- Environmental Management Systems (EMS)
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- EMS Training
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- Waste Management Related Initiatives
Environmental Management Systems Training Course (Text Only)
Introduction to EMS 101
Module 1, Scene 1
Environmental Management Systems (EMS) 101
(START)
Scene Note: The opening scene shows a generic industrial facility with EMS 101 as the title. The words Welcome to EMS 101 then scroll across. The text reads, this course is designed to provide an overview of environmental management systems (EMS) and how they can support environmental improvements in a variety of settings. This course consists of the following four modules:
- Module 1: Introduction
- Module 2: What is an EMS?
- Module 3: EPA's Perspective on EMS
- Module 4: Benefits and Examples of EMS
Enter the Facility and Begin the Course
Module 1, Scene 2
Scene Note: The plant manager, Clyde, stands inside the facility by a door and a chalkboard.
Clyde:
Welcome to Industrious Industries. I'm Clyde, the plant manager.
Industrious Industries is a medium-sized company that manufactures
widgets. Today we are hosting a meeting between the U.S. Environmental
Protection Agency (EPA), our state environmental agency (SEA), a
community representative, and Industrious Industries. We are going
to talk about Environmental Management Systems (EMS). This chalkboard
has some information about our company and the purpose of the meeting.
Module 1, Scene 3
The chalkboard reads:
This course takes place at Industrious Industries, a medium-sized manufacturing facility, with a generally strong compliance record. In the last year, the state and EPA identified several compliance violations at the facility. The corporate headquarters of Industrious Industries endorsed this plant's proposal to implement an EMS to improve the facility's overall compliance and environmental performance. The plant is hosting a meeting to share EMS information with EPA, the state, and local environmental representatives. The following representatives are attending the meeting:
Module 1, Scene 4
The chalkboard reads:
- Terry, Industrious Industries Corporate Environmental Representative
- Andrew, EPA Regional Representative
- Nancy, State Environmental Agency (SEA) Representative
- John, Citizen's Group Representative
- Clyde, Industrious Industries Plant Manager
Module 1, Scene 5
Clyde:
Well, everyone else is already in the meeting room; let's go inside.
Module 1, Scene 6
The chalkboard reads:
Module 1
Introduction
Module 1, Scene 7
Scene Note: The scene shows the meeting room for Industrious Industries. The meeting room contains a large conference room table with 5 chairs and a chalkboard. The representatives are seated around the table.
Clyde:
I'm Clyde, the plant manager for Industrious Industries. I am responsible
for production at this plant, as well as environmental compliance.
I lead EMS efforts at this plant.
Module 1, Scene 8
Terry:
I'm Terry. I also work for Industrious Industries at our Headquarters
location. I am responsible for environmental management across our
company. Today, I'll be providing some information on EMS and why
we chose to implement an EMS at this plant.
Module 1, Scene 9
Andrew:
I'm Andrew. I work for the EPA Regional office. I work with Nancy
to help monitor compliance with regulations at facilities in this
state.
Module 1, Scene 10
Nancy:
I'm Nancy. I work for your state environmental agency (SEA). Last
year, I identified some minor compliance violations at this plant.
Our agency has initiated some EMS efforts, so I'm happy to see that
Industrious Industries is promoting this concept.
Module 1, Scene 11
John:
I'm John. I work for the local chapter of Save the Environment.
We interact with all of the facilities in the area to help them
find better ways to protect the environment. Clyde was nice enough
to invite me to this meeting so that I can learn more about EMS.
Module 1, Scene 12
Clyde:
Welcome to Industrious Industries. As you know, today we will be
learning more about EMS. Our instructor will be Terry, who manages
EMS and compliance efforts for Industrious Industries. Also, Nancy
and Andrew will share some information about EMS, and EPA and the
state's involvement in EMS. As this is an exploratory meeting, let's
keep things informal and interactive. Terry, are we ready to get
started?
Module 1, Scene 13
Terry:
Thanks Clyde. I'm really happy to be here to share some information
on EMS with all of you. I'm sure this will be a productive meeting.
First, let's talk about what constitutes an EMS.
The chalkboard reads:
Click Here to go to module 2.
Scene Note: Clyde and the other representatives are still seated at the conference room table in the meeting room of the facility.
The chalkboard reads:
Module 2
What is an EMS?
Module 2, Scene 2
Terry:
Why don't we start with a little information on Industrious Industries
and how we have traditionally managed environmental protection?
Module 2, Scene 3
Clyde:
Sure. Historically, Industrious Industries has focused on regulatory
compliance approaches that allow the plant to meet its production
schedule and comply with the law. Running into any compliance issues
is bad for our reputation and also can impact our production schedule
and business goals. Over time, we've also implemented some pollution
prevention initiatives, but not in a systematic manner.
Module 2, Scene 4
Terry:
That's right. Most recently, we have seen that environmental management
and business practices are truly interrelated and we've focused
on integrating environmental management into our business in a more
systematic manner using EMS. EMS provides a framework for managing
our environmental efforts in a systematic way that integrates with
our overall business goals.
Module 2, Scene 5
Nancy:
I've heard that there are various models and standards for EMS.
Which one does Industrious Industries use?
Module 2, Scene 6
Terry:
There are several models that can be used to develop, implement
and maintain an EMS. Industrious Industries uses the model described
by the ISO 14001 Standard, which was developed by the International
Organization for Standardization (ISO) and builds on an approach
developed many years ago by quality experts. It focuses on continual
improvement through an ongoing cycle of actions called the Plan-Do-Check-Act
or continual improvement cycle. We'll talk briefly about each of
these components to explain the key steps that comprise an EMS.
Module 2, Scene 7
Chalkboard shows: "Plan, Do, Check, Act" diagram. The "Plan, Do, Check, Act" diagram is a circular image with arrows directing the viewer clockwise through the continual improvement cycle. Around the circle are five main boxes beginning at the 1o'clock position with the Environmental Policy, then onto 3 o'clock to the Planing phase, six o'clock is the Implementation phase, 9 o'clock is the is the Checking and Corrective Action phase, and then the Management Review phase located at 11 o'clock. The Management Review feeds back into the Planning phase to achieve changes required to attain and maintain the desired level of system effectiveness.
Module 2, Scene 8
Andrew:
Please note that EPA does not endorse any particular EMS model.
However, EPA generally supports the implementation of all EMS models
that promote sustained compliance, pollution prevention, community
involvement, and continual improvement. We will provide additional
information on EPA and state perspectives on EMS in Module 3.
Module 2, Scene 9
Terry:
That's right. EPA supports the implementation of EMS, but does not
mandate the manner in which we choose to implement it. At Industrious
Industries we use the model previously illustrated on the chalkboard.
I'll be talking about each of the components of this model in the
remaining parts of this Module.
Module 2, Scene 10
Terry:
An EMS begins with a strong ENVIRONMENTAL POLICY. This policy describes
the company's approach to managing its environmental affairs and
reflects its commitment to protecting human health and the environment.
Commitment to the environmental policy must originate from, and
be strongly supported by, top management. A recent study showed
that companies showing the greatest environmental improvements have
very strong upper management commitment. Our corporate president,
Ms. Isabel Industrious, has pledged her complete support to our
EMS. The environmental policy establishes a framework for environmental
leadership and acts as a contract between the personnel of the organization
and company stakeholders. Industrious Industries' environmental
policy is shown on the chalkboard
Scene Note: (click the > button ).
Module 2, Scene 11
The chalkboard expands and reads:
Environmental Policy
Industrious Industries is committed to
- Maintaining compliance with all environmental laws and regulations,
- Implementing pollution prevention projects and programs where practical,
- Improving our environmental performance over time by setting and achieving objectives and targets, and
- Communicating with the public regarding our plans and progress in environmental management.
Module 2, Scene 12
Terry:
Developing the environmental policy helps to lay the groundwork
for the EMS PLANNING phase. In addition to the environmental policy,
successful EMS implementation also requires:
- Ensuring that management is prepared to provide active support,
- Forming a multi-disciplinary EMS implementation team, and
- Holding a facility kick-off meeting to prepare everyone to implement the EMS.
Module 2, Scene 13
Clyde:
During this stage, we also developed the scope and budget for the
EMS. It's important to define the scope of the EMS up front. Generally,
the scope will be the facility's entire operation. However, for
large companies or facilities, a specific production operation,
production line, or support activity may have its own EMS.
Module 2, Scene 14
Terry:
That's right. In addition, at this point it's important that management
provides the resources needed for implementation. Now let's talk
in more detail about the Plan-Do-Check-Act elements of an EMS. These
phases, or steps, are the means used to achieve the environmental
policy commitments we just discussed.
Module 2, Scene 15
Terry:
The first Plan-Do-Check-Act step we'll discuss is PLANNING. The
PLANNING phase is critical to all subsequent phases because it identifies
what an organization does that can impact the environment. During
this phase, the facility evaluates all activities that it conducts
and products and services that it provides to identify environmental
aspects associated with facility operations and potential environmental
impacts. These terms are defined on the chalkboard.
Module 2, Scene 16
The Chalkboard expands and reads:
Planning
- Environmental Aspects
- Legal & Other Requirements
- Objectives & Targets
- Management Actions to Support Objectives and Targets
Environmental aspect - an element of an organization's activities, products, or services that can interact with the environment.
Environmental impact - any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organization's activities, products, or services.
(Source: ISO 14001 Standard).
Module 2, Scene 17
John:
Can you be more specific? Those definitions sound complicated.
Module 2, Scene 18
Terry:
You're right, John. Aspects and impacts are a hard concept to grasp.
Clyde, why don't we take a quick walk to the production line and
perhaps I can explain these terms more clearly.
Module 2, Scene 19
Scene Note: The five representatives are now in an industrial plating shop within Industrious Industries. There are four dip tanks along the shop floor and the second dip tank in the process has spilled material around it on the shop floor. There is a steel arm overhead moving a widget through the plating process. An Industrious Industries employee is overseeing the process.
Terry:
Do you see any activities here that have the potential to interact
with the environment?
Module 2, Scene 20
Scene Note: A yellow flashing arrow appears and points at the Industrious Industries employee.
Nancy:
Well, yes. That worker is adding some sort of chemical to the tank
over there. Does that mean chemical use is an environmental aspect?
Module 2, Scene 21
Scene Note: A yellow flashing arrow appears and points at the last of the four dip tanks.
Clyde:
Right. Also, that tank is being heated and the heating process,
along with the chemical reactions taking place in the tank, are
creating air emissions that we must control. The process of heating
the material in the tank causes air emissions, which are an environmental
aspect. Degradation of air quality would be an environmental impact.
Module 2, Scene 22
Terry:
Now you are getting the idea.
Module 2, Scene 23
Scene Note: A yellow flashing arrow appears and points at the second dip tank, which has spilled material on the floor around it.
John:
It also looks like there are some drips and spills from one of the
tanks. Therefore, drips and spills must be environmental aspects.
Module 2, Scene 24
Terry:
Yes, they are. If we don't collect and treat those properly, they
can impact the soil and groundwater under the plant. Soil and groundwater
contamination are environmental impacts. Spills and associated contamination
were a big problem at older Industrious Industries plants. At this
plant, we have control systems to prevent spills and minimize the
impact that could be associated with any spills that do occur. We
train workers specifically to help prevent spills and drips and
provide equipment and containment to help prevent or reduce the
"environmental impact" if a spill does occur.
Module 2, Scene 25
Scene Note: A yellow flashing arrow appears and points at the waste drum located at the end of the four dip tanks.
Andrew:
I see a drum collecting some hazardous waste at the end of the line.
Is the generation of hazardous waste an aspect or an impact?
Module 2, Scene 26
Terry:
Waste generation is an environmental aspect of a variety of activities.
An impact associated with hazardous waste generation would be the
potential for waste to be mismanaged and impact the environment
through releases to air, soil, or groundwater. Another potential
impact is the use of landfill space.
Module 2, Scene 27
Terry:
Well, I hope that our tour has helped you understand the concept
of aspects and impacts a little better. If you get confused as you
begin to evaluate all of the aspects and impacts at Industrious
Industries, you might want to think of an aspect as a potential
cause and the impact as the actual effect of an operation or activity
here at Industrious Industries. Well, let's go back to our meeting.
Module 2, Scene 28
Scene Note: The five representatives have returned to the meeting room and are seated back around the conference table.
Terry:
To summarize, examples of environmental aspects are chemical use,
energy use, use of natural resources, solid or hazardous waste generation,
wastewater generation, noise, and water use. One more note. Environmental
impacts can be positive or negative. We focus on reducing negative
impacts and increasing positive ones. To read more about aspects
and impacts for Industrious Industries, click here.
Scene Note: A table opens if the user selects to click. The table shows examples of Industrial Industries aspects and impacts.
Aspects | Impacts |
---|---|
Chrome emission to atmosphere | Degradation of air quality |
Cyanide emissions for plating tank | Worker exposure to cyanide |
Generation of wastewater | Water contamination |
Water use | Depletion of natural resources |
Module 2, Scene 29
Nancy:
Wow, now that I think about it, this facility has a lot of aspects
and impacts. How do you focus your efforts?
Module 2, Scene 30
Terry:
Well, we first decide if we can control the aspect. For an EMS,
we only focus on those aspects that we can control. For example,
we can't control everything about how raw materials are made, but
we do have control over who we purchase from, which materials we
use, and how we manage those materials during our production process.
So we focus on those things we can control. We also do not always
have control over how electricity is generated at the power plant
from which we purchase electricity, but we can exercise some control
over how much electricity we use. After we identify environmental
aspects we can control, we rank them using a predetermined set of
criteria. Each company or facility must develop criteria that are
important to achieving its specific environmental and business goals
and meeting its environmental policy commitments.
Module 2, Scene 31
Terry:
Once all of the environmental aspects are ranked according to the
predetermined ranking criteria, the facility identifies a cut-off
point to decide which environmental aspects will be considered important
to the organization. The aspects that are determined to be important
are called significant environmental aspects; these are the aspects
that rank highest against the facility's specific criteria. Establishing
these priorities allows management to focus the organization's resources
on priority areas. Addressing significant environmental aspects
will be discussed later as part of establishing objectives and targets.
Module 2, Scene 32
Nancy:
Some examples of ranking criteria that I have seen used at various
types of facilities include those listed on the chalkboard.
Module 2, Scene 33
The chalkboard expands and reads:
Potential Ranking Criteria
- Actual or potential environmental impact
- Costs associated with addressing the aspect or potential impact
- Potential savings from addressing the aspect
- Pollution prevention potential from addressing an aspect or impact
- Risk of noncompliance associated with an aspect
- Community concerns associated with an aspect
Module 2, Scene 34
Terry:
Thanks, Nancy; those are good examples. Another component of the
PLANNING phase is identifying Legal and Other Requirements. For
this part of planning, a facility should develop a specific procedure
that describes how the facility will identify legal and other requirements
that apply to its operations.
Module 2, Scene 35
Clyde:
At this facility, our Legal and Other Requirements Procedure describes
how we gather information, analyze it, and identify the requirements
that apply to our operations. Like other EMS procedures, it describes
the who, what, where, when, why, and how for this activity. For
this facility, our operations are regulated primarily under the
Resource Conservation and Recovery Act (RCRA), the Clean Air Act
(CAA), and the Clean Water Act (CWA). We have also identified several
other requirements that we voluntarily implement. For example, we
are adhering to the company's policy to implement pollution prevention,
improve environmental performance through objectives and targets,
and communicate with the public on our environmental management
progress.
Module 2, Scene 36
Andrew:
Thank you for that great overview of your legal and other requirements.
I think you have your work cut out for you. What's next?
Module 2, Scene 37
Terry:
Now that you have an understanding of our legal and other requirements,
we will examine our aspects and impacts to identify specific objectives
and targets. Check out the definitions on the chalkboard.
Module 2, Scene 38
The chalkboard expands and reads:
Objective
An overall environmental goal driven by the ENVIRONMENTAL POLICY that an organization sets out to achieve. An objective should be quantifiable, where practical.
Target
A detailed performance requirement, applicable to all or part of the organization, that arises from the environmental objectives. Targets also should be quantifiable, whenever practical, and should support achievement of the environmental objectives.
Module 2, Scene 39
Terry:
Objectives and targets are linked directly to specific aspects and
impacts. Environmental objectives represent specific goals that
are set, whereas targets provide quantitative or qualitative indicators
of environmental performance against established goals. The point
is that objectives and targets are designed to decrease negative
aspects and impacts or increase positive impacts. In other words,
objectives and associated targets are established to measure progress.
Module 2, Scene 40
John:
Objectives and targets sound kind of similar. Can you give an example
of an objective and a target?
Module 2, Scene 41
Terry:
Sure. This plant currently generates hazardous waste from various
processes used in the plating lines. We plan to reduce hazardous
waste generation at the plant; this is an objective. The quantifiable
target for that is to reduce hazardous waste generation by 10 percent
by the year 2005, using hazardous waste generation in 2003 as a
baseline. When you set objectives and targets, it is important to
make sure that you have the ability to track and measure your performance;
that is, you need to be able to measure progress. Then, during other
stages of the EMS process, you can report on progress toward achieving
the objectives and targets you set.
Module 2, Scene 42
Terry:
To ensure that the company's aspects and impacts are clearly defined
and that its objectives and targets can be met, it's useful to involve
plant personnel that may be impacted by any changes. In addition,
management must support the environmental policy and be willing
to invest money and resources to achieve objectives and targets.
Resources may be required to support training for facility personnel,
the purchase of new equipment, time for meetings, and hiring outside
consultants. Ultimately, management is responsible for providing
adequate resources and being involved in the development, review,
and approval of objectives and targets. Management personnel should
appoint an EMS coordinator. The EMS coordinator is the specific
management representative responsible for ensuring that the EMS
is established, implemented, and maintained in accordance with facility-specific
requirements.
Module 2, Scene 43
Clyde:
For our plant, I'm the EMS coordinator. The EMS objectives and targets
Terry discussed are documented in our Environmental Management Program.
Module 2, Scene 44
Terry:
That's right. The Environmental Management Program documents the
actions required to implement and achieve objectives and targets.
Other EMS models may use a different name for this document.
Module 2, Scene 45
The chalkboard expands and reads:
Environmental Management Program
An action plan that describes EMS objectives and targets; the program plan describes how the organization will translate its environmental goals and policy commitments into concrete actions to achieve environmental objectives and targets. It should describe: (1) responsibilities, (2) means, and (3) time frames.
In other words, the program should specify who will do what, how they will do it, and by when they will do it.
Module 2, Scene 46
Terry:
One of the most important parts of achieving objectives and targets
is for management to identify and designate a "champion" who is
responsible for ensuring their achievement.
Module 2, Scene 47
Clyde:
For this plant, I'm the champion (in addition to being the coordinator).
I know the facility and its environmental issues, work with the
plant personnel, and see the benefit of implementing an EMS here.
Also, Terry has made it very clear to me that implementation of
the EMS is part of my job responsibility.
Module 2, Scene 48
Terry:
Now that we've reviewed the PLANNING phase, let's talk about the
IMPLEMENTATION phase. During this step, we do the things that we
planned. Implementation includes a number of activities as shown
on the chalkboard.
Module 2, Scene 49
The chalkboard expands and reads:
Implementation
- Structure & Responsibility
- Training, Awareness, Competence
- Communication
- EMS Documentation
- Document Control
- Operational Control
- Emergency Preparedness and Response
Module 2, Scene 50
Clyde:
Well, the first activity includes defining a management structure
and associated roles and responsibilities for the EMS. We found
that the groundwork for this activity was laid during the planning
phase, when we developed environmental management programs designed
to achieve objectives and targets.
Module 2, Scene 51
Terry:
That's right, the steps build on, and support, each other. For the
EMS, roles and responsibilities should be defined, documented, and
communicated at all levels to facilitate effective implementation.
To ensure that EMS roles are established and associated activities
take place, job-specific EMS responsibilities should become a part
of each individual's job description. Incentives also can be used
- for example, some facilities provide incentives for employees
to meet EMS requirements, through reward and recognition programs.
Module 2, Scene 52
Terry:
Training is another key activity for implementation. Because EMS
concepts are new to many employees and impact their daily activities,
we can't expect success unless we teach them about our EMS and what
they can and must do to support it.
Module 2, Scene 53
Clyde:
At this plant, we found that there are essentially two types of
training needed. First, we developed an awareness training course
to raise the level of awareness of all personnel about the content
of our EMS, the company's environmental policy, our significant
environmental aspects, objectives and targets, and the environmental
commitments of management. The other type of training is job specific.
Module 2, Scene 54
Terry:
Job-specific training is tailored to job types to ensure that workers
understand the significant environmental aspects of their job functions
and the potential impacts of not following EMS instructions. The
training also reviews the benefits of improved environmental performance.
For example, such training may include instruction on how to manage
hazardous waste properly. Where EMS objectives and targets require
changes to equipment or operations, workers also need to be trained
regarding the changes required in how they perform their jobs.
Module 2, Scene 55
Terry:
Another important element of the IMPLEMENTATION step is communication.
This includes both internal and external communication to support
continual improvement with respect to environmental protection.
Internal communication focuses on communication within the plant
and within our company. Communication channels must be created to
ensure that the personnel that need information at any level and
function will receive that information in a reasonable time frame.
Personnel must also be able to forward suggestions and concerns
about the EMS to those management personnel that can appropriately
address such issues. It is quite helpful to allow all personnel
the authority to identify system nonconformance or regulatory noncompliance
and report such issues to the person responsible for managing the
corrective and preventive action process. This helps to foster continual
improvement. Of course, this only works well if employee suggestions
and comments are appreciated and rewarded.
Module 2, Scene 56
Terry:
The chalkboard shows some activities associated with internal communication
at this plant and at other Industrious Industries facilities.
Module 2, Scene 57
The chalkboard expands and reads:
Examples of Internal Communication
- Notes in pay checks that inform employees about EMS efforts
- Training courses
- Posted signs with reminders of key EMS goals and actions
- Weekly EMS meetings at the facility to review progress with key management personnel
- Posting of results of progress toward objectives and targets on facility bulletin boards (for example, waste generation and chemical use rates)
- Meetings with senior management to report on the EMS
- Employee suggestion box and communications about awards for successful projects
Module 2, Scene 58
Clyde:
At this plant, we also have identified our external stakeholders
and have implemented regular communication with them regarding our
EMS. This group includes customers, vendors, suppliers, neighbors,
and regulators. More importantly we have a procedure to receive
and document external concerns and ensure an appropriate response
in a timely manner. Here are some of the ways we
communicate with our external stakeholders:
Module 2, Scene 59
The chalkboard expands and reads:
Examples of External Communication
- Meeting with vendors and suppliers to explore options for green chemicals
- Telling customers about our EMS efforts
- Participating in community meetings to discuss our plant and its EMS efforts
- Hosting an open house or tour of the facility
- Hosting meetings like this to share information and obtain input about EMS efforts
- Communicating our EMS efforts to Federal, state, and local regulators
Module 2, Scene 60
Clyde:
Even before we implemented our EMS we were communicating externally.
Module 2, Scene 61
Terry:
That's great. It also shows that this plant, like most other organizations,
already has some of the elements of an EMS in place. The EMS simply
helped to bring all of the elements together.
Module 2, Scene 62
Another activity associated with the IMPLEMENTATION step is documentation; this falls into two categories: (1) documentation that describes the EMS, and (2) other documentation related to the EMS.
Module 2, Scene 63
Nancy:
I believe that the first item includes your EMS manual, which describes
the core elements of your EMS and provides direction to related
documentation like management procedures, work instructions, and
forms. The chalkboard shows examples of EMS documentation.
Module 2, Scene 64
The chalkboard expands and shows a pyramid of different levels of EMS documentation:
EMS Documentation Pyramid
Level I - Policy; system description
Level II - Operational and management procedures
Level III - Work instructions or standard procedures
Level IV - Plans and reference documents
Level V - Records
Module 2, Scene 65
Scene Note: The chalkboard continues to show the pyramid
Part of document management includes identifying each EMS document and its document retention period. Five levels of EMS documentation typically constitute the hierarchy. As you move down the pyramid, the level of detail and number of pages generally increase. Level I documents record leadership's stated intent and approach to environmental management. Level II documents define specific activities used by the organization and specifically identify the who, what, when, where, why, and how for these activities. Level III documents include detailed work instructions or checklists used by each group of the organization. Level IV documents are supporting information that typically includes example forms, labels, logs, and drawings. Level V includes the records which provide a written history of EMS performance and actions completed.
Module 2, Scene 66
Terry:
That's right. The first level of EMS documentation includes the
environmental policy and an overall description of the EMS. Subsequent
levels include procedures and activity-specific documentation that
support the EMS, including work instructions, emergency preparedness
and response plans, training plans, and media-specific compliance
plans.
Module 2, Scene 67
Clyde:
Because documentation is so important, we have a specific EMS Document
Control procedure. At this point, examples of documents we manage
as a part of our EMS is shown on the chalkboard.
Module 2, Scene 68
The chalkboard expands and reads:
EMS documents that should be controlled under the EMS Document Control Procedure are:
- Environmental policy
- Lists of objectives and targets
- Description of roles, responsibilities, authorities, and lines of communication
- EMS Manual (system description)
- System-level procedures
- Work instructions to support the EMS
- Related plans (for example, emergency preparedness and response and training plans)
Module 2, Scene 69
Clyde:
For the EMS, we also developed and described the means and controls
we use to make sure that EMS documentation is up to date and readily
available to all employees. Our EMS Document Control Procedure describes
how we manage our EMS documentation. It describes how documents
are periodically reviewed and revised and how obsolete documents
are promptly removed from all points of issue and use.
Module 2, Scene 70
The chalkboards expands and reads:
The EMS Document Control Procedure should address how EMS documents will be:
- Prepared
- Issued and distributed
- Revised
- Reviewed
- Disposed of (for outdated documents)
Module 2, Scene 71
Terry:
Now let's talk about operational controls. Operational controls
ensure that operations and activities do not exceed specified conditions
or performance standards, or violate applicable regulations such
as discharge limitations. Operational controls are used to support
the EMS and can be physical controls, engineering controls, or administrative
controls. The need for an operational control is based on the significant
aspects and legal requirements identified earlier.
Module 2, Scene 72
Terry:
For aspects that need to be controlled, we review whether existing
physical controls (for example, berms, walls, and roofs), engineering
controls (for example, alarms, level indicators, and gauges), and
administrative controls (procedures and inspections) are sufficient.
If they are not, we must develop an operational control. For example,
we have developed operational controls on our plating lines regarding
chemical use, production methods, and temperature control to support
both high quality production and our EMS objectives and targets.
These operational controls help ensure that specified conditions
and performance standards are met.
Module 2, Scene 73
Clyde:
For example, at this plant we have an Operational Control Procedure
that describes how our wastewater treatment plant will be operated
to ensure compliance with Clean Water Act permit requirements regarding
discharges to surface water from our facility.
Module 2, Scene 74
The chalkboard expands and reads:
Examples of activities that may require operational controls include:
- Chemical purchasing
- Material handling
- Maintenance
- Plating line operations
- Wastewater treatment system operation
- Waste accumulation and disposal
- Storage of parts before off-site shipment
Module 2, Scene 75
Terry:
One of the goals should be to keep operational control procedures
simple, focusing on the "who, what, where, when, how, and why" of
getting the job done to meet both facility production and EMS requirements.
Module 2, Scene 76
Andrew:
Just as a note, for EPA's National Environmental Performance Track
program, facilities must have operation and maintenance programs
for equipment and operations that relate to legal and regulatory
compliance and associated significant environmental aspects. We
will talk more about this program later.
Module 2, Scene 77
Terry:
Thanks Andrew. The last item under IMPLEMENTATION is emergency preparedness
and response. Of course, this activity is critical whether you have
an EMS or not. Industrious Industries facilities already have strong
programs in this area (1) to comply with applicable environmental
laws and corporate policy and (2) most importantly, to protect our
personnel and those who live around our plant.
Module 2, Scene 78
Clyde:
Right. At this plant, we built on existing procedures and plans
to develop our Emergency Preparedness and Response Plan for the
EMS. One area we had to improve was the process for identifying
the potential for emergencies and accidents. Typically, we had complied
with applicable legal requirements. However, for our EMS we wanted
to be more proactive and identify potential hazards that were not
strictly regulated.
Module 2, Scene 79
The chalkboard expands and reads:
Items that should be addressed in the Emergency Preparedness and Response (EPR) program include:
- Type and location of hazardous substances used and stored on site
- Key organizational responsibilities
- Arrangements with local emergency responders, including points-of contact for response agencies
- Emergency response procedures
- Emergency communication (lines of communication and internal and external contact information)
- Locations and functions of emergency equipment and provisions for maintenance of such items
- Prevention requirements (for example, testing alarms, training)
- Evacuation routes
Module 2, Scene 80
Terry:
At Industrious Industries, we make sure that our EPR plans address
relevant environmental regulations and the requirements of the EMS.
This is helping us consolidate our EPR efforts so we have less documents
and clear direction regarding what we need to do in the event of
an emergency. This is sometimes referred to as integrated contingency
planning. Important EPR items include identifying the potential
for problems, testing the EPR plan annually, and updating the EPR
plan, as necessary. The third step of the EMS cycle is CHECKING
AND CORRECTIVE ACTION.
Module 2, Scene 81
The chalkboard expands and reads:
Checking and Corrective Action
- Monitoring & Measurement
- Nonconformance, Corrective & Preventive Action
- Records
- EMS Audit
Module 2, Scene 82
Terry:
Now let's discuss the third step of the EMS cycle, CHECKING AND
CORRECTIVE ACTION. Checking evaluates how we are doing and corrective
action responds to any issues we identify. Questions we ask include:
Are we doing what we said we would do? If not, why? Are we making
progress toward our objectives and targets? Do we need to make any
adjustments? If we properly set up the tracking mechanisms during
our PLANNING and IMPLEMENTATION steps, checking simply represents
making sure that everything is being done and evaluating results.
This is where it all starts to tie together.
Module 2, Scene 83
Terry:
The first item under the CHECKING AND CORRECTIVE ACTION phase is
monitoring and measurement. This means that we track specific parameters
that help us:
- Document that we are implementing the EMS,
- Determine if we are meeting our objectives and targets,
- Achieve operational control,
- Calibrate monitoring equipment, and
- Ensure compliance.
Module 2, Scene 84
Terry:
Remember, for this first round we are focusing on what was significant
during the initial PLANNING phase.
Module 2, Scene 85
Clyde:
To help illustrate the concept of monitoring and measurement, examples
of items that we measure and monitor at this Industrious Industries
plant are shown on the board.
Module 2, Scene 86
The chalkboard expands and reads:
Example monitoring and measurement items:
- Chemical additions and concentrations in the plating baths
- Plating bath temperature
- Percent of widgets meeting quality specifications
- Amount of hazardous waste generated
- Amount of solvent used for parts cleaning
- Use of checklists to determine compliance with applicable regulations
Module 2, Scene 87
John:
How do you track all of that?
Module 2, Scene 88
Terry:
Well, at Industrious Industries we use databases to track production
data. We have modified some of these to track items such as those
shown above. Employees either use a computer terminal at their work-station
or complete daily or weekly logs that are then provided to our administrative
personnel for data entry. It's a good amount of work, but it supports
our production quality program as well as the EMS. Our production
quality has improved at plants that implement monitoring and measurement
efforts related to the EMS or related to quality improvement programs.
Module 2, Scene 89
Andrew:
Terry, who looks at all of that data?
Module 2, Scene 90
Terry:
Well, our plant supervisors and managers use it for a variety of
purposes, including determining if we are in conformance with the
EMS. We also use it to plan for chemical and raw material purchasing,
staffing, and similar items.
Module 2, Scene 91
Clyde:
Also, we post key data on our bulletin board to show how well we
are doing; sharing information with staff helps us keep moving in
a positive direction. The chalkboard shows an example of an EMS
tracking chart for one of our production lines. The chart shows
water use normalized per square foot of parts plated. We normalize
most data we track to account for changes in our production levels.
Module 2, Scene 92
The chalkboard expands and shows a combination bar and line chart, titled:
Water Use Normalized Per Square Foot of Parts Plated
Scene Note: The chart shows gallons of water use in 1,000-gallons on the Y-axis. The second Y-axis shows production in 100 square foot plated. Months are shown on the X-axis. The trend of the line generally shows water use in production decreasing over time.
Module 2, Scene 93
Clyde:
This next chart shows our caustic soda use normalized to production.
Module 2, Scene 94
The chalkboard expands and shows a combination bar and line chart, titled:
Caustic Soda Use Per Square Foot Plated.
Scene Note: The chart shows caustic use in tons on the Y-axis, influient in million gallons on the second Y-axis, and months on the X-axis.
Module 2, Scene 95
Clyde:
We also track and try to reduce the number of rejected parts because
hazardous waste is tripled when we generate reject parts.
Module 2, Scene 96
John:
What do you mean hazardous waste generation is tripled when you
generate a reject part?
Module 2, Scene 97
Clyde:
Well, we first generate waste to plate the part. Then we generate
waste when we strip the part using toxic chemicals to remove the
poor quality plating. Then we have to plate the part again and this
generates more waste. So you can see that quality and the environment
are interrelated.
Module 2, Scene 98
Terry,
This brings us to our next EMS activity: non-conformance, checking, and preventive action. Despite our best efforts, non-conformance occasionally will occur and must be addressed. The chalkboard shows a definition of non-conformance.
Module 2, Scene 99
The chalkboard expands and reads:
Non-conformance -
When facility practices do not meet applicable EMS criteria or when EMS implementation is not consistent with the procedures described in the EMS.
Module 2, Scene 100
Andrew:
Can you give some examples of EMS non-conformance?
Module 2, Scene 101
Terry:
Sure. The chalkboard shows some examples that we've run into at
Industrious Industries.
Module 2, Scene 102
The chalkboard expands and reads:
Examples of non-conformance include:
- Work instructions are not followed or records that document compliance with work instructions are not available (for example, required inspection logs are not completed)
- Employees do not receive required training
- Contrary to established procedures, contractors are allowed on-site to conduct work without meeting pre-approval criteria
- The EMS documentation is not kept up-to-date
Module 2, Scene 103
Terry:
When problems occur, we try to identify the root cause of the problem
to ensure that corrective and preventive action will be effective.
The root cause is the reason WHY something is in non-conformance.
For example, if a work instruction is not followed, it may be because
there is a new worker that did not receive proper training. In that
case, the work instruction is not the root cause of the problem,
our training program is.
Module 2, Scene 104
Terry:
Procedures should be established to define the responsibility and
authority for handling and investigating non-conformance. Efforts
are then implemented (1) to mitigate any impacts caused by the non-conformance
and (2) to initiate corrective and preventive action. Reoccurrence
of a non-conformance is prevented through implementation of operational
controls, training, monitoring and measurement, and management review.
Module 2, Scene 105
Terry:
The CHECKING AND CORRECTIVE ACTION phase also includes records.
As we discussed earlier, records are one level of EMS documentation.
Records are objective evidence that prove EMS activities have been
performed or that desired results have been achieved.
Module 2, Scene 106
Nancy:
Are records the same as procedures?
Module 2, Scene 107
Terry:
No. Procedures are prescriptive and tell you what to do; records
are objective and provide evidence of the results of following a
procedure. For example, we have an Operational Control Procedure
for our wastewater treatment plant. It states what we will do when
we treat wastewater and how we will do it. The wastewater treatment
system log sheets and our database document that the procedure is
followed and track our results; this comprises the record for that
procedure.
Module 2, Scene 108
Clyde:
Basically, records document that you are doing what you said you
would do within your EMS, including: training, setting of objectives
and targets, identifying legal and other requirements, implementing
operational controls, and following EMS system-level procedures.
When you audit the EMS, records are one type of documentation that
will be reviewed.
Module 2, Scene 109
Terry:
Right. Records provide a means of tracking the history of our EMS
progress. Because they are part of the EMS and will be audited,
EMS records must be kept in good order and should be readily retrievable.
That is one reason that records are addressed in the EMS Document
Control Procedure we discussed earlier. This brings us to the last
item under CHECKING AND CORRECTIVE ACTION, EMS Audits.
Module 2, Scene 110
Terry:
EMS audits check that the EMS system is implemented as planned.
EMS audits are conducted internally or by outside parties to make
sure the system is working or to support criteria related to certifications
or participation in voluntary programs. For example, the EPA National
Environmental Performance Track program expects members to conduct
EMS auditing and prepare annual reports that document progress towards
meeting EMS objectives and targets. Also, EPA conducts site visits
at selected member facilities in the program to help maintain program
credibility.
Module 2, Scene 111
John:
I have seen some companies advertise that they are ISO registered.
What does that mean?
Module 2, Scene 112
Terry:
Well, for facilities that choose to implement an EMS that conforms
to the ISO 14001 Standard, there is a formal registration they can
receive. EMS auditors working for an organization that is accredited
by ISO's Registrar Accreditation Board (RAB) will audit the facility's
EMS to document that the EMS is implemented in conformance with
the requirements of the standard. Once a facility passes such an
audit, the facility can claim that it is an ISO 14001 registered
organization. The registration may help you compete with other companies
in your industry. For example, most of the large automakers require
that their suppliers are ISO 14001 registered.
Module 2, Scene 113
The chalkboard expands and reads:
Management Review
Module 2, Scene 114
Terry:
Well, the next step in the EMS cycle is MANAGEMENT REVIEW. This
is where people like me come back into the picture. It is good to
have a management review procedure to ensure that top management
periodically meets to evaluate the EMS. Management needs to ensure
that the system is implemented as planned and that it is producing
the expected results. Management reviews are one key to continual
improvement and help ensure that the EMS will continue to meet the
organization's needs over time.
Module 2, Scene 115
Nancy:
What types of things do you consider during your MANAGEMENT REVIEW?
Module 2, Scene 116
Terry:
Some examples are provided on the chalkboard.
Module 2, Scene 117
The chalkboard expands and reads:
Management Review
Examples of information considered during management review:
- EMS audit results
- Reports of spills or incidents
- Progress against objectives and targets
- Review of aspects and impacts
- Details regarding implementation of EMS procedures and work instructions
- Actual or potential changes to legal and other requirements
- Business and environmental challenges and their relevance to the EMS
Module 2, Scene 118
Terry:
The MANAGEMENT REVIEW phase not only considers where things stand,
but makes sure that resources are available to make them better.
Here we begin to look forward and start to plan our improvements.
This returns us to the PLANNING phase of the EMS cycle. In closing,
I'd like to reemphasize our commitment to EMS. Also, we've been
happy to see EPA is endorsing the use of EMS. I thought perhaps
our guests could discuss EPA's EMS perspective. Andrew, would you
like to lead that discussion?
Module 2, Scene 119
Andrew:
Sure.
Module 2, Scene 120
Scene Note: The chalkboard says: Click Here to go to Module 2 Quiz
Module 2 - What is an EMS? - Quiz
1. Which of the following is not a major component of an EMS?
- Planning
- Implementation
- Management Review
- Checking and Corrective Action
- Responding to Notices of Violation
Answer: E. Responding to Notices of Violation
Responding to notices of violation is a subset of corrective action under the broader heading of "checking and corrective action."
2. An environmental policy:
- Must be supported by top management
- Establishes a framework for environmental leadership
- Acts as a contract between personnel of the organization and company stakeholders
- Is the first step in implementing an EMS
- All of the above
Answer: E. All of the above
3. An EMS should include provisions designed to:
- Achieve compliance with legal and other requirements
- Promote pollution prevention
- Communicate with affected stakeholders
- B and C
- All of the above
Answer: E. All of the above
An EMS should include a policy that supports pollution prevention as well as procedures for complying with legal and other requirements and communicating with internal and external stakeholders such as suppliers, vendors, the community, and personnel from regulatory agencies.
4. Please complete the following statement: The generation of hazardous waste is (an):
- Environmental impact
- Environmental aspect
- Both of the above
- Neither of the above
Answer: B. Environmental aspect
The generation of a hazardous waste is an environmental aspect. Any release of a hazardous waste, such as a release to soil, would be an environmental impact.
5. Which of the following is not true about EMS objectives and targets?
- Facility personnel should strive to make targets quantifiable, but this approach is not always necessary for objectives
- Targets are detailed performance requirements that are designed to support the achievement of objectives
- An EMS should include systems to track and measure progress against objectives and targets
Answer: B. Facility personnel should strive to make targets quantifiable, but this approach is not necessary for objectives
Facility personnel should strive to make both EMS objectives and targets quantifiable, where practical, and should develop systems in the EMS to enable facility personnel to track and measure progress against objectives and targets.
6. An environmental management program is not:
- An action plan that describes EMS objectives and targets
- A statement of the organization's environmental policy
- A document that describes how organizations will translate environmental goals and commitments into action
- A document that includes responsibilities, means, and time frames
Answer: B. A statement of the organization's environmental policy
An environmental management program is a component of the EMS Planning phase; a statement of environmental policy should be developed before the EMS Planning phase.
7. True or false - Training staff is not necessary for successful implementation of an EMS.
- True
- False
Answer: B. False
EMS concepts likely will be new to many employees and will impact their day-to-day activities. An EMS will not be successful unless staff are trained on why the EMS is being implemented and what they can do to help.
8. Which of the following is likely least important to discuss during the Management Review phase of an EMS?
- Results of an EMS Audit
- Environmental aspects and impacts
- Strategies for managing regulators during inspections
- Actual or potential changes to legal requirements
Answer: C. Strategies for managing regulators during inspections
Because an EMS is designed to include proactive approaches to managing environmental obligations, a management review of an EMS should focus on proactive, EMS-related items. Reactive approaches (such as strategies for managing regulators during inspections) should be of less importance to facility management during the EMS management review.
Proceed to Module 3
Scene Note: The five representatives are sitting at the conference room table in the meeting room at the facility.
The chalkboard reads:
Module 3
EPA's Perspective on EMS
Module 3, Scene 2
Andrew:
Okay, let's talk about EPA's perspective on EMS. Generally speaking,
EPA believes that an effectively designed and operated EMS is advantageous
to businesses and can play a role at facilities that are regulated
by a number of statutes (for example, the Resource Conservation
and Recovery Act, also known as RCRA, the Clean Air Act, and the
Clean Water Act). Because EMS is a proactive approach to environmental
management, it can create an environment that supports regulators
and the regulated community working together efficiently and effectively.
The chalkboard shows an explanation of EMS that I like.
Module 3, Scene 3
The chalkboard reads:
An EMS serves the organization and its mission. Implementing EMS is a process, not an end result. It's the people and their actions, not their words and aspirations. Improvement rests on changing attitudes and behaviors to want to, not have to.
Module 3, Scene 4
John:
If a company has an EMS, does that ensure it will be in compliance
with all environmental laws?
Module 3, Scene 5
Andrew:
That's a good question John. While there are no guarantees of 100
percent compliance
with environmental regulations, EPA believes that a well-run EMS can improve a facility's environmental performance. Strong initial implementation and a commitment to sustaining EMS efforts are important to EMS success, including sustained compliance and continual environmental improvement.
Module 3, Scene 6
John:
It seems to me that many systems could be called an EMS. Does EPA
have a more specific idea about what type of EMS a facility should
implement?
Module 3, Scene 7
Andrew:
There are many approaches to EMS. At a minimum, all facilities must
have some method for addressing environmental requirements and achieving
compliance. In the past, facilities often had a number of media-specific
systems or programs in place, each focusing on complying with specific
laws (for example, the Clean Air Act). Also, facilities often relied
on reactive systems that responded to problems as they occurred.
In contrast, an EMS employs a proactive and holistic approach that
deals with all environmental obligations in a systematic manner.
EPA encourages the use of recognized environmental management frameworks,
such as the ISO 14001, as a basis for designing and implementing
an EMS.
Module 3, Scene 8
Andrew:
EPA supports and promotes the development and use of any EMS that helps the organization achieve its environmental obligations and improve its long-term environmental performance. While we don't require or endorse a specific EMS standard, we are familiar with a number of models that could be used (e.g., the EXIT EPA symbol.)
In addition, EPA has developed EMS templates and tools for a number of industry sectors, for small businesses, and for federal facilities, like Army bases. Learn more about different models and templates.
Module 3, Scene 9
Terry:
As we discussed earlier, perhaps the most well recognized and formalized
EMS approach is the ISO 14001 Standard for EMS. However, EPA supports
any Plan-Do-Check-Act approach that can help to improve environmental
performance.
Module 3, Scene 10
Andrew:
That's right. EPA's position on EMS is documented in a May 2002
Position Statement on EMS. The EPA Administrator signed this position
statement, which includes the following principles of continual
improvement:
Module 3, Scene 11
The chalkboard expands and reads:
- Encourage widespread use of EMS across a range of organizations and settings with emphasis on compliance, continual environmental improvement, and pollution prevention
- Encourage organizations that use EMS to obtain stakeholder input, demonstrate accountability, and share the information with the public and government agencies
- Encourage use of recognized environmental management frameworks
- Work collaboratively with key partners such as states, tribes, localities, industry, and non-government organizations to implement its policy
- Lead by example by implementing EMS at appropriate EPA facilities
- Foster continual learning by supporting research and public dialogue on EMS
Module 3, Scene 12
Clyde:
What about EPA? You are telling facilities and other organizations
that EMS is a good idea. Are you doing anything to implement EMS
within EPA itself?
Module 3, Scene 13
Andrew:
As a matter of fact, we are. EPA has developed its own Policy on
EMS that includes a number of internal commitments as shown on the
chalkboard:
Module 3, Scene 14
The chalkboard expands and reads:
- Ensure compliance by meeting or exceeding all applicable environmental requirements
- Strive to continuously improve environmental performance in terms of both regulated and unregulated environmental impacts
- Employ source reduction and other pollution prevention approaches whenever practicable
- Require consideration of environmental factors when making purchasing and operating decisions
- Establish, track and review specific environmental performance goals
- Share information on environmental performance with the public and allow appropriate opportunities for input into EMS development and implementation
Module 3, Scene 15
John:
I'm glad to hear EPA is also implementing EMS. Where can I learn
more about EPA tools and resources to support EMS?
Module 3, Scene 16
Andrew:
The main EPA EMS Web Page,
is a good starting point. It links to a range of documents and sites
where tools and resources are available.
In addition, it links to EPA's Innovation Strategy, which includes EMS as a key innovation action item. Finally, EPA is developing various guidance documents and policy statements that encourage users to integrate an EMS into their permitting and compliance efforts. For example, in April 2004 EPA released a Strategy for Determining the Role of Environmental Management Systems in Regulatory Programs. The strategy addresses how EPA may consider EMSs in permits and regulations.
Module 3, Scene 17
Andrew:
In addition, EPA is implementing voluntary recognition programs,
such as the EPA National Environmental Performance Track Program.
The program's criteria require the implementation of EMS. The program
provides recognition and some regulatory flexibility for members
that are in good standing with the criteria of the program.
Module 3, Scene 18
Clyde:
Can you tell us a little more about the Innovations Strategy and
the National Environmental Performance Track Program you just mentioned?
Module 3, Scene 19
Andrew:
Sure. The purpose of EPA's Innovation Strategy is to address the
need for a broader set of tools than EPA has relied upon in the
past. This broader set of tools will help EPA address increasingly
complex and interrelated environmental challenges, including those
that focus on protecting our air, water, and land and finding ways
to achieve environmentally sustainable growth. Expanding the use
of EMS is one of EPA's 14 Key Actions associated with the Innovation
Strategy.
Module 3, Scene 20
EPA's National Environmental Performance Track Program, was designed to recognize and reward good environmental performers. This program offers recognition and regulatory incentives to organizations with good compliance records and EMSs that focus on sustained compliance, pollution prevention, community involvement, and continual improvement in environmental performance.
Module 3, Scene 21
Andrew:
In addition, EPA headquarters offices and EPA regions have developed
and tested EMS templates, or guidance documents, for specific government
and industry sectors, for example:
local governments, metal finishing, colleges and universities, and other sectors.
Module 3, Scene 22
John:
Why would there be specific guidance documents and sector initiatives?
Are there different standards for EMS for each industry?
Module 3, Scene 23
Andrew:
That's a good question. The EMS standards are not specific to any
industry or group. However, each industry or group has particular
compliance, waste management, and other environmental challenges
and regulations that must be addressed. Therefore, the tailored
guides include information that is more specific to each group's
needs.
Module 3, Scene 24
Terry:
We have found these sector specific materials to be very useful.
You can learn more about EPA's EMS sector initiatives by visiting
EPA Sectors Strategies Division Web Site.
EPA also promotes EMS through several voluntary partnership programs
and by encouraging the consideration of EMS approaches when addressing
compliance issues. EPA policy and guidance documents on EMS provide
more information on how EMS approaches can be integrated into such
efforts. A good source for general information and for links to
other EPA and non-EPA programs is the main EPA EMS Web Site.
Module 3, Scene 25
John:
How is EPA's EMS effort organized?
Module 3, Scene 26
Andrew:
Well, different offices focus on EMS efforts that support their
programs and efforts. The EPA Office of Water has focused on EMS
initiatives with local governments and has launched a national Public
Entity EMS Resource (PEER) Center to provide on-line EMS resource
information and assistance to public entities. In addition to a
National PEER Center, eight local Resource Centers have been established.
Module 3, Scene 27
Andrew:
EPA's Office of Solid Waste, OSW (renamed Office of Resource Conservation and Recovery, ORCR, on January 18, 2009) encourages the widespread adoption
of successful, high quality EMSs at facilities regulated under RCRA.
ORCR also works to ensure that, at a minimum, the RCRA permitting
program is constructed in a manner that allows for, and facilitates,
EMS implementation with an emphasis on continual pollution prevention,
improved environmental performance, and regulatory compliance.
Module 3, Scene 28
Andrew:
ORCR is working with the EPA Regions and States to use EMS as a tool
in voluntary programs and to conduct pilot programs for potential
changes in permitting programs that allow EMS-based changes to be
made. Finally, ORCR is sharing EMS information with its Regional
and state partners and developing appropriate assistance programs.
If you would like more information about ORCR EMS efforts, you can
read the following EPA Fact Sheet (PDF) (2 pp, 973K, About PDF)
Module 3, Scene 29
John:
That sounds good. But I am more involved at the local level. What
is going on in the EPA Regions and States?
Module 3, Scene 30
Andrew:
Your local branches of the EPA, called Regions, also are implementing
EMS initiatives. You can learn more about efforts in your area by
visiting the EPA Regional Web Pages.
EPA Regional Offices and State programs are implementing EMS efforts that focus internally on their own organizations and externally on the communities in which they are located and the facilities that they regulate.
Module 3, Scene 31
Andrew:
You can also refer to EPA Regional and Other EMS Assistance Programs for EPA-related EMS programs and links to some EPA Regional EMS
Programs. Other examples include the Design for the Environment
EMS Implementation Guide, efforts by the Office of the Small Business
Ombudsman, and the work of Compliance Assistance Centers. Links
to all of these are available on the EPA EMS Web Site.
Module 3, Scene 32
John:
Wow. There is a lot going on.
Module 3, Scene 33
Andrew:
There sure is. Also, you should note that the specific programs
and opportunities for your business and area also depend on your
state. Nancy, perhaps you can talk about state efforts related to
EMS.
Module 3, Scene 34
Nancy:
Sure. A good number of states have voluntary EMS programs, provide
EMS technical assistance, or provide EMS training opportunities.
For example, the Texas EMS Program
provides incentives for regulated entities that adopt and implement
a results-based EMS. To receive incentives, regulated entities must
have an EMS approved by the Texas Commission on Environmental Quality
(TCEQ) either through a TCEQ audit or through an approved third
party audit. The state also provides technical assistance and training
support.
Module 3, Scene 35
Andrew:
I also know that the California EPA has an EMS and Sustainability
Program which includes a focus on pilot projects and other efforts that
will help determine if EMS increases public health and environmental
protection, and provides better public information than existing
regulatory requirements.
Module 3, Scene 36
Nancy:
Yes. Texas and California are just two examples. I certainly can't
cover each state during this meeting. However, I would like to stress
that many states are supporting EMS efforts. You can check with
your EPA Regional or state environmental agency web sites or call
these entities to learn more about specific incentives, assistance,
and programs in each state.
Module 3, Scene 37
The chalkboard reads:
Click Here to go to Module 3 Quiz
Module 3, EPA's Perspective on EMS - Quiz
1. True or False: - EPA has developed EMS templates or guidance documents for specific industrial sectors:
- True
- False
Answer: A. True
EPA has developed EMS templates or guidance documents for industrial sectors such as local governments, the metal finishing industry, and colleges and universities. Additional information about sector-specific EMS materials prepared by EPA can be found on the EPA Sector Strategies Division Web Site.
2. Which of the following entities has developed specific EMS policies and programs?
A. EPA Headquarters
- EPA Regions
- State Environmental Agencies
- All of the above
Answer: D. All of the above
Depending upon the region of the county in which you are located, there may be multiple EMS policies or programs that apply in your area. Interested parties should check with the appropriate EPA Regional office or state environmental agency for more information.
3. Which of the following is an EPA voluntary program that encourages the use of EMS and provides recognition to participants in the program?
- National Environmental Performance Track Program
- EMS and Sustainability Program
- EPA's Innovation Strategy
Answer: A. National Environmental Performance Track Program
The National Environmental Performance Track Program encourages the use of EMS and provides recognition and some regulatory flexibility for participants that are in good standing relative to the criteria for the program. The EMS and Sustainability Program is a program that has been implemented in the state of California to determine the impact of EMS implementation on public health and environmental protection and the effectiveness of communication efforts toward stakeholders. EPA's Innovation Strategy is a comparatively broader effort that is designed to encourage innovative methods of solving environmental problems, of which EMS initiatives are one part.
Proceed to Module 4
The chalkboard reads:
Module 4
Benefits and Challenges of EMS
Module 4, Scene 2
Terry:
We have covered a lot of information today. We learned about EMS
and EPA's perspective on EMS. It's important to remember that the
specific design and implementation of an EMS is different in each
and every organization. The effectiveness of the system is highly
dependent upon an organization's commitment to establish and maintain
an effective system. I thought we could end our meeting by reviewing
some benefits and challenges associated with EMS.
Module 4, Scene 3
Terry:
Potential benefits of EMS are summarized on the chalkboard.
Module 4, Scene 4
The chalkboard expands and reads:
An EMS may help you:
- Improve environmental performance;
- Enhance compliance;
- Prevent pollution and conserve resources;
- Reduce or mitigate risks;
- Attract new customers (and retain customers that require suppliers to have an EMS);
- Increase efficiency and reduce costs;
- Improve employee morale and the recruitment of new employees;
- Enhance your image with citizens, regulators, lenders, and investors;
- Improve employee awareness of environmental issues and responsibilities; and
- Qualify for recognition and incentive programs such as the EPA National Environmental Performance Track Program.
Module 4, Scene 5
Terry:
However, developing and implementing an EMS may involve some costs
and pose challenges, including those shown on the chalkboard.
Module 4, Scene 6
The chalkboards expands and reads:
Potential costs and challenges associated with EMS:
- Internal resources, including management and employee time, are required;
- Facility personnel likely will require additional training;
- Consultants may need to be hired;
- Technical resources may be required to analyze environmental impacts and improvement options;
- New technologies may be needed to support environmental objectives and targets;
- Senior management must be committed and provide resources;
- A long-term commitment to EMS is required for success;
- Facility personnel may be resistant to the changes that are necessary to implement an effective EMS; and
- Facility personnel may view EMS obligations as "not part of my job."
Module 4, Scene 7
Andrew:
Those are good examples of benefits and challenges. EPA also has
some materials explaining the business case for EMS (for example, EMS Business Advantage (PDF) (8 pp, 435K, About PDF)
Module 4, Scene 8
Nancy:
Well, I've been looking into that and there are lots of resources.
For example, part of the EXIT EPA SYMBOL University of North Carolina
at Chapel Hill EMS Study effort includes maintaining a national
database of EMS implementation. This effort included collecting
data on EMS implementation for a number of years and has resulted
in the preparation of a report that documents results of EMS implementation
in regards to helping facilities improve environmental performance.
You can also learn more about EMS efforts by visiting web sites,
such as those that were listed in Module 3. For example, information
on the results of implementation of EMS at local governments is
included on the EPA Office of Water EMS Web Page.
Module 4, Scene 9
Terry:
Well, I wish we had more time to go into case studies, but we need
to wrap up this meeting. I strongly encourage you to check the resources
we've listed and search for more resources regarding EMS benefits,
challenges, and results. Based on all that you have heard today,
do you have any questions or comments?
Module 4, Scene 10
Clyde:
Based on our discussions today, I can see that EPA and some states
strongly support EMS. Do you think that EPA or the states eventually
will require facilities to have an EMS?
Module 4, Scene 11
Andrew:
Generally speaking, EPA supports the idea of voluntary EMS. EPA
supports and promotes the development and use of any EMS that helps
an organization achieve its environmental obligations and improve
its long-term environmental performance. However, EPA does not require
EMS implementation.
Module 4, Scene 12
Terry:
On a more business-driven note, some major corporations are requiring
that their suppliers implement EMS, or even obtain ISO 14001 registration.
At Industrious Industries, we are focusing on implementing an EMS
to remain competitive and improve our environmental performance.
Module 4, Scene 13
Clyde:
Recently, we have been approached by companies that sell EMS software.
Is a software system necessary to implement a functioning EMS?
Module 4, Scene 14
Andrew:
Well, some of those software packages can be helpful in implementing
an EMS, but they may not be necessary or appropriate for all facilities.
The chalkboard shows some things you may want to consider when considering
EMS software purchases or development.
Module 4, Scene 15
The chalkboard expands and reads:
- Some companies believe that if you have EMS software, you have an EMS. EMS is not a computer based system. It is people driven.
- A database or software system is simply a tool to assist in implementing an EMS.
- Each facility is different and software must be flexible to allow for individual implementation.
Module 4, Scene 16
Terry:
Industrious Industries has found that a well-designed software package
can help us with our EMS efforts. However, the tool is only as good
as the data it incorporates and the manner in which it is maintained
and used. In addition, you should make sure that the software has
all of the features you want for your particular EMS. That's why
Industrious Industries generally develops its own simple tracking
sheets or modifies databases we already use for production to incorporate
EMS parameters and measurement and monitoring.
Module 4, Scene 17
Nancy
Those are good points. I would recommend that you do thorough research before committing to any large purchase of an EMS software package. Depending on the size of the business and scope of the EMS, a fancy software package may not be necessary. You should get through the PLANNING phase of your EMS before making decisions about what your particular needs are.
Module 4, Scene 18
John:
Who at Industrious Industries or any other business is responsible
for making the EMS happen and who is going to do the activities
like aspects and impacts assessment and ranking, procedure writing,
and everything else to keep the cycle of continual improvement progressing?
Module 4, Scene 19
Nancy:
John, that is a critical question. The people leading and managing
EMS implementation can vary at each business. However, one factor
is the same at every organization that implements EMS - in order
for a business to have a successful EMS, each employee must be involved.
This may sound like an exaggeration, but an EMS is a cultural shift
within an organization. It takes resources, time, education, and
involvement to succeed.
Module 4, Scene 20
Terry:
That's right. Here at Industrious Industries, I am a corporate environmental
manager. My job includes making sure that facilities are in compliance
with the law. In addition, I am responsible for implementing EMS
at our plants. I work with the right people at each plant to develop
the core EMS team. But all employees are involved in some way. Finally,
I meet quarterly with the President and Board of Industrious Industries
to report on EMS progress and resulting benefits. The involvement
of corporate leadership, the EMS team, and indeed the entire company
are critical to establishing a fully functioning, high-quality EMS.
Module 4, Scene 21
Clyde:
Well, thanks for coming to our plant to learn more about EMS. I
hope all of you will continue to research EMS and consider ways
that you can apply these concepts to environmental management.
Module 4 - Benefits and Challenges of EMS - Quiz
1. True or False: A complex software system and/or databases will always be required for the effective implementation of an EMS.
- True
- False
Answer: B. False
Depending upon the size and complexity of a facility's operations, software or databases may not be necessary to implement a fully-functioning EMS. However, such tools may be useful as part of the process of implementing an EMS.
2. Which of the following may not be required to develop an EMS:
- Commitment of senior management
- Major rewriting of facility or corporate business plans
- Long-term commitment to an EMS program
- Internal resources, including staff time and provision of training
Answer: B. Major rewriting of facility or corporate business plans
Although items such as senior management commitment and use of internal resources are necessary for an effective EMS, typically major restructuring of existing business plans is not.
This is the end of the course.