CMS Update

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CMS Update Overview

• ECO Staff Meeting
• April 27, 2004

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Overall Plan
Cornell Management System Fully implemented in
pilots
CMS Pilot Detail Design, Implementation
Deployment
Develop Pilot Implementation Plans
Gap Assessment
Establish CMS Framework
Kick-off Pilots
2004
2005
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Management System Approaches

• Non-Voluntary
• Executive Order 13148
• Code of Environmental Management Principles
  (CEMP) EPA
• EPA NEIC Compliance-Focused EMS
• Responsible Care American Chemistry Council

• Voluntary
• ISO 140011996
• EPA Region II EMS
• Occupational Health Safety (OHSAS) 18001
• ANSI/AIHA Z10-200X (OHSMS)
• ILO/OSH 2001 (OHSMS)

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1 - Environmental Policy

• Environmental policy defined by senior management
• appropriate to nature, scale and environmental
  impacts
• The policy must
• Commit to continuous improvement
• Commit to prevention of pollution
• Commit to comply with applicable requirements,
  including voluntary initiatives
• Be documented, implemented, maintained and
  communicated
• Be available to public

• What we have
• Cornell Policy 2.9 Environmental Compliance and
  Voluntary Environmental Initiatives issued March
  2003
• Cornell Policy 2.4 Health Safety Policy

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2 Roles, Responsibilities Accountability

• What we have
• Environmental Officials
• Environmental Representatives
• Environmental Compliance Program Administrators
  (ECPAs)
• CMS Director
• CMS Manager

• Roles, responsibility and authorities shall be
  defined, documented and communicated
• Resources essential to the implementation of the
  CMS environmental compliance. Including
• human resources
• financial
• technology
• specialized skills
• Senior Administration has appointed the CMS
  Director and CMS Manager.
• report to Senior Administration on the
  performance of the CMS

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3 - Environmental Aspects Impacts

• Procedure to identify environmental aspects
• Determine which aspects have or can have
  significant impacts
• Significant environmental aspects are considered
  for objectives and targets
• Information is kept up-to-date

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3 Environmental Aspects ImpactsAn Example...
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3 - Environmental Aspects Impacts

• What we have
• ECO DMS
• ECAPs
• ECO Current Operation Description
• Figure 1.2
• Table 1.1

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4 EnvironmentalRequirements

• What we have
• Profiles
• Electronic tools (ENFLEX, Dakota Auditor, etc.)
• Attendance of conferences, workshops, etc.

• Legal and other requirements to which Cornell
  subscribes directly applicable to aspects
• Procedure established and maintained to identify
  requirements
• Include effective communication to affected
  faculty, staff, students
• Track anticipate changes

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5 Voluntary Initiatives

• What we have
• Policy 2.9 - ESC
• Work towards establishing chair of ESC
• Lots of voluntary initiatives underway

• Procedure established to identify and coordinate
  college, division and university voluntary
  initiatives
• In accordance with Policy 2.9
• Communication to affected faculty, staff, and
  students

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6 -Objectives and Targets

• Established and integrated into organizational
  decision-making
• Action plans established to meet the objectives
  and targets
• The following are considered
• Relevant environmental requirements,
• significant environmental aspects,
• technological, financial, operational and
  business requirements
• Views of identified stakeholders are considered

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6 Objectives Targets Information Flow in a
Management System
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7 - Training, Awareness and Competence

• Identify those whose job responsibilities affect
  ability to achieve compliance and the CMS
  objectives and targets
• Trained and are capable of carrying out these
  responsibilities
• Priority is placed on individuals whose roles can
  cause significant environmental impacts
• Records are kept up to date and are documented

• What we have
• Annually Required Environmental Training
  (Utilities)
• Inspection Preparedness Training
• Bulk Storage Training Sessions
• Clean Air Training Sessions
• Safetybase

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8 Internal External Communications

• What we have
• ECO/CCF Coordination Meetings
• ECO Incoming Correspondence Log
• ECO File of Record Outgoing Correspondence Log
• Program Service Team Meetings

• Procedures for
• internal communication of aspects the CMS
• receiving, documenting and responding to relevant
  communication from external stakeholders
• Consider processes for external communication of
  significant environmental aspects

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9 Operational Controls

• Identify operations activities associated with
  significant environmental aspects
• Procedures cover situations to avoid deviations
  from environmental compliance, policies or
  objectives and targets
• Similarly for outside parties
• Relevant procedures and requirements are
  communicated to outside parties
• Operating criteria are stipulated in the
  procedures

• What we have
• WFP table of operations activities
• PBS SOPs
• Paint Booth Standard Procedures (SPs) and Job
  Plans (JPs)

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10 Documentation Document Control

• Procedures for controlling documents required by
  the CMS
• Current revisions are available in locations for
  effective functioning
• Obsolete documents promptly removed or
  identified
• Documents are maintained in an orderly manner
• legible
• dated
• readily identifiable.
• Procedures and responsibilities for creating and
  modifying documents
• Documentation describing the core elements of the
  CMS

• What we have
• Critical Documents Matrix
• ECO filing system
• Draft CMS Documentation System

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11 Corrective and Preventive Action

• Procedures for preventing, investigating and
  correcting any occurrence that may cause a
  deviation
• System for tracking the resolution with
  responsibility and authority defined
• Actions are appropriate for the level deviation
• Procedures are modified after an incident

• What we have
• Petroleum Tank Inspection Forms
• Incident Tracking Database
• EPA PCC

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12 - Emergency Preparedness Response

• What we have
• Cornell University Emergency Plan
• Release Reporting Plan
• SPCCs

• Procedures to identify the potential for, and the
  response to, accidents and emergency situations
• Address prevention and mitigation of
  environmental impacts
• Reviewed as necessary, especially after accidents
  or emergency situations
• Periodically tested where practicable

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13 - Monitoring Measuring

• Procedures to monitor and measure key
  characteristics of significant environmental
  aspects
• Include recording information to track
  performance, relevant operational controls and
  conformance with the CMS
• Monitoring equipment is calibrated and maintained
  with appropriate documentation
• Procedure to periodically evaluate compliance
  with relevant environmental requirements

• What we have
• Utilities
• Coal sulfur content
• Boiler hours of operation
• CVM Incinerator
• Opacity readings
• ECAPs

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14 - Record Control

• Procedures for the identification, maintenance
  and disposition of environmental records
• Records are legible, identifiable, and traceable
• Records are easily retrievable and are protected
  from damage, deterioration or loss
• Retention history is established
• Records demonstrate conformance with the CMS

• What we have
• Filing System
• File of Record
• Archiving
• ECO DMS

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15 - CMS ConformanceAudit

• Program for periodic audits of CMS conformance to
  determine if the CMS has been properly
  implemented and maintained
• Results presented to Senior Administration for
  review
• Program based on environmental importance of an
  activity and previous audits

• What we have
• System assessments within different programs

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16 Continuous Improvement Review

• Senior Administration periodically reviews the
  CMS to ensure continuing suitability, adequacy
  and effectiveness
• Necessary information is collected and provided
• Senior Administration assesses the need for
  changes

• Examples
• GEs digital cockpit allows faster management
  review
• MAXIMO capability for cockpit

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THANK YOU!

• Special thanks to Anne for editing the CMS
  Element Requirements and Factsheet!
• Once again, thanks to Lorrie, Lisa Careen for
  supporting all of the Steering Team meetings!

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Where We Are

• Completed (1st) gap assessment
• Utilities
• CALS Greenhouses
• ECO Programs
• EHS Chemical Management Programs
• Pesticide Program
• Writing gap assessment reports

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Next Steps

• Finalize gap assessment reports
• Draft implementation plan
• Get pilots kicked-off
• Next round of gap assessments
• Planning another advanced EMS workshop

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Once Around

• In 1-2 sentences to describe the most valuable
  thing the CMS could provide to you or for you.