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Environmental Management System Training. United States Forest Service July 6, 2004. Ed Pinero, Acting Federal Environmental Executive. EMS Implementation Workshop. An Overview of Environmental Management Systems (EMS) and the ISO Standard.

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Environmental management system training l.jpg

Environmental Management System Training

United States Forest Service

July 6, 2004

Ed Pinero, Acting Federal Environmental Executive


An overview of environmental management systems ems and the iso standard l.jpg

EMS Implementation Workshop

An Overview of Environmental Management Systems (EMS)and the ISO Standard

EMS Implementation Workshop


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WHAT IS AN ENVIRONMENTAL MANAGEMENT SYSTEM? The ISO 14001 Definition

  • “The overall management system that includes organizational structure, planning activities, responsibilities, practices, procedures, processes and resources for developing, implementing, achieving, reviewing and maintaining the environmental policy.”

EMS Implementation Workshop


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“ems” vs. “EMS”

  • All organizations have some type of environmental management system regardless of what they do

  • For this discussion, the focus is a more formalized, recognized, and structured approach defined in the international EMS standard, ISO 14001

  • In most cases, additional effort is needed to transition from existing environmental activities to the more formal ISO 14001-type EMS

EMS Implementation Workshop


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An Effective EMS is:

  • Flexible

  • Transparent

  • Useful to the “practitioner”

  • In harmony with mission focus

  • Focused on continual improvement

EMS Implementation Workshop


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EMS and ISO 14001

  • 14001 is one of the standards in the 14000 series

  • Created by International Organization for Standardization (Geneva, Switzerland)

  • Each participating nation has a committee that develops consensus and contributes (one vote each, for US it is ANSI)

EMS Implementation Workshop


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Important EMS Terms

  • “Shall”

  • “Establish and Maintain”

  • “Responsibility and Authority”

EMS Implementation Workshop


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Plan Do Check Act

Continual Improvement

Management

Review

Environmental

Policy

Planning

Checking & Corrective Action

Implementation &

Control

EMS Implementation Workshop


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Planning

Determine

Identify

Environmental

Significant

Develop

Aspects and

Impacts

Environmental

Aspects

Establish

Identify

Environmental

Activities,

Objectives

Products

and

Management

Targets

and

Services

Program

DetermineLegal and Other

Requirements

EMS Implementation Workshop


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Environmental Aspects and Impacts-ISO 14001 Definition

ENVIRONMENTAL ASPECTS

Elements of an organization’s activities, products or services which can interact with the environment. (For example: wastewater discharges, air emissions, resource consumption, energy usage, ecosystem alterations, etc.)

ENVIRONMENTAL IMPACTS

Any change to the environment, whether adverse or beneficial, wholly or partly resulting from an organization’s activities, products, or services(based on the aspects, for example: air emissions impacts the air by degrading the air quality).

EMS Implementation Workshop


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Implementation and Operation

Capabilities &

Organization &

Controls

Accountability

Communications

Document Control

Training,

Awareness and

Competence

Operational Control

Structure and

Responsibility

Communication

Emergency

Preparedness and

Response

EMS Implementation Workshop


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Checking and Corrective Action

Non-conformance,

Monitoring and

Corrective and

Measuring

Records

Preventive Action

Periodic Internal EMS Audits

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Management Review

  • To Assess the

  • suitability,

  • adequacy, and

  • effectiveness of the EMS

  • Take account of:

  • audit findings

  • progress records on objectives

  • changes to facilities

  • changes in activities, products or services

  • changes in technology

  • concerns of interested parties

  • other relevant information

  • In order to determine the need for change and improvement to:

  • the environmental policy

  • the objectives and targets

  • other elements of the EMS

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Plan Do Check Act

Continual Improvement

Environmental

Policy

Management

Review

Planning

Checking & Corrective Action

Implementation &

Control

EMS Implementation Workshop


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Keep in mind…

  • The EMS and related measurement tools are just that, tools. Alone, they will not guarantee success. The organization must use the tools, not just have them.

  • An effective EMS is “alive”; constantly measuring performance, making adjustments, and looking for opportunities for continual improvement

  • Accountability is critical

EMS Implementation Workshop


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EMS Implementation Workshop

Why Implement an Environmental Management System?


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The Drivers - Why EMS?History/perspective

  • EMS responded to “root causes” for poor environmental program management and compliance problems

  • EMS has corollary benefits of management systems to mission and environmental stewardship

  • EMS represents the next step in evolution from compliance, to pollution prevention (for compliance), to EMS

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EO 13148

  • Establishes EMS as environmental management policy for the Federal government

  • Requires agencies to incorporate EMS into agency environmental directives and policies

  • Requires facilities to develop and implement EMS by December 31, 2005

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What an EMS is

  • A formal, structured framework of policies, procedures and practices to manage and reduce an organization’s environmental footprint

  • Based on a PLAN-DO-CHECK-ACT framework

  • An approach that reflects the relationship between environmental issues and core mission

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What an EMS is NOT

  • A one-time project, plan or initiative

  • Focused solely on regulatory compliance

  • An effort solely for the environmental shop

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Benefits of an EMS

  • Improved environmental awareness, involvement and competency across organization

  • Better communication of environmental issues - internal and external

  • Positive effect on regulatory compliance and environmental performance

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Benefits of an EMS

  • Improved efficiency, reduced costs, greater consistency in environmental program

  • Flexibility and opportunity to correct imperfections through “continual improvement”

  • Identification of risk and prevention of problems outside of regulatory - e.g., aging infrastructure, known unregulated hazards

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Barriers - What stands in the way of EMS?

  • Organizational change - natural resistance to change in any organization

  • Lack of top management involvement and visibility

  • Organizational issues - “that’s an environmental responsibility”

  • “That’s my responsibility” from the environmental shop

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Potential Barriers

  • small p and BIG P political uncertainty - is EMS here to stay?

  • Perception that EMS already exists - systems exist now, why change?

  • Misunderstanding of relationship to mission “environment only gets in the way of mission”

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The Three C’s of an Effective EMS

Conformance

Meets the requirements (Implements the “shalls”)

Consistency

Various elements inter-related (i.e., Significant aspects reflected in emergency planning, etc.)

Continual improvement

Mechanisms are in place to improve the EMS and organizational performance, supported by management commitment and support

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Keep in mind - AN EMS

  • Is a management system -

    • THAT’S WHAT MAKES IT WORK!!

  • Is more than compliance - includes safety, energy, water etc. and non-regulated impacts

  • Supports mission!

  • Takes time - it is a process, not an event

  • Requires the environmental people to get out of their box -

  • EMS requires commitment - its not a part-time job!

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Using Measurement as a Management Tool

  • Knowing existing conditions allows informed management decisions.

  • An EMS identifies, directs and facilitates relevant measurements.

  • Measurements include environmental conditions, status of programs, compliance, and the EMS itself.

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Examples of Metrics to Measure Benefits

  • Improves the environmental condition (environmental indicators)

  • Facilitates meeting your mission (how often environmental issues interfere with your mission)

  • Minimizes accidents and problems (incidents, losses)

  • Reduces redundant paperwork (time spent per task)

  • More efficient use of resources (investment per unit activity)

  • Facilitates compliance with requirements (number of non-compliances, penalty costs, missed EO deadlines)

  • Responds to public scrutiny trends (complaints, communications)

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Managing Aspects vs. Impacts

  • It is more prudent and more efficient to manage “how” you interact with the environment than to manage “what” you have done to the environment

  • An EMS is built around identifying, prioritizing, controlling, and improving upon, those elements of the organization that interact with the environment

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Fixing the Root Causes

  • An EMS is designed to identify the root causes of non-conformances and initiate corrective and preventive action.

  • This helps minimize the “bandage” syndrome, where the fixes are simply superficial.

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Achieving and Maintaining Compliance

There is “compliance management system” embedded within the broader “environmental management system”

  • First- the theme of compliance is seen throughout the plan-do-check-act elements

  • Second, there are specific compliance-related requirements in an EMS (such as periodic compliance audits) that help address compliance issues before they occur.

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Supporting Mission

  • An EMS identifies and addresses environmental issues that can hamper mission through emergencies or non-compliance

  • The EMS perspective identifies opportunities that ultimately support mission through increased efficiency

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Connecting the Environment and the Process Owners

  • An EMS helps each member of the organization understand their role in the environment, and to see how their role at the facility impacts the environment

  • An EMS provides for responsibility, ownership, and accountability of actions and related impacts

  • Results? People that are more aware, better trained, more motivated, and more enthusiastic

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Connecting the Organization With the Public

  • An EMS allows an organization to identify issues which may become a concern to the public

  • An EMS indicates to the public that an organization is aware and responding to environmental issues

  • An EMS provides a forum for discussion and reaction to environmental interests of the public

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EMS Implementation Workshop

Selecting and Preparing the EMS Team


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Function of the Team

  • Conduct the gap analysis

    • Gather and analyze existing data

    • Identify needs

    • Develop implementation plan

  • Initiate early stages of EMS

    • Policy, Aspects/Impacts, Objectives/Targets Environmental Management Program

  • Monitor implementation of EMS

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Responsibilities of the Team

  • Collect input and information from employees and Management

  • Educate members of the organization or facility on the EMS

    • Awareness training

    • Activity specific training

  • Brief and advise Management

  • Interact with local community

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Knowledge and Skills

All

  • EMS knowledge and understanding

  • Enthusiasm and energy

  • Organizational / (p)olitical savvy

    Specialists

  • Communication skills

  • Project management skills

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The Team Members

  • Keep numbers manageable

  • Strong leadership

    • Known ability to communicate with management

    • Good people skills

    • Best leadership may be outside of environmental shop

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Team Members

  • Broad base - Include resource (budget) personnel, facilities, representative process owners, on- site contractors, management representative

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Process

  • Get commitment and authority to act

  • Find appropriate members

  • Provide initial background information of EMS

  • Get commitment from Team

  • Get fully trained

  • Consider consultants help

  • Keep management apprised of progress

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Level of Effort

  • Leverage existing resources - budget/ planning cycles etc.

  • Depend on Team champions

  • Don’t underestimate effort needed and ensure commitment is there

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EMS Implementation Workshop

Defining Your Fenceline: What is the scope of an EMS?


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EMS Fenceline

  • Link to aspects - “can control” or are “expected to have an influence”

  • Define the scope of your EMS -alternatives

    • Use physical boundaries of facility

    • Reflect existing management systems

    • Reflect organizational structure

EMS Implementation Workshop


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EMS “Boundaries”

  • Geographic fenceline or boundary

    • Consider where activities primarily occur

    • Reflect of top management control

  • Management boundaries previously established

    • Existing management plans or systems

  • Corporate boundaries

    • Reflect existing management structure

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Don’t forget to consider!

  • Non mission activities

    • Visitor and personnel support, housing, food service, recreation

  • Contractors and services

  • Geographically separate areas

  • Local governments and neighbors

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Use caution:

  • Don’t artificially exclude processes that you clearly control but are “unmanageable”

  • Don’t artificially exclude something because you believe you can’t control it organizationally

  • Contracted processes are still within your control - they can’t be excluded

EMS Implementation Workshop


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Questions to ask

  • Are all organizations associated with activities, products, and services included?

  • Will the boundary include process owners and those with authority to improve processes?

  • Is there management control available for the selected boundary?

  • Is primary mission covered?

EMS Implementation Workshop


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EMS Implementation Workshop

Gap Analysis and Implementation Plans


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Gap Analysis

  • A gap analysis is an assessment process used to compare the current state of your facility’s EMS against a standard. It is not an audit; you cannot “fail” a gap analysis

  • Other similar processes are “Initial Environmental Reviews (IERs)” or “Environmental Management Reviews (EMRs).”

EMS Implementation Workshop


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Purpose of a Gap Analysis

  • To identify gaps between your current management systems and the EMS standard

  • To identify existing policies, procedures, programs, metrics, and personnel that can be part of the EMS

  • To assist in establishing a list of actions to achieve the desired EMS

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Conducting a Gap Analysis

  • Use tool or checklist that identifies requirements

  • Analysts must be familiar with EMS framework and site activities

  • Allow several days to complete data collection

  • Prepare a summary report that explains what the gaps are and what must be done to fill them

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Steps in a Gap Analysis

  • Facility walk-through

  • Document review

  • Staff interviews

  • Compare with desired EMS elements

  • Identify and document gaps (be specific, yes or no answers are not helpful)

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Developing the Implementation Plan

  • Uses the Gap Analysis findings

  • Intended to logically plan for the implementation

  • Requires assessing what needs to be done, and assigning time frames, resource needs, and milestones to do so

  • Provides a tool to ensure management commitment and “staying the course”

EMS Implementation Workshop


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Planning the Level of Effort

  • Estimate level of effort based on gap analysis

  • Leverage existing resources

  • Don’t underestimate!

  • Obtain management commitment for implementation early

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ISO 14001 Policy Statement Requirements

  • Be appropriate to the nature, scale and environmental impacts of the organization’s activities, products and services

  • Provides framework for setting objectives and targets

  • Be documented, implemented, maintained and communicated to all employees

  • Include a commitment to:

    • Continual improvement

    • Prevention of pollution

    • Compliance with environmental regulations and other requirements to which the organization subscribes

  • Be available to the public

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Policy Statement Importance

  • Is the foundation of the EMS

  • Demonstrates management commitment

  • Communicates the “environmental culture and commitments” of the organization

  • Gives the entire organization a statement to rally around

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Timing the Policy Statement

Policy statement may not be first step:

  • Review your agency’s current environmentally-related policy for adaptability

  • Determine level of awareness of EMS with senior managers and level of understanding of importance of the policy

  • Make a case for EMS first

  • Use initial EMS development information to help formulate policy

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Writing the EMS Policy Statement

  • Is a short, concise statement that includes the requirements as well as additional information to meet stakeholder expectations

  • Does not need to summarize or repeat EMS details

  • Signed by senior-most management within the defined EMS scope

  • Is consistent with EMS framework and aspects

  • Needs to be “ memorable” to staff

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EMS Implementation Workshop

Legal and Other Requirements


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RCRA

CAA

CWA

SDWA

CERCLA

EPCRA

NEPA

OSHA

Pollution Prevention Act

Examples of Legal Requirements

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Unique to Federal Community

Executive Orders and Memoranda

Parent Agency Policies

Voluntary programs

Performance Track

LEED Certification

Energy Star facility

Examples of “Other” Requirements

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Identify - Initial materials should be in place

  • Identify existing permits, licenses, reports

  • Use compliance programs of parent agency or service

    • Agency general counsel and legal advisors

  • TEAM guide

  • On line tools

  • Compliance assistance materials -documents

EMS Implementation Workshop


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Providing Access and Maintaining

  • Ensure easy access

    • Hardcopy, web access, database

  • Identify and support process to receive and include updates

    • Headquarters audit programs and other tools including tools used by other agencies

    • TEAM guide

    • WEB sites and listserves

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Access

  • Ensures there is a process that keeps regulatory and other information up-to-date

  • Ensures that there is a process to direct any new information to that part of the organization where it is relevant

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Process - When things change

  • Remember - when aspects change, legal and other requirements need to be checked!

  • Recognize relationship between aspects, activities and legal or other requirements

  • Recognize relationship between regulated activity process owners and requirements

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EMS Implementation Workshop

Aspects, Impacts, and Significant Aspects


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Specific Benefits

  • Prompts your organization to identify issues not typically managed; particularly non-regulated issues

  • Integrates environmental issues into operations

  • Makes for proactive planning

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Environmental Aspects and Impacts-ISO 14001 Definition

ENVIRONMENTAL ASPECTS

Elements of an organization’s activities, products or services which can interact with the environment. (For example: wastewater discharges, air emissions, resource consumption, energy usage, ecosystem alterations, etc.)

ENVIRONMENTAL IMPACTS

Any change to the environment, whether adverse or beneficial, wholly or partly resulting from an organization’s activities, products, or services (based on the aspects, for example: air emissions impacts the air by degrading the air quality).

EMS Implementation Workshop


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ISO 14001 requires organizations to:

  • Develop procedures to identify environmental aspects in order to determine those which have or can have significant impact on the environment

  • Keep aspects information up-to-date (regularly, and whenever changes occur), not once and done.

  • Necessary records will include aspects lists, and significant aspects list

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Role of Aspects in the EMS

  • Significant aspects drive the EMS and are a subset of the full list of aspects

  • EMS is designed to identify, control, manage, and improve upon the significant aspects

  • Compliance with Legal and Other Requirements is a part of the system that does relate to the aspects

  • Elements such as operational control (procedures and work instructions), training, monitoring and measurement, emergency planning, and setting objectives all depend on significant aspects.

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More on Environmental Aspects

  • Aspects are “cause”, impact is the “effect”

  • Control and influence of aspects is a factor

  • Aspects can be:

    • direct or indirect

    • normal, abnormal, or emergency

    • past, present, or future

  • Aspects address not only waste stream, but resource consumption, energy, and other “non-traditional” factors (noise, odor, visual)

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Going About the Aspects Process

  • Identify who and how this will be done (aspects procedure)

  • List and characterize activities, products services

  • Identify aspects and impacts for each A/P/S -Tap into your knowledge base!

  • Determine significance

  • Maintain records

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Activities, Products and Services

  • This is where you describe what you do at your facility – mostly “activities” for Feds

    • Consider mission – what ‘facility’ is designed to do - e.g. visitor center

    • Consider activities that support the mission – e.g. vehicle maintenance

    • Consider actions that are both regulated and not regulated e.g. commuting to work

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Aspect Analysis - Examples of Activities

  • Mission related operations

  • Maintenance

  • Motor vehicle fleet operations

  • Wastewater treatment

  • Solid waste handling and disposal

  • Raw material and chemical handling

  • Bulk storage of fuels

  • Administrative and employee activities

  • Engineering

  • Purchasing

EMS Implementation Workshop


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List Aspects

  • Can sort and organize aspects, for example:

    • Releases to air

    • Water consumption, pollution

    • Land contamination

    • Use of raw materials, natural resources

    • Other local environmental, community issues

  • Will be able to “re-sort” later to better manage the aspects

EMS Implementation Workshop


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Aspect:

Waste generation

Material usage

Fuel usage

Air emissions

Chemical consumption

Energy consumption

Not an aspect:

Improve air quality – this is an objective

P2 – this is an objective

Vehicle maintenance – this is an activity

Water pollution – this is an impact

Examples of Aspects

EMS Implementation Workshop


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Activity, Product, or Service

Aircraft operations

Bus transportation and maintenance

Environmental Aspect

Jet fuel consumption

Jet fuel releases (potential)

Noise generation

Gasoline consumption

Electricity consumption

Solid waste generation

Water consumption

Waste water generation

Examples

EMS Implementation Workshop


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Activity, Product, or Service

Vehicle maintenance

Environmental Aspect

Hazardous waste generation

Gasoline consumption

Noise generation

Electricity consumption

Solid waste generation

Water consumption

Waste water generation

Release of volatiles

Examples

EMS Implementation Workshop


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Activity, Product, or Service

Store

Cafeteria

Environmental Aspect

Raw material consumption

Fuel consumption for transport

Solid waste generation

Food waste generation

Electricity consumption

Water consumption

Waste water generation

Release of ammonia from refrigeration equipment (potential)

Examples


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Activity, Product, or Service

Office work

Environmental Aspect

Electricity consumption

Water consumption

Waste water generation

Release of ozone depleting substances in air cooling units (potential)

Solid waste generation

Heavy metals “use” in computers

Examples

EMS Implementation Workshop


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Activity, Product, or Service

Cleaning offices

Playing field upkeep (golf course, softball field, parade ground)

Environmental Aspect

Hazardous material release

Electricity consumption

Solid waste generation

Waste water generation

Water consumption

Waste water generation

Runoff from pesticide usage

Gasoline consumption

Grass clipping generation

Examples

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Identify the Impacts of Aspects

  • Once the aspects are identified, you must identify the impact(s) associated with each one.

  • This can be done using the same process you used for aspects, except there might be more involvement of environmental staff to assess impacts

  • List impacts along with aspects

EMS Implementation Workshop


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Air emissions (exhaust)

Water consumption

Fuel release (accidental spills)

Fuel release (accidental spills)

Noise generation

Energy consumption (lights left on)

Paper recycled

Air quality degraded

Water resource depleted

Storm water contaminated

Soil contaminated

Area nuisance

Increased CO2 from coal-fired power plant emissions

Landfill space conserved, raw materials conserved

Examples of Aspects & Impacts

AspectsImpacts

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Determine Significant Aspects

  • A significant aspect is one that has or can have a significant impact on the environment (you define)

  • Site selects the criteria for significance rating and cutoff value

  • Significance can be determined by numeric cutoff value or subjective assessment based on yes/no answers

  • Significance could be tied to: environmental degradation concerns, natural resource concerns, regulatory or legal exposure, concerns of interested parties

EMS Implementation Workshop


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EMS Requirements

  • ISO 14001 uses “significant” aspects and impacts as the basis for developing objectives and preparing programs.

  • The organization chooses which aspects are “significant,” based on applying their own criteria, to the related impacts. However, once significant, the EMS must address the aspect.

  • Process and criteria for significance described in procedure.

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Many Methods for Determining Significance Criteria

  • Staff judgment

  • Risk Assessment

  • Organizationally-derived criteria and/or hybrid approaches based on staff judgment and risk assessment

  • Key is to be consistent, and in line with “reality check” – are you capturing what makes sense?

  • Criteria must relate to environmental impact

EMS Implementation Workshop


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Examples of Significance Criteria

  • Magnitude - How big of a problem is it?

    • Global, regional, local?

  • Severity - How bad will it get?

  • Probability - How likely is it to occur?

    • Daily, weekly, monthly, annually, in emergencies, only when a certain event happens, when a new project starts?

  • Regulated?

  • Of concern to interested parties?

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Applying the Criteria

  • Each aspect must be evaluated in terms of the criteria

  • Significant ones listed

  • Each time a new aspect enters the system for whatever reason, it must be evaluated for significance

  • ALL significant aspects must be carried forward into the system

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Identify

Aspects

Significant?

no

Remains on

aspect list

yes

Significant

aspect

No, or yes

but want to

do more?

Objectives and

targets

Under

Control?

Operation

controls

yes

Address

now?

No (still must have controls)

Yes

EMPs, and

Operational

Control

Deployed

in EMS


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EMS Implementation Workshop

Setting Objectives and Targets

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Definition

An EMS objective is an overall goal that reflects the environmental policy statement set by the organization.

An EMS target is a detailed, measurable performance metric related to the objective.

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Examples

Objective: Reduce use of hazardous chemicals

Target: Reduce use of EPA listed Toxic Release Inventory chemicals by 5% annually based on calendar year 2001 use figures

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Examples

Objective: Reduce energy consumption

Target: Reduce energy consumption by 25% by the year 2005 based on a 2000 calendar year baseline.

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Examples

Objective: Improve environmental compliance

Target: Reduce the number of internal environmental compliance audit findings by 50% on an audit-to-audit basis.

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Examples

Objective: Reduce transportation congestion

Target: Increase the number of employee-days of mass transit use by 50% by the year 2006 based on a 2002 calendar year baseline.

Target: Purchase 25 bicycles for use within the facility by the year 2004.

EMS Implementation Workshop


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ISO: Organizations Shall Consider

  • Policy

  • Legal and other requirements

  • Significant environmental aspects

  • Technological options

  • Financial, operational and business requirements

  • Views of interested parties

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Setting Objectives and Targets

  • Begins with initial planning data

    • Policy

    • Legal and other requirements

    • Significant environmental aspects

  • Consider

    • Technological options

    • Financial, operational and business requirements

    • Views of interested parties

EMS Implementation Workshop


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Setting Objectives and Targets

  • Other drivers for consideration

    • Agency mission

    • Agency / management priorities

  • This is where you can reflect “reality”

    • What can be done

  • You will do this again

EMS Implementation Workshop


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Setting Objectives and Targets

  • Some organizations set compliance as an objective to help remind them that the remainder of the system reflects that commitment

  • Significant aspects can be deferred if they are controlled and get no worse because of their deferral

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Targets - How aggressive?

  • It depends:

    • Stretch targets - you may not meet them but trying may get you further

    • Minimal targets - you will get there - likely to only maintain status quo - little improvement

  • Be Realistic: you may need additional info to address ability to measure success towards objective

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REMEMBER

  • Setting objectives and targets must be true to policy statement commitments - pollution prevention, continual improvement and particularly compliance with regulations, are not negotiable considerations

  • Objectives and targets drive your management plan

  • You will do this exercise again and again ...

EMS Implementation Workshop


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Setting objectives and targets; the process

  • Prepare summary of issues to be considered

    • community concerns

    • agency/ management priorities

    • cost data

    • future missions of facility or agency

  • Provide informationto decision makers

EMS Implementation Workshop


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Considerations

  • Use what will work best but keep in mind:

    • You will need buy-in from management AND the organization

    • The objectives and targets selected will be the basis for the environmental management program for this cycle

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Closing the Loop

  • Objectives and Targets must ultimately be established at each relevant function and level of the organization

  • Targets identify how progress will be measured

EMS Implementation Workshop


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EMS Implementation Workshop

The Environmental Management Program

EMS Implementation Workshop


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Environmental Management Program

The Management Program defines how the Objectives and Targets are to be achieved - including:

  • Assignment of responsibility at each relevant function and level - the who

  • Description of means - the how and what

  • Identification of time frame - the when

EMS Implementation Workshop


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Assignment of Responsibility:

  • Function

    • Reflects relationship between activity and impact - ensures that impact is addressed where it occurs

    • Reflects support structure to ensure program is enabled - procurement, budget, training

EMS Implementation Workshop


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Assignment of Responsibility:

  • Level

    • Ensures that program reflects and recognizes hierarchy and structure of the organization

    • Reflects necessity of accountability - Organizational levels above direct process are generally supervisory and management and must be engaged

EMS Implementation Workshop


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Identification of Means

  • The “how” an organization intends to achieve a given objective and target

    • Will reflect the activity(ies) that has prompted the “significance” and Objective and Target determination

    • Will define what is to be done to manage and improve processes to address the ongoing or potential impact of the activity

EMS Implementation Workshop


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Definition of Time-frame

  • Simply the schedule for addressing the objective and target

    • Should reflect temporal nature of activities prompting target - how soon can things be altered

    • Recognize the ability to address both short and long-term issues as well as ongoing responsibilities

EMS Implementation Workshop


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Example

Objective: Increase solid waste diversion

Target: Increase to a 60% diversion rate for all solid waste by the year 2005 based on a 40% diversion rate in 1996.

EMS Implementation Workshop


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EMP - Example

EMP - Increase recycling at cafeteria

Function - Cafeteria tray handlers, cafeteria purchasing agent, facility solid waste handler

Level - In addition to above - cafeteria line supervisor and manager, budget officer, and facilities manager

EMS Implementation Workshop


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EMP - Example

Means - Purchase more recyclable containers, post signs and improve disposal behavior - separate and recycle more cans and bottles

Time-frame - Starting next purchasing cycle and targeting to reach 10% annual reduction

EMS Implementation Workshop


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EMP - the Process

  • Begin with Objective and Target and activities list that drives significance determination

  • Determine necessary changes to activity to address impact and draft a means to achieve

  • Determine who is directly and indirectly linked to the impact - who are the process owners?

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EMP - the Process

  • Determine others that affect or enable the process or activity - identify their roles and how the organizational structure provides accountability

  • Determine factors affecting time-frame for the activity or process and factors that may control changes

EMS Implementation Workshop


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EMP - the Process

  • Develop metrics that reflect target to allow “checking”

  • Develop program ensuring that individuals critical to implementing change are included

  • Review information to identify gaps - ensure connections between means, responsibilities and schedule are each identified and addressed

EMS Implementation Workshop


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New Developments

  • The EMP must be established and maintained.

    • Changes in activities or other new developments that affect Objective and Targets must be reflected in the EMP

    • Since aspects must be kept up-to-date - changes will flow to EMP

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EMP Implementation

  • EMP may be stand alone or integrated into existing planning processes

    • Important to ensure that wherever it lands it will be effective

    • Important that those responsible for implementation are aware of ensuing change

  • Ensure that Management embraces the EMP!

EMS Implementation Workshop


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EMS Implementation Workshop

Initial Awareness Training


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Why EMS Awareness Training

  • The initial stages of the EMS depend on individuals within the organization

    • The EMS Team will include a range of representatives from within the organization

    • Information gathering will depend in part on contributions from across the organization

    • Something new - people need to know

  • Knowledge and understanding build ownership

EMS Implementation Workshop


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Why Employee Awareness?

  • The EMS is deployed by the practitioners

    • Practitioners are more aware of the day-to-day impacts of their activities than anyone

    • Practitioners know the best improvements

  • Ultimately, the Standard requires awareness of the impacts of the organization’s activities

    • Start the process

EMS Implementation Workshop


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Awareness TrainingProcess

  • Process similar to obtaining management support

    • Recognize issues important to all entities within the organization

      • Mission

      • Improved health, safety and security

      • Improved efficiency

      • Improved environmental footprint

  • Don’t overwhelm

EMS Implementation Workshop


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Awareness TrainingProcess

  • Timing - Early enough to facilitate gap analysis and other early stages of EMS

  • Support - Ensure adequate management support - authority and responsibility

  • Message - Like Management, reflect issues of importance to audience

  • Presenter(s) - Ensure adequate knowledge of EMS elements

EMS Implementation Workshop


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Awareness TrainingProcess

  • Keep it simple

  • Goals is to inform and solicit assistance

  • Use familiar tools

    • Email

    • Cafeteria notices

    • Managers briefings

  • Remember - this is the initial effort

EMS Implementation Workshop



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Environmental Management System Audit

A systematic and documented verification process of objectively obtaining and evaluating evidence to determine whether an organization’s environmental management system conforms to the environmental management system audit criteria set by the organization, and for communication of the results of this process to management.

EMS Implementation Workshop


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EMS Audits

  • Purpose of an EMS Audit

    • Does the system conform to set criteria?

    • Has EMS been properly implemented, maintained?

    • Provide information to management and organization to allow continual improvement

  • Addresses all of EMS (documentation and implementation)

  • Not a performance audit or a compliance audit

EMS Implementation Workshop


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Purpose of an EMS Audit

  • Evaluates conformance of EMS to framework, policy commitments

  • Addresses management components

  • Doesn’t explicitly address compliance

  • Includes all personnel and activities associated with significant impacts

EMS Implementation Workshop


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What do you need to do?

  • Develop audit procedure(s) and programs that describe the “when, how, who, and where” of how the EMS auditing will be done

  • Conduct audits

  • Keep proper records

  • Feed audit information into rest of EMS

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Audit Outcomes

  • Assessment tool to provide for corrective action and continual improvement of system- which leads to improved performance

  • Report to management

EMS Implementation Workshop


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EMS Implementation Workshop

Management Review


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Management Review

  • Specific requirement of ISO 14001; to occur periodically and must include top management

  • Distinct from checking or EMS audit

  • Designed to ensure ongoing and practical involvement by top management

  • Essential part of management commitment and continual improvement

EMS Implementation Workshop


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Management Review Components

  • Full system overview

  • Status of objectives and targets

  • EMS Performance

  • Audit findings

  • Evaluation of environmental policy

EMS Implementation Workshop


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Towards Continual Improvement

  • Identify areas for improvement of EMS

  • Review and approve corrective or preventive action plan

  • Verify effectiveness of action plans

  • Make changes to procedures

  • Add or adjust Objectives and Targets

  • Revise Environmental Policy

  • Provide support and resources

EMS Implementation Workshop


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Ensuring Effective Management Reviews

  • Develop a procedure and schedule; with set agenda, sign in process, minutes, and follow up action items

  • Make sure top management attends

  • Keep good records

  • Ensure you follow up!!!!!!

EMS Implementation Workshop


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EMS Implementation Workshop

Synchronizing Planning with the Other Elements

Deploying the EMS


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Plan Do Check Act

Continual Improvement

Management

Review

Environmental

Policy

Planning

Checking & Corrective Action

Implementation &

Control

EMS Implementation Workshop


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Implementation and Operation

Capabilities &

Organization &

Controls

Accountability

Communications

Document Control

Training,

Awareness and

Competence

Operational Control

Structure and

Responsibility

Communication

Emergency

Preparedness and

Response

EMS Implementation Workshop


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Implementation and Operation

  • Structure and responsibility - define general responsibility

  • Training, awareness and competence - train to policy, environmental impacts

  • Communication - inform relative to aspects and the EMS

  • EMS Documentation - develop, maintain and provide access to core directions

EMS Implementation Workshop


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Implementation and Operation

  • Operational control - provide standard direction to address impacts and goals

  • Emergency preparedness and response -provide direction to address extraordinary situations

EMS Implementation Workshop


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Checking and Corrective Action

Non-conformance,

Monitoring and

Corrective and

Measuring

Records

Preventive Action

Periodic Internal EMS Audits

EMS Implementation Workshop


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Checking and Corrective Action

  • Monitoring and measurement - determine if the EMS is working, goals are being met and compliance is assured

  • Non-conformance - define responsibility for addressing issues raised from monitoring and measurement

  • Records - develop and maintain body of knowledge from EMS

EMS Implementation Workshop


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Checking and Corrective Action

  • EMS audit - determine if EMS is properly developed and deployed

EMS Implementation Workshop


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Management Review

  • To Assess the

  • suitability,

  • adequacy, and

  • effectiveness of the EMS

  • Take account of:

  • audit findings

  • progress records on objectives

  • changes to facilities

  • changes in activities, products or services

  • changes in technology

  • concerns of interested parties

  • other relevant information

  • In order to determine the need for change and improvement to:

  • the environmental policy

  • the objectives and targets

  • other elements of the EMS

EMS Implementation Workshop


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EMS Implementation Workshop

EMS Conformance Auditing


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Environmental Management System

The part of the overall management system that includes organizational structure, planning activities, responsibilities, practices, procedure, processes and resources for developing, implementing, achieving, reviewing and maintaining the environmental policy.

EMS Implementation Workshop


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Environmental Management System Audit

A systematic and documented verification process of objectively obtaining and evaluating evidence to determine whether an organization’s environmental management system conforms to the environmental management system audit criteria set by the organization, and for communication of the results of this process to management.

EMS Implementation Workshop


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EMS Audit

  • Not a compliance audit

  • Done by those with EMS auditing training/experience

  • Periodic “snap-shot” assessment to verify system

EMS Implementation Workshop


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Internal vs. External Audits

  • Internal audits (First Party audits) are those done by participants of the EMS being audited (can be employees, or consultants as agents of the organization)

  • Second party audits are those done by auditors from outside the EMS in question (but could be from same organization)

  • Third party audits are done by independent, registrars

  • In all cases, audit should cover same elements!!!!

EMS Implementation Workshop


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Certification vs. Self Declaration

  • In both cases, a representation is made to outside parties of conformance to EMS criteria.

  • Certification is done by accredited, third party registrars

  • Self-Declaration is any other claim of conformance other than certification

  • Self-Declaration should be more than internal EMS audit

EMS Implementation Workshop


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EMS Auditing and ISO

  • ISO created companion auditing guidance standards (14010, 14011, 14012 (soon to be 19011), but these are not required for certification

  • Registrars must adhere to these at a minimum

  • ISO issues guidance to certification and accreditation bodies (but can be used to guide self declaration programs)

  • US accrediting body is ANSI-RAB

EMS Implementation Workshop


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EMS vs. Compliance vs. EMR Auditing

  • Different criteria- EMS looks at system, compliance looks at regulatory requirements

  • EMS audit is a system, or process audit, a compliance audit looks at compliance performance (compliance status), EMR looks at pieces of the system or a very broad perspective

EMS Implementation Workshop


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Self Declaration and EO 13148

  • Protocol developed by EO Workgroup

  • EMS verification procedures will rest with each Agency/Bureau

    • Procedures due by December 31, 2004

    • Updated at least every five years

  • Procedures will require an independent basis

  • Facilities may self declare prior to procedures using protocol guidance

EMS Implementation Workshop


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Agency Self Declaration Procedures

  • Will include

    • Selection and direction for use of evaluation guide

    • Frequency of internal evaluations

    • Requirement for management declaration

    • Frequency of independent review

    • Makeup of review team including qualifications of independent reviewers

EMS Implementation Workshop


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Resources

  • www.ofee.gov - EMS section - slides, presentations, briefing papers

  • http://p2library.nfesc.navy.mil/ems/index.html Exceptional EMS tools - including roadmap and decision assistance

  • www.epa.gov/ems General tools - Federal facility site being upgraded

EMS Implementation Workshop


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