Introduction to Environmental Management Systems

1. Designing Your EMS: A USDA Workshop Introduction to Environmental Management Systems Environment International Ltd. June 14-16, 2005

2. EMS Requirements in Executive Order 13148 • Agency level EMS self assessment by October 2001 • Facility pilot EMS by April 2002 • EMS at all appropriate facilities by December 2005

3. Self Declaration • Memorandum to Agency Environmental Executives dated January 27, 2004. • Final version of protocol dated September 10, 2003. • Verify conformance with ISO 14001. • www.epa.gov/

4. What is an Environmental Management System? “The part of the overall management system that includes organizational structure, planning activities, responsibilities, practices, procedures, processes and resources for developing, implementing achieving and reviewing the environmental policy.” ISO 14001

5. An EMS is Environmental • Facilitates environmental compliance • Addresses environmental impacts • Broadens environmental responsibilities to all whose work can have a significant impact on the environment • Environmental office has technical expertise to contribute

6. An EMS is Management • Must have commitment of top managers • EMS owned by facility manager • Must be consistent with other management systems

7. An EMS is a System • Requires awareness of formal structure • Addresses policies, procedures, programs • Doesn’t specifically address compliance components (drums, labels, etc.)

8. ISO 14001 Components Continual Improvement Environmental Policy Management Review Checking & Corrective Action Planning Implementation & Control

9. Environmental Policy • Issue a policy statement signed by facility manager • At a minimum, commit to • Continual improvement • Pollution prevention • Environmental compliance • Identifies EMS framework • Publicly available

10. Planning • Identify aspects and impacts from facility activities, products, and services • Review legal requirements • Set objectives and targets • Establish formal EMS program

11. Implementation & Operation • Define roles and responsibilities • Provide EMS training • Establish internal and external communication mechanisms • Establish document control system • Establish operational controls • Integrate with or establish emergency preparedness procedures

12. Checking & Corrective Action • Conduct periodic monitoring of environmental performance • Identify root causes of findings and conduct corrective and preventive actions • Maintain environmental records • Conduct periodic EMS audit

13. Management Review • Conduct periodic senior management review of EMS • Revise parts of the EMS as needed

14. Benefits of an EMS • Help maintain compliance • Reduce operating costs • Integrate environmental programs into mission • Increase employee involvement • Reduce environmental impacts

15. Designing Your EMS: A USDA Workshop Getting Your EMS Started:Your EMS Team Environment International Ltd. June 14-16, 2005

16. Functions of the Team • Educate all organizations at facility • Conduct gap analysis • Collect input from employees, management • Plan and implement EMS • Interact with local community as needed

17. Knowledge and Skills Needed for Team • Enthusiasm and energy • Project management skills • Patience and persistence • Training expertise • Excellent communication skills • Process/systems knowledge • EMS knowledge • Political savvy • Access to top management

18. Designing Your EMS: A USDA Workshop Environmental Policy Statement Environment International Ltd.

19. How not to create your environmental policy…

20. Policy Statement Importance • Demonstrates management commitment • Defines framework for EMS • Provides framework for setting objectives and targets • Must be appropriate to activities at facility

21. Environmental Policy I C P M O R P M E R P V O L E V I N E A M T E N I N C O T E N Management Commitment ISO 14001 Requirements

22. Designing Your EMS: A USDA Workshop Gap Analysis Environment International Ltd.

23. Definition A gap analysis is a process used to assess the current state of your facility’s EMS. Other similar processes are “environmental management system reviews (EMRs).”

24. Purpose of a Gap Analysis • Identify gaps between your current management systems and the EMS standard • Collect policies, procedures, programs, metrics, and personnel that support the current EMS • Establish a list of actions to achieve conformance with the standard

25. EMS Fenceline • Factors that will define the scope of each NAA location’s EMS • Physical size of your location • Research mission of your facility • Self-supporting location versus tenant of a larger facility having its own EMS • State and municipal agencies that have environmental regulatory oversight over your location

26. Steps in a Gap Analysis • Facility walk-through (reference fenceline) • Document review • Staff interviews • Identify and document gaps

27. Facility Walk Through • Identify Activities, Products, and Services • Main reason for facility’s existence • Support activities • Develop Comprehensive Picture of Facility • Maps • Pictures • Lists of buildings and organizations

28. Document Review Examples of relevant documents: • Environmental policy statements • Other policy statements • Mission statements • SOPs • Position descriptions • Environmental plans (HW, P2, INRMP, SPCC, STORMWATER, AS-BUILT, etc) • Training materials

29. Staff Interviews • Identify organizational structure • Identify requirements to fulfill mission • Determine awareness of staff of EMS • Awareness of environmental programs and goals

30. Identify and Document Gaps • Compare with EMS elements • Make a list of specific actions to close gaps

31. Designing Your EMS: A USDA Workshop Identifying Environmental Aspectsdefined as a part of activity or product that interacts with environment Environment International Ltd. March 22-23, 2005

32. Aspects and the EMS When first developing your EMS, do a comprehensive aspects review ISO 14001 requires organizations to: • develop procedures to identify environmental aspects • keep register of aspects up-to-date

33. Building an Aspects Register • Assemble list of activities, products, and services • Characterize activities, products, and services • List aspects • Organize and rank aspects as appropriate

34. Characterizing Your Activities, Products, and Services • Interviews with research and field staff (what are they doing, are they using hazardous materials, etc.) • What are your location’s hazardous material purchases (review inventories) • Hazardous waste records • Records from emergency planning, accident reports, emergency incidents • Water and energy consumption records

35. Step 1 • Look at the Comprehensive Picture of Your Facility • Research Activities • Facility Operations Activities • Construction and Demolition Activities • Within Your “Fenceline”, Identify and List Activities • Crop research • Animal research • Use hazardous chemicals • Generate hazardous waste

36. STEP 2 • Determine if there are environmental aspects associated with each activity on your list • An environmental aspect is the part of an activity, product, or service that interacts with the environment. An aspect can be thought of as the actual or potential “cause” of an environmental impact. • Aspects can be regulated or unregulated.

37. Activity, Product, or Service Purchasing Hazardous Chemicals Environmental Aspects Depletion of natural resources in the following ways: (a) Energy utilized in chemical manufacturing; and (b) Energy requirements for chemical storage (e.g., use of electricity for low-temperature refrigeration or ventilation Generation of hazardous waste by the following activities: (a) Duplicate purchasing of hazardous chemicals already on location inventory; (b) Large-scale purchasing of unusable quantities of chemical; and, (c) Chemical is not used, resulting in chemical entering hazardous waste stream due to expired use date. Example 1

38. Activity, Product, or Service Facility Maintenance Environmental Aspects Hazardous waste generation (spent fluorescent lamps, PCB containing lamp ballasts, spent solvents, paints) Generation of asbestos-containing waste Generation of universal waste (used oils, mercury-containing equipment) Ozone depletion (repair of older refrigeration equipment containing ozone depleting refrigerants) Generation of solid waste (excess furniture and equipment) Release of volatiles Example 2

39. 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 Example 3

40. Activity, Product, or Service Office work Environmental Aspect Electricity consumption Water consumption Waste water generation Release of ozone depleting substances in air cooling units Solid waste generation Disposal of toxics from computer toner, etc. Example 4

41. Step 3 • A significant environmental aspect is an environmental aspect that has or can have a significant environmental impact. • Significance could be tied to: • Environmental concerns • Natural resource concerns • Regulatory or legal exposure • Business or mission concerns • Concerns of interested parties

42. Factors That May Play a Rolein Managing Aspects • Size, severity and duration of environmental impact • Ease of improvement • Regulatory or Executive Order requirement • Cost • Mission impact • Community impact • Sustainability

43. Designing Your EMS: A USDA Workshop From Aspects to Impacts Environment International Ltd. March 22-23, 2005

44. Definition An environmental impact is a change to the environment, either adverse or beneficial, wholly or partially resulting from an organization’s activities, products, or services.

45. Potential Aspect Impact Cause EffectProcess OutcomeVerb Noun

46. Vehicles emit exhaust Water leaks Fuel spills occur Spills happen from containers Lights, computers are left on when not in use Paper is bleached w/Cl2 Bicycles used, not cars Air pollution Water resource depleted Stormwater contaminated Chemical contamination of soil, water Air pollution and use of resources Dioxins in wastewater Less air pollution Examples of Aspects & Impacts ASPECTSIMPACTS

47. EMS and Impacts • Use the aspects register to identify impacts • EMS addresses significant aspects • Document your process for identifying aspects and impacts • Add impacts to the aspects register

48. Designing Your EMS: A USDA Workshop Legal and Other Requirements Environment International Ltd.

49. RCRA CAA CWA SDWA CERCLA ESA Natural and Cultural Resource regulations EOs NEPA EPCRA OSHA Pollution Prevention Act OPA Energy Policy Act Historical Preservation regulations FIFRA TSCA Potential Environmental Legal Requirements

50. EMS and Environmental Compliance • Commitment to compliance is a key part of an EMS • Achieve compliance through application of source reduction techniques • Use EMS to direct resources to source reduction projects that address compliance issues