THE QUALITY ASSURANCE JOURNAL, VOL.

2, 61–67 (1997)

Application of an Environmental
Management System (EMS) based on
the Guidelines established by the
International Organization for
Standardization (ISO) in ISO 14001 to
an Academic Research Facility in
Australia

This article represents an approach for The implementation of an EMS to the

dealing with the environmental impacts
that are associated with the daily
activities of a research facility in
Australia. The principles that were
observed in this regard followed the
guidelines established in the AS/NZ
standard ISO 14001 (1996) for the
development of an Environmental
Management System (EMS) (1).
laboratory facility was not as
straightforward as was previously
thought. Different means in achieving
the requirements of the EMS were
considered before setting up an interim
system. Some of the major setbacks
faced in the development of an
environmentally friendly premises, where
the daily activities have the lowest
possible impact on the environment, are
outlined.

The aim of this paper is to reflect the

Christian Khalil ways in which such a process could be
(PhD Scholar), Research Fellow,
Chemical Safety and Applied applied to a small research facility, the
Toxicology Laboratories, complexity and diversity of issues to be
Department of Safety Sciences,
University of New South Wales
addressed and the continual
(UNSW), Sydney 2052, Australia management commitment and support
required to achieve its objective.
Boban Markovic
(PhD), Lecturer, Department of
Safety Sciences, UNSW, Sydney
2052, Australia
INTRODUCTION
Chris Winder The EMS process is mainly a management tool that
(Associate Professor in Chemical
will help organizations in managing and reducing
Safety), Department of Safety
the impact of their activities products or services. It
Sciences, UNSW, Sydney 2052,
is wrongly interpreted by some as a means to
Australia
manage the external environment associated with a

CCC/1087-8378/97/020061–07 $17.50
© 1997 John Wiley & Sons, Ltd.
62
particular activity, or a process that is it is seen as a
pollution control measure or waste management
plan. Perhaps the most expressive definition of an
EMS would be that adopted by the International
Organization for Standardization (ISO) which
states:
‘‘The part of the overall management system which
includes organizational structure, planning activ-
ities, responsibilities, practices, procedures, proc-
esses and resources for developing, implementing,
reviewing and maintaining an environmental
policy.’’
The Department of Safety Science is one of the
departments in the Faculty of Science and Technol-
ogy at the University of New South Wales (UNSW)
located in Sydney, New South Wales Australia. The
Department has been witnessing a broadening and
expansion of its activities since its creation in
1986.
The main concern of the department is to provide a
scientific approach to the problems of health, safety
and environment in the workplace along with the
promotion of safety awareness in the areas of
physical, health and behavioural sciences.
The Chemical Safety and Applied Toxicology
(CSAT) laboratories are an integral part of the
research work of the Department of Safety Science.
The laboratories have been undertaking research in
the development of new methods which measure
the toxic properties of materials based on in vitro
toxicology methods. All tests are carried out on cells
in permanent culture or from blood cells isolated
from human donors using the latest molecular
biology techniques and tissue culture methods.
An EMS was developed for the CSAT laboratories
in 1996. This in conjunction with the Departmental
Occupational Health and Safety (OH&S) policy
introduced in 1997 provides a structured approach
for organizational efforts to address environmental
concerns through the allocation of resources,
assignment of responsibilities and ongoing evalua-
tion of practices, procedures and processes that are
a part of the everyday laboratory activities.
The approach that was adopted followed closely
the guidelines established in the AS/NZ standard
ISO 14001 (1996) as the framework for developing
and implementing the EMS and its co-ordination
with other management systems already in place,
such as workplace risk assessment, safety and
workplace procedures, exposure control, training of
personnel and waste management.
Christian Khalil et al.
“The main use is to allow all
affiliated employees to assess
their environmental
performance
”
OBJECTIVES OF THE EMS
There are several critical objectives required for a
laboratory. The main use is to allow all affiliated
employees to assess their environmental perform-
ance, minimize their impact and recognize the
economic and environmental benefits of having an
EMS in place.
The EMS is also a means that could be used for
reducing the expenses of any organization and this
could be achieved through a variety of processes
such as:
a) Increasing the efficiency of the current processes
in use;
b) Improving storage and handling practices;
c) Recycling of waste materials;
d) Reducing accidental damage through good
emergency planning; and
e) Avoiding waste handling and disposal.
These are also some of the benefits at the organiza-
tional level. To these benefits can be added the
environmental benefits that are essential in promot-
ing the CSAT laboratories image along with its
current environmental programs. The environ-
mental benefits consist of the following issues:
a) Reducing the discharge of wastes;
b) Better compliance with regulatory requirements
in regard to pollution matters;
c) Reduction of environmental release of
materials;
d) Efficiency in energy use;
e) Less waste and a more environmentally friendly
premises.
An EMS contains components that have similarities
with other programs. It can therefore be structured
such that it can be integrated easily and trans-
Application of an Environmental Management System
Figure 1. Areas of overlap in Management Systems
parently into the management structures such as a
Safety Management System (SMS) (Figure 1).
BENEFITS ASSOCIATED WITH THE
PRESENCE OF AN EMS
The EMS approach can help in setting up risk
control targets for improvement with an emphasis
on minimization of environmental impacts, cost
reduction and risk control.
Implementing the guidelines of the EMS and their
adoption by department management can yield
many advantages. Among the advantages is the
fact that the collection of the information regarding
current regulatory requirements will help in future
planning. Furthermore, the environmental
improvements that will be introduced at this stage
will be less costly than their adoption at a later
stage. By following the Guidelines outlined in the
EMS a safer workplace environment will be pro-
duced and the existence of guidelines for organiza-
tional health and safety compliance will continue to
value add to the EMS. The reduction in the risks of
risk exposure or accidents occurring will reduce
any potential lost time and therefore will increase
the overall departmental productivity.
“the adoption of a sound
environmental management
does not necessarily need great
expense
” with the documentation of the existing structures
63
The establishment of a hazard and risk analysis of
the different components of the existing
frameworks will minimize the risk of property
damage along with reducing some of the operating
costs that would have been incurred as a result of
the accidents. The integration of information in one
program will help others, such as improving the
staff training program. Therefore the adoption of a
sound environmental management does not
necessarily need great expense and the benefits that
result of its implementation outweigh by far any
initial investment.
PRELIMINARY MEASURES FOR THE
IMPLEMENTATION OF THE EMS
The primary step in the process of establishing an
EMS consisted in undertaking a scoping study
whose results allowed the identification of environ-
mental impacts and problems that might arise out
of the EMS implementation and development. An
environmental audit of all existing facilities in the
laboratory and the assembly of all the documenta-
tion required in order to comply with the relevant
legislation was carried out. The development of a
training and awareness program and the restructur-
ing of the existing environmental activities into the
existing structure of workplace health and safety
management programs was also considered (2,3).
A statement of environmental commitment state-
ment was proposed for the CSAT laboratories along
64
Figure 2. The approach observed in the EMS development
and different responsibilities into the new manage-
ment framework. The next step consisted in draft-
ing the environmental policy where a set of
priorities was established along with proposed
implementation and evaluation procedures.
The planning steps consisted mainly in considering
the environmental aspects associated with the daily
activities of the premises, the adequacy of resources
and environmental information to deal with the
issues along with the legal requirements that needs
to be met as a minimum standard (Figure 2).
THE WASTE MANAGEMENT STRATEGY
One issue of major importance was identified in the
planning process, which is the amount of waste that
is generated by any laboratory. It was decided to
develop a chemical management strategies. The
first step for both of the components of the EMS
was to update the chemical database. The inventory
of chemicals was reviewed and old/surplus chem-
icals removed. Material Safety Data Sheet (MSDS)
for most of the chemicals on premises were
reviewed and the missing MSDS requested from
chemical suppliers. The Hazardous Materials
Inventory for some chemicals on the premises was
also audited and updated so as to meet with current
regulations and laws (4). A further step consisted in
the analysis of some of the hazardous processes that
Christian Khalil et al.
were used in the laboratory and the establishment
of new protective measures to avoid any future
accidents. This process was documented in a formal
system of workplace assessments.
Disposal of hazardous wastes was also investi-
gated. This was performed by referring to the
current regulations in regard to waste disposal (5),
and their integration along with the existing prac-
tices observed in this specific workplace. This step
consisted in reviewing the procedures that were in
place regarding the restrictions on the ways wastes
are produced and disposed off and the general
disposal procedure for non contaminated wastes.
The disposal arrangements were also audited and
some new measures put in place.
Specific waste disposal procedures consisted
mainly in recommendations and instructions relat-
ing to different waste categories such as chemical,
solvent, biological and sharp/glass waste. A waste
manifest tracking system was implemented so as to
account for all the wastes that are being disposed
off as well as their means of disposal.
In the line of waste management, the permits
granted by the NSW EPA regarding the waste
disposal were also considered. Finally a Waste
Minimization and Recycling program was devel-
oped and implemented.
Application of an Environmental Management System
INVOLVEMENT OF MANAGEMENT
The implementation and operation of the manage-
ment system along with the structure and responsi-
bilities lies within the hands of the upper manage-
ment. Although the EMS was developed for the
CSAT laboratory, issues that are external to the
laboratory premises but intrinsic to the department
had also to be considered. The emergency planning
for the laboratory should take into consideration
the proximity of other working areas next to the
laboratory, which means an integrated emergency
procedures for the laboratory and adjoining
premises.
All aspects of emergency planning were con-
sidered. Emergency response information and dia-
grams were set up at different locations. A more
open hazard communication strategy was also
encouraged.
The most important task for the management is the
periodic review of the EMS document produced
and an update of the procedures in accordance with
the new regulations.
SETBACKS IN THE EMS
CONSTRUCTION PROCESS
Some setbacks were encountered during the con-
struction of the EMS. The early problems encoun-
tered were associated with the integration of the
new policies with the existing ones. The major
setback was mainly associated with the legislative
side where State and Commonwealth environ-
mental related legislation had to be integrated in
one document. The complexity of this issue is
shown by the variety of relevant legislation (Table
1) (6).
In addition to these legislations, the issue of
Common Law had to considered in EMS formula-
tion because of its importance in assigning respon-
sibilities for laboratory managers and supervisors.
In this regard issues such as negligence, nuisance,
and the degree of knowledge of the nature of the
hazards need to be always considered. Hence the
task of putting together all these laws in the
framework of the EMS and assigning specific
responsibilities was one of the most difficult tasks
in the project.
Management was also very co-operative with the
65
team which helped in increasing the efficiency of
the team in developing an internal audit system.
THE AUDIT RECOMMENDATIONS
The overall CSAT laboratory activity was found to
be satisfactory but some changes were recom-
mended to keep in pace with up and coming
legislation. The changes that were recommended as
a result of the audit performed included:
d Chemical labelling
The labelling of some of the chemicals in the
laboratory area needed to comply with new
requirements for decanted materials (7,8). Further,
labelling of wastes, especially those that will be
disposed off needs improvement. It was recom-
mended the characteristics of the chemicals (e.g.
flammable or corrosive) should be clearly stated on
the secondary container that contains these
chemicals.
Table 1. Legislative requirements to be considered
in the EMS preparation
Commonwealth Australian Quarantine
Inspection services requirements
NSW Clean Air Act 1961
NSW Clean Water Act 1970
NSW Dangerous Goods Act 1975 and
Regulation 1978
NSW Environmental Offences and Penalties Act
1989
Commonwealth NHMRC: Code of practices on
the handling of carcinogenic and highly toxic
substances
NSW OHS Act, 1983
The Commonwealth Poison Act, 1966
NSW Poisons and Drugs Act 1978
NSW Pollution Control Act 1970
NSW Radiation Control Act 1990
NSW Waste Minimization and management Act
1995
66
d Chemical storage
The date when chemicals were transferred into the
chemical storage area for disposal and the chemical
name and dilution (if applicable) should be clearly
legible on the containers because these will be of
great help to the university waste contractor for
proper disposal of these chemicals. Furthermore the
storage of some corrosive dangerous chemical with
poisonous and toxic chemicals in an open cabinet of
a height of more than two metres was identified as
a potential hazard that should be dealt with
immediately.
d Waste disposal
In regard to the hazardous waste it was noticed that
these wastes were not stored in secondary contain-
ers. This storage requires a lot of space but
secondary containers are part of legal requirements.
It was also noted that the chemicals to be disposed
of were placed in a single fume hood in large
quantities. This issue should be looked at so as to
minimize the storage since the university waste
contractor could be contacted on weekly basis.
Furthermore, the presence of these chemical mix-
tures for a long time may be considered by the legal
authorities as an intentional mean of disposal of the
most volatile chemicals (e.g. xylene) into the atmos-
phere and this would represent a breach of the
Clean Air Act.
d Training
The issue of safety training and the legal require-
ments to be adopted in the laboratory safety
training is a fundamental responsibility of all
laboratory directors for which the University Safety
and Environmental Service Unit (S&ES) continues
to provide responsive assistance (9).
UNSW's policy on training states that all faculty
and staff supervisors including those in laboratories
and offices are responsible for training all employ-
ees (including permanent, part-time, and casuals)
and students under their direction about hazards
including hazardous substances in their work areas.
This information and training must be provided to
employees at the time of their initial assignment to
the work area, and to students within a reasonable
period after enrolment in a course or laboratory
involving the use of chemicals.
Additional instruction must also be provided
whenever a new hazard is introduced in the work
area or laboratory. The university safety and envi-
Christian Khalil et al.
ronment unit should be contacted for answers to
any questions about the department's safety train-
ing procedures.
“Documentation at all levels is
critical to maintaining the
maximum return on the
investment
”
d Communication and implementation
Supervisors are responsible for communicating
specific information to their staffs and/or students
concerning safety procedures to be followed for all
routine and non-routine laboratory or maintenance
tasks involving hazardous materials. Employees
and students are to be informed of any new
information concerning potential hazards as it
becomes available.
d Documentation
Documentation at all levels is critical to maintain-
ing the maximum return on the investment by
providing a legal record that reasonable care has
been exercised by the responsible party. The devel-
opment of a unified training evaluation and doc-
umentation form that can help schools and depart-
ments meet regulatory requirements is needed.
Other documentation schemes can also be used,
including meeting minutes, training evaluations,
certification sheets, memoranda, and sign-in sheets.
Instruments (e.g., tests, quizzes) to measure learn-
ing can be implemented at any level to provide
some added assurance that information that has
been delivered has also been absorbed as part of
everyday practice.
d Hazard and risk analysis
A hazard and risk analysis of all different labo-
ratory activities is to be conducted as soon as
possible so as to identify the various risks and
communicate them to the employees and research-
ers (9). Questions and concerns of employees or
students about safety in general and the chemical
hazard communication program in particular
should first be addressed to the principal inves-
tigator, supervisor, or building/department safety
co-ordinator (10). Compliance will be determined
by an inspector appointed by the upper manage-
ment through auditing of records and random
interviews with individuals in their work environ-
Application of an Environmental Management System
ment whenever he or she decides to audit the
program.
d Emergency management
An important issue to be considered is related to
the emergency planning procedures. Emergency
planning diagrams and instructions for first aid,
spills, and fires are being updated to exceed all
standards.
CONCLUSION
The EMS developed does not only represent a
management systems of the external environment
but rather an integration of different systems
already in place in one integrated management
structure. This approach will simplify the inter-
pretation of the different legal requirements and
policies associated with the daily activity of the
laboratory. In this particular situation the EMS
represented a successful attempt in combining
quality, environmental management and occupa-
tional health and safety systems under the EMS
document.
Developing the EMS is not an end in itself, since the
EMS produced needs a continual commitment of
the management along with open lines of commu-
nications between the different parties who are
stakeholders in the EMS. In addition to the manage-
ment support that is required, management com-
mitment to various aspects of personnel training,
regular auditing of the performance and the com-
pliance with the systems introduced is required.
Furthermore, it is the responsibility of the manage-
ment to keep a record of the yearly performances
and to have a constant involvement in keeping up
to date with the new standards and legislation
introduced.
In conclusion the most important aspects of having
the EMS in place are summarized in the following
points:
d A better understanding by the management of
overall performance of the organization;
67
d An improvement in the quality of the services
provided; and
d An awareness of the impacts of certain activities
on the environment and on the occupational
health and safety of the employees and
students.
All this would lead to a better understanding of the
organization for its needs which would help in
setting up benchmarks for continual improvement.
The EMS being the tool for measuring the overall
performance.
The implementation of a management system
would lead to a more environmentally friendly and
safe workplace, where less accidents and therefore
less compensation payouts occur. This would
induce a reduction of the environmental risks and
therefore liability.
Finally an environmentally friendly premises
means a better image in the community due to the
implementation of the Ecologically Sustainable
Development (ESD) principles.
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