Environmental Management Systems

1
Environmental Management Systems

• An Overview

With Practical Applications
2
Presentation Outline

• 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)

3
Where is your organization on the continuum of
EMS development?

• Ask yourself the following questions
• Are you looking for ways to improve EHS
  performance?
• Is the state of your EHS affairs exposing added
  liability?
• Does a lack of time or resources prevent
  effective EHS management?
• Are your organizations EHS goals linked to
  other corporate goals?
• If you answered YES to one or more of the above
  questions, enhancing your EMS can help your
  organization.

4
Quality Systems vs. EMS
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EMS - Key Principles

• Top Management Commitment
• Focus on Continual Improvement
• Flexibility
• Compatibility with Organizational Culture
• Employee Awareness and Involvement

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EMS - Key Principles

• Top Management Commitment
• making the environment an organizational
  priority Thinking of effective environmental
  management as fundamental to the organization's
  survival
• integrating environmental management throughout
  the organization Thinking about the environment
  as part of product/service and process
  development and delivery, among other activities
  
• looking at problems as opportunities
  Identifying problems, determining root causes and
  preventing problem recurrence

7
EMS - Key PrinciplesContinued

• Most EMSs are built on the "Plan, Do, Check, Act"
  model.
• This model leads to continual improvement

8
EMS - Key PrinciplesContinued

• Flexibility
• An effective EMS must be dynamic to allow your
  organization to adapt to a quickly changing
  environment. For this reason, you should keep
  your EMS flexible and simple.

9
EMS - Key PrinciplesContinued

• Compatibility with Organizational Culture
• tailoring the EMS to the culture, or
• changing the culture to be compatible with the
  EMS approach.

10
EMS - Key PrinciplesContinued

• Employee Awareness and Involvement
• Make sure that everyone understands why the
  organizationneeds an effective EMS, what their
  role is, and how an EMS will help to control EHS
  impacts in a cost-effective manner.
• Employee involvement helps to demonstrate the
  organization's commitment to EHS goals and helps
  to ensure that the EMS is realistic, practical
  and adds value.

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Key Benefits

• Improve environmental performance - Enhanced
  Compliance
• Prevent pollution and conserve resources
• Reduce/mitigate risks
• Increase efficiency
• Reduce costs
• Enhance image with public, regulators, lenders,
  investors

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EMS Costs

• Time
• Training
• Consulting Assistance, if needed
• Costs for technical resources improvements, if
  needed.

13
Compliance-Focused EMSs

• EMSs 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.

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An EMS Under settlement agreements Should Contain

• Formal review of the firms current EMS.
• Development of a comprehensive, documented,
  compliance-focused EMS.
• Development of policies, procedures, and
  standards for 12 key elements listed by EPA.
• After 2-3 years of implementation and refinement
  at least one EMS audit, with results reported to
  the organization and EPA.

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Key Elements of aCompliance-Focused EMS

• Environmental policy
• Organization, personnel, and oversight of EMS
• Accountability and responsibility
• Environmental requirements
• Assessment, prevention, and control
• Environmental incident and noncompliance
  investigations
• Environmental training, awareness, and competence
• Environmental planning and decision-making
• Maintenance of records and documentation
• Pollution prevention program
• Continuing program evaluation and improvement
• Public involvement / community outreach

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Key Elements of aCompliance-Focused EMS
(contd)

• Environmental policy
• Management commitment to achieving compliance
  with applicable federal, state, and local
  environmental statutes, regulations, enforceable
  agreements, and permits
• Managements commitment to continuous improvement
  in environmental performance.
• Managements intent to provide adequate personnel
  and other resources for the EMS.

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Key Elements of aCompliance-Focused EMS
(contd)

• Organization, personnel, and oversight
• EMS Organization including charts that identify
  units, line management, and other individuals
  having environmental performance and regulatory
  compliance responsibilities.
• duties, roles, responsibilities, and authorities
  of key environmental program personnel
• Ongoing means of communicating environmental
  issues and information

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Key Elements of aCompliance-Focused EMS
(contd)

• Accountability and responsibility
• Responsibilities of management, on-site service
  providers, and contractors
• required reporting to regulatory agencies, and
  corrective actions
• Incentive programs for managers and employees
• Potential consequences for departure from
  specified operating procedures, including
  liability for civil/administrative penalties
  imposed as a result of noncompliance.

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Key Elements of aCompliance-Focused EMS
(contd)

• Environmental requirements
• Process for identifying, interpreting, and
  effectively communicating environmental
  requirements
• Procedures for prospectively identifying and
  obtaining information about changes and proposed
  changes in environmental requirements, and
  incorporating those changes into the EMS.
• Processes to ensure communication with regulatory
  agencies regarding environmental requirements and
  regulatory compliance.

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Key Elements of aCompliance-Focused EMS
(contd)

• Assessment, prevention, and control
• Process for assessing operations, for the
  purposes of preventing and controlling releases,
  ensuring environmental protection, and
  maintaining compliance with statutory and
  regulatory requirements.
• Process for identifying operations and activities
  where documented standard operating practices
  (SOPs) are needed to prevent potential violations
  or pollutant releases, and defines a uniform
  process for developing, approving, and
  implementing the SOPs.
• System for conducting and documenting routine,
  objective self-inspections by department
  supervisors and trained staff, especially at
  locations identified by the process described
  above.
• Process for ensuring input of environmental
  requirements (or concerns) in planning, design,
  and operation of ongoing, new, and/or changing
  buildings, processes, maintenance activities,
  and products.

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Key Elements of aCompliance-Focused EMS
(contd)

• Environmental investigations
• Standard procedures and requirements for internal
  and external reporting of potential violations
  and release incidents.
• Procedures for investigation, and prompt and
  appropriate correction of potential violations.
  The investigation process includes root-cause
  analysis of identified problems to aid in
  developing the corrective actions.
• System for development, tracking, and
  effectiveness verification of corrective and
  preventive actions.

22
Key Elements of aCompliance-Focused EMS
(contd)

• Training, awareness, competence
• Specific education and training required for
  organization personnel, as well as process for
  documenting training provided.
• Program to ensure that organization employees are
  aware of its environmental policies and
  procedures, environmental requirements, and their
  roles and responsibilities within the
  environmental management system.
• Program for ensuring that personnel responsible
  for meeting and maintaining compliance with
  environmental requirements are competent on the
  basis of appropriate education, training, and/or
  experience.

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Key Elements of aCompliance-Focused EMS
(contd)

• Planning and decision-making
• Process to integrate environmental planning into
  organizational decision making
• Established written targets, objectives, and
  action plans by at least each operating
  organizational subunit with environmental
  responsibilities, as appropriate, including those
  for contractor operations conducted at the
  facility, and how specified actions will be
  tracked and progress reported.
• Targets and objectives must include achieving and
  maintaining compliance with all environmental
  requirements.

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Key Elements of aCompliance-Focused EMS
(contd)

• Maintenance of records documentation
• Types of records developed in support of the EMS
  (including audits and reviews), who maintains
  them and where, and protocols for responding to
  inquiries and requests for release of
  information.
• Data management systems for any internal waste
  tracking, environmental data, and hazardous waste
  determinations.

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Key Elements of aCompliance-Focused EMS
(contd)

• Pollution prevention program
• Internal program for preventing, reducing,
  recycling, reusing, and minimizing waste and
  emissions, including procedures to encourage
  material substitutions.
• Mechanisms for identifying candidate materials to
  be addressed by program and tracking progress.

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Key Elements of aCompliance-Focused EMS
(contd)

• Evaluation and improvement
• Program for periodic (at least annually)
  evaluation of the EMS
• Program for ongoing evaluation of facility
  compliance with environmental requirements,
  including periodic compliance audits by an
  independent auditor(s).
• Audit results are reported to upper management,
  and potential violations are addressed through
  the process described under Environmental
  Incident and Noncompliance Investigations above.

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Key Elements of aCompliance-Focused EMS
(contd)

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

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EMS - Future Directions

• Increasing regulatory focus Compliance Focused
  EMS
• Moving From Certifying EHS Performance By
  Periodic Inspections To Continuous Demonstration
• Stronger Focus On Managing Costs, Optimizing
  Business Processes Quality Systems
• Real Time EHS Decision Making
• Governmental Organizations - Compliance With
  Executive Order 13148 Greening the Government
  Through Leadership in Environmental Management (
  December 31, 2005)

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EMS Compliance-Focused Tools

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

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Summary

• 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)

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Thank You!
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