Environmental Management Systems (EMS) for Port Tenants and Owners

1. Environmental Management Systems (EMS) for Port Tenants and Owners US Environmental Protection Agency Region 2 July 30, 2008

2. What is an Environmental Management System? a cycle of assessment in which people, policies, plans, procedures and review mechanisms are applied by an organization to achieve its established environmental objective

3. Main Elements of EMS • Fenceline • Management Buy-in • Envir Policy Statement • Legal Regulations • Aspects/Impacts • Objective/Targets • Communication • Documentation • Audits/Management Reviews

4. Cycle of Continual Improvement Management Review EMS Implementation

5. General Benefits of an EMS • Improve environmental performance • Enhance compliance • Develop new customer marketing options • Increase efficiency/reduced costs • Enhance employee morale • Improve public image • Increase employee environmental awareness

6. Management Commitment Securing this buy-in Apparent in policy • Importance • Role

7. Where is your fenceline? • Options • Zones of Control, Influence and Interest • Consider practical constraints and timing • Assignment of responsibilities • Must be documented • Examples: ‘landside’, harbor or maintenance operations

8. EMS Implementation Team • Roles and responsibilities • Management Representative vs. EMS Specialist • Members should include: upper management, operations manager, public affairs rep, health and safety officer, etc.

9. Environmental Policy • Appropriate for nature, scale & environmental impacts of activities, products or services • Commitment to continual improvement, pollution prevention & compliance • Provides a framework for setting and reviewing objectives and targets • Documented, implemented and maintained • Communicated to all employees • Available to the public

10. Legal and Other Requirements • Establish and maintain a procedure to address requirements • Identify and gain access to updates of legal and other requirements • Applies to environmental aspects of the facility

11. CAA Diesel emissions PM, VOCs from painting/repair Vessel emissions CWA Ballast, bilge water discharge Stormwater discharge SPCC EPCRA Release reporting Chemical inventories FIFRA Pesticide use RCRA Hazardous waste generation Onshore waste water tanks Underground storage tanks Bulk storage TSCA PCBs Lead paint CERCLA Development of brownfields Dredging Other Regulations OPA, OSHA, MARPOL Illustrations of Applicable Regulations

12. Environmental Aspects & Their Impacts • Environmental Aspect element of an organization's activities, products or services that could impact the environment • Environmental Impact actual or potential change to the environment due to an organization’s activities, products or services (i.e the results of an environmental aspect)

13. Factors to Consider for Determining Significance • Environmental concerns such as: • The size of the impact • The frequency of the impact • Legal and other requirements • Business concerns such as: • Feasibility and cost of changing the impact • Effect of change on other activities and processes • Concerns of interested parties

14. Port Landside Operations Activity Aspects Bulk Storage Diesel Emissions Emptying Bilges Cleaning Vessels Land Use Impacts Resource Depletion Air Pollution Water Pollution Damaged Habitats Threatened Health

16. Establishing Objective and Targets • Objective • Overall environmental goal • i.e., ‘The end journey’ • Targets • Detailed performance-based requirements • How to achieve the end journey • Factors to Consider • Relate to significant aspects & business priorities • Base on technical and financial limitations

17. Environmental Management Program (EMP) • Definition • Who • When • How

18. EMS Process Flow Environmental Policy Aspects Environmental Mgmt Program Impacts Assess Feasibility Objectives & Targets Significance

19. Operations Controls, Training & Communication Strategy • Operation controls: guidelines for procedures • ensure work is performed effectively • Training: education of stakeholders on EMS • enhances sustainability of efforts • Communication strategy: internal/external method to convey EMS policy, progess, etc. • enhances sustainability by engaging stakeholders

20. Required Documentationprovides accountability as official evidence of all EMS components • Description of the “fenceline” • Environmental policy • Objectives & targets • Formal plans (e.g., emergency response, SPCC, waste minimization, training plans) • Standard operating procedures & other non-engineering operational controls

21. Monitoring and Measurement • Allows for gauging of performance, analysis of problems • EMS implementation team selects measures, i.e., key indicators of operations and activities • Tie to objectives, targets & significant impacts • Choose carefully, then evalute and record • Example: quantity of energy/water used or waste, emissions, etc produced as measure of operational performance of a specific activity

22. EMS Audits • Environmental compliance audits • EMS gap analyses • Internal EMS audits • Not necessarily all-inclusive • Role of HQ and peer groups • Scope • Frequency • Practical recommendations

23. Corrective and Preventive Action • Resolve the immediate problem • Consider whether the same or similar problems exist elsewhere  • Prevent the problem from recurring • Define responsibilities and schedules

24. Management Review • Enhances sustainability • Allows for cost-effectiveness • Demonstrates progress made in achieving objectives and targets • Allows for continual improvement • Ensures the EMS remains dynamic and can address future needs/problems • Seeks to answer, “Is the system working (i.e., suitable, adequate and effective)?”

25. EMS Benefits at Ports • Integrates new/pre-existing environmental efforts with larger business goals • Increases sustainability, thus improving health of business, community & environment • Allows for more efficient use of financial, human and natural resources • Improves communication, internal & external • Fosters community awareness & support

26. EMS Benefits in Action

31. R2 Port EMS Contact Linda Longo, 212-637-3565 longo.linda@epa.gov