targets, objectives, and action plans Established written targets, objectives, and action plans by at least each operating organizational subunit with by at least each operating organizational subunit with environmental responsibilities, as appropriate, including environmental responsibilities, as appropriate, including those for contractor operations conducted at the facility, those for contractor operations conducted at the facility, and how specified actions will be tracked and progress and how specified actions will be tracked and progress reported.reported.

Targets and objectives must include achieving and Targets and objectives must include achieving and maintaining compliance with all environmental maintaining compliance with all environmental requirements.requirements.

Key Elements of aKey Elements of aCompliance-Focused EMS Compliance-Focused EMS (cont’d)(cont’d)

Maintenance of records & Maintenance of records & documentation: documentation:

Types of records developed in support of the Types of records developed in support of the EMS (including audits and reviews), who EMS (including audits and reviews), who maintains them and where, and protocols for maintains them and where, and protocols for responding to inquiries and requests for release responding to inquiries and requests for release of information.of information.

Data management systems for any internal Data management systems for any internal waste tracking, environmental data, and waste tracking, environmental data, and hazardous waste determinations.hazardous waste determinations.

Key Elements of aKey Elements of aCompliance-Focused EMS Compliance-Focused EMS (cont’d)(cont’d)

Pollution prevention program:Pollution prevention program:

Internal program for preventing, reducing, recycling, Internal program for preventing, reducing, recycling, reusing, and minimizing waste and emissions, reusing, and minimizing waste and emissions, including procedures to encourage material including procedures to encourage material substitutions.substitutions.

Mechanisms for identifying candidate materials to be Mechanisms for identifying candidate materials to be addressed by program and tracking progress.addressed by program and tracking progress.

Key Elements of aKey Elements of aCompliance-Focused EMS Compliance-Focused EMS (cont’d)(cont’d)

Evaluation and improvement:Evaluation and improvement:

Program for periodic (at least annually) evaluation of Program for periodic (at least annually) evaluation of the EMSthe EMS

Program for ongoing evaluation of facility compliance Program for ongoing evaluation of facility compliance with environmental requirements, including periodic with environmental requirements, including periodic compliance audits by an independent auditor(s).compliance audits by an independent auditor(s).

Audit results are reported to upper management, and Audit results are reported to upper management, and potential violations are addressed through the process potential violations are addressed through the process described under Environmental Incident and described under Environmental Incident and Noncompliance Investigations above.Noncompliance Investigations above.

Key Elements of aKey Elements of aCompliance-Focused EMS Compliance-Focused EMS (cont’d)(cont’d)

Public involvement & community Public involvement & community outreach: outreach:

Program for ongoing community education and Program for ongoing community education and involvement in the environmental aspects of the involvement in the environmental aspects of the organization's operations and general organization's operations and general environmental awareness.environmental awareness.

EMS - Future EMS - Future DirectionsDirections

Increasing regulatory focus… Compliance Focused EMS

Moving From Certifying EH&S Performance By Periodic Inspections To Continuous Demonstration

Stronger Focus On Managing Costs, Optimizing Business Processes & Quality Systems

Real Time EH&S Decision Making

Governmental Organizations - Compliance With Executive Order 13148: Greening the Government Through Leadership in Environmental Management ( December 31, 2005)

EMS Compliance-Focused EMS Compliance-Focused ToolsTools

A complete EMS utilizes reliable A complete EMS utilizes reliable software tools supported by software tools supported by systems, procedures, and people.systems, procedures, and people.

SummarySummary

The EMS Continuum

The Link Between Quality Assurance & EMS Program

Key Principals

Key Elements

EMS Benefits & Costs

Compliance Focused EMS

EMS Future Directions

Comm-TracTM (EMS Management Software)

Thank You!Thank You!

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