Creatin

g an
EMS
for
 Objectives

• What is an EMS?

• What are the models we have to choose from?

• What do we have to do and when?

 What is an EMS
(Environmental Management System)

That facet of the organization’s overall management structure that

addresses the immediate and long-term impact of it’s products,
services, and processes on the environment.

It is a systematic approach to ensuring that environmental

activities are well managed in the organization.

An EMS brings together the people, policies, plans, review

mechanisms, and procedures used to manage environmental
issues.
 What is an EMS
Provides a predictable structure for managing,
assessing, and continuously improving the
effectiveness and efficiency of the management of
environmental activities.

Builds in periodic review by top management.

Emphasizes continuous improvement instead of crisis

management.
 What is an EMS

It’s focus is management practices.

It’s goal is minimal impact to the

environment.
 Tangible Returns on an EMS
Investment
1. Provides an environmental management framework.
2. Reduces support costs by integrating site contractors and
activities.
3. Supports risk management by reducing the risk profile and
diminishes liability.
4. Supports performance-based contracting.
5. Helps avoid gaps and overlaps.
6. Shows due diligence (improves relationship with regulators and
the public).
7. Integrates related ES&H activities like P2 and worker safety.
8. Improves recognition of P2 opportunities.
 Opportunities-Awards
National Performance Track
EPA voluntary program to reward recognized
facilities and organizations with
1. a proven record of regulatory compliance,
2. a demonstrated commitment to continued
improvement and outreach to the local
community and the public, and
3. an EMS.

Others (Env. Leadership Program, Project XL, Env. Management

Reviews)
 WHY?
• Executive Order 13423
Strengthening Federal Environmental, Energy,
and Transportation Management

• DOE Order 450.1

Environmental Protection Program
 E.O. 13423
• Is incorporated in the FRA contract with DOE.
• Directs Federal agencies to implement EMS at all appropriate organizational levels
to:
– ensure the use of EMS as the primary management approach for addressing environmental
aspects of internal agency operations and activities,
– Establish agency objectives and targets to ensure implementation of the EO,
– Collect analyze and report information to measure performance in the implementation of
the EO.
• Sustainable Practices:
1. Energy efficiency
2. Use of renewable energy
3. Reduction of water consumption intensity
4. Sustainable acquisition of recycled content, energy efficient, biobased, and environmentally
preferable products and services
5. Pollution prevention, including reduction or eliminatin of the use of toxic and hazardous chemicals
and materials
6. Waste prevention and recycling
7. Sustainable design/high performance buildings
8. Vehicle fleet management, including the use of alternative fuel vehicles and alternative fuels and the
further reduction of petroleum consumption
9. Electronics stewardship
 DOE Order 450.1
• Environmental Protection Program.
– Was DOE Order 5400.1
– Significantly modified
• Not currently incorporated in the FRA
contract with DOE.
– FAO is not pushing for its incorporation
• Is performance based and designed to meet
the requirements of E.O. 13423.
 DOE Order 450.1
Contractor Requirements Document (CRD)

• Requires contractors to integrate numerous

environmentally related requirements already
placed on it by existing statutes, regulations, and
policies through the use of an EMS incorporated
into an ISMS.

• 13 Points (See handout).

 CRD Points
1. Integration into ISMS.
2. Integration into ISMS.
3. Integration into ISMS.
4. Waste prevention, recycling and acquisition, energy efficiency, EMS, fleet
and transportation efficiency.
5. Procurement and distribution programs for toxic or hazardous materials
management.
6. Economically beneficial landscape practices.
7. P2.
8. P2.
9. P2.
10. Monitoring.
11. Analyses to support monitoring.
12. Oxygen Depleting Substances.
13. EPCRA reporting and planning.
 EMS Options
• Models
– ISO 14001 (certification or not).
– CEMP (The Code of Environmental Management
Principles).

• All follow Plan, Do, Check, Act formula.

 ISO 14001
• Established by the International Organization for Standardization
(ISO).
• Part of ISO 14000 series that covers environmental managements
systems, environmental auditing, environmental performance
evaluation, environmental labeling, life-cycle assessment and
environmental aspects in product standards.
• Specifies the framework for the management system that allows the
organization to meet its environmental obligations reliably and
consistently outside of the “Command and Control” regime.
• Revised in 2004.
 EMS Elements
from ISO 14001
• Scope
• Normative References
• Terms and Definitions
• EMS Requirements
– General Requirements
– Environmental Policy
– Planning
– Implementation and Operation
– Checking
– Management Review
 Policy
• Statement signed by facility manager.
• Appropriate to the nature, scale and impacts of the organizations
activities, products and services.
• Commit to:
– Continual improvement
– Pollution prevention
– Compliance and other requirements
• Provides framework for setting and reviewing environmental objectives
and targets.
• Documented, implemented and maintained.
• Communicated to persons working for or on behalf of the organization.
• Available to public.
 Planning
• Identify aspects and impacts from activities, products, and services.
– Determine significance
– Document and keep up-to-date
– Are taken into account in establishing, implementing and maintaining the EMS
• Review legal and other requirements.
– Identify and have access to
– Determine how they apply to aspects
– Are taken into account in establishing, implementing and maintaining the EMS
• Set objectives, targets and programs.
– Document at relevant functions and levels
– Measurable
– Take into account legal and other requirements when establishing
– Program for achievement
• Designation of responsibility
• Means and time-frame to achieve
 Planning
Important Questions:
1. How do activities interact with the environment?
2. Do they produce waste?
3. Are hazardous materials involved?
4. Are operations located in ecologically sensitive areas?
5. How much water and energy are used?
6. How are significant impacts currently identified?
7. What effect could an accident have on the environment?
8. How are laws and regulations tracked?
9. Have commitments beyond compliance been made?
10. Are there ways to support other initiatives, such as NEPA?
11. How can it be integrated with safety?
 Identifying Environmental
Aspects
An aspect is an element of an activity, product, or service that
interacts with the environment.

– Can be thought of as the actual or potential “cause” of an

environmental impact.

– Can be regulated or unregulated.

– Can be negative or positive.

– Begin by looking backward and then forward.

 Examples
• Vehicles emit exhaust
• Water leaks from distribution system
• Fueling spills occur
• Volatiles from open containers
• Noise from equipment
• Unnecessary energy use from lights and computers left on
• Use of paper bleached with chlorine
• Bicycles don’t emit exhaust
Activity, Product, or Service
Vehicle usage
Visitor Services
Environmental Aspect
Fuel consumption
Fuel exhaust
Noise generation
Fuel consumption
Electricity consumption
Solid waste generation
Water consumption
Waste water generation
Activity, Product, or Service Environmental Aspect
Vehicle Maintenance Hazardous waste generation

Gasoline consumption

Noise generation

Electricity consumption

Solid waste generation

Water consumption

Waste water generation

Release of volatiles
Activity, Product, or Service
Cafeteria food service
Office Work
Environmental Aspect
Food waste generation
Electricity consumption
Water consumption
Waste water generation
Use of ammonia in
refrigeration equipment
Electricity consumption
Water consumption
Release of ozone depleting
substances in air cooling units
Solid waste generation
Disposal of toxics from
computer toner, etc
Waste water generation
 Aspects and the EMS

A comprehensive aspects analysis was done during

development of the EMS.

– Begins with development of a procedure to identify

aspects.

– Maintain register of aspects up-to-date.

 Building an Aspects Register
• Assemble list of activities, products, and services.

• Characterize activities, products, and services.

• List aspects.

• Quantify aspects if possible.

– Helps in prioritization and ranking for improvement.
 Planning
Objectives and Targets:
• Objectives describe the goals for environmental performance.
Examples: emissions goals, pollution prevention, use of raw materials,
or incidence of non-compliance.

• Targets are specific and measurable intermediate steps that can be

measured in terms of obtaining the objectives.
Examples: achieving a 50% reduction in releases of certain toxic
substances within two years.

Performance Indicators can give a sharper focus to goal-setting.

Developing them allows managers to assess compliance status, manage
environmental liability, evaluate risk, track progress and meet the
challenge of continuous improvement.
 Implementation and
Operation
• Resources, roles, responsibility and authority.
• Competence, training and awareness.
• Communication.
• Documentation.
• Control of documents.
• Operational control.
• Emergency preparedness and response.
 Resources, roles, responsibility and
authority
• Management shall ensure the availability of resources
essential to establish, implement, maintain and improve
the EMS
– Human resources and specialized skills
– Organizational infrastructure
– Technology
– Financial
• Shall be defined, documented and communicated
• Appoint management representative
– Ensure the EMS is established, implemented and maintained
– Report to top management on the performance of the EMS for
review, including recommendations for improvement
Competence, training and awareness
Ensure persons performing tasks for it or on its behalf (contractors should be
included) that have the potential to cause a significant environmental impact
be competent on the basis of appropriate education, training or experience,
and shall retain records.
Identify training needs associated with the environmental aspects and the EMS
and provide training or take other action to meet these needs and retain
associated records.
Establish, implement and maintain a procedure to make persons working for or on
the Labs behalf (contractors) aware of:
1. The importance of conformity with the Labs policy and procedures and with the
requirements of the EMS
2. The significant aspects and related actual or potential impacts associated with their
work, and the environmental benefits of improved personal performance
3. Their roles and responsibilities in achieving conformity with the requirements of
the EMS, and
4. The potential consequences of departure from specified procedures.
 Communication and Reporting
Establish, implement and maintain a procedure, with
regard to environmental aspects and the EMS, for:
– Internal communication with various levels and
functions
– Receiving, documenting and responding to relevant
communication from external interested parties
Decide whether to communicate externally about
significant environmental aspects, and if so,
document the decision and method for
accomplishment
 Communication and Reporting
Necessary to motivate and direct employees, and build confidence and
acceptance with the public and regulators.
Important Questions:
What is the process for communicating the policy?
Do they work well and run smoothly or are they in “crisis” mode?
Are the right audiences being reached?
Is dialogue two-way?
How is feedback managed?
Are corrective action results communicated effectively?
How can continual improvement be effectively communicated?
Communication Techniques:
Examples: written directives, e-messages, regular employee mtgs.,
public meetings, press releases, periodic rpts., newsletters, etc.
 Documentation
Must include:
1. The environmental policy, objectives, and targets
2. Description of the scope of the EMS
3. Description of the main elements of the EMS and their
interaction, and reference to related documents
4. Documents, including records, required by the standard
5. Documents, including records, determined by the Lab to be
necessary to ensure the effective planning, operation and
control of processes that relate to the EMS
 Control of documents
Documents required by the EMS and by the standard shall be
controlled, including records
A procedure must be established, implemented and maintained to:
1. Approve documents for adequacy prior to use
2. Review and update as necessary and re-approve documents
3. Ensure that changes and the current revision status of documents
are identified
4. Ensure that relevant versions of applicable documents are available
at points of use
5. Ensure that documents remain legible and readily identifiable
6. Ensure that documents of external origin determined by the Lab to
be necessary for the planning and operation of the EMS are
identified and their distribution controlled, and
7. Prevent the unintended use of obsolete documents and apply
suitable identification to them if they are retained for any purpose
 Operational Control
Identify and plan those operations that are associated with the identified
significant environmental aspects consistent with the environmental
policy, objectives and targets, in order to ensure that they are
carried out under specified conditions, by
1. Establishing, implementing and maintaining a documented
procedure to control situations where their absence could lead to
deviation from the environmental policy, objectives and targets
2. Stipulating the operating criteria in the procedure
3. Establish, implement and maintain procedure related to the
identified significant environmental aspects of goods and
services used by the Lab and communicating applicable
procedures and requirements to suppliers, including contractors
 Emergency Preparedness and
Response
Establish, implement and maintain a procedure to identify
potential emergency situations and potential accidents that
can have an impact on the environment and how it will
respond to them
Respond to actual emergency situations and accidents and
prevent or mitigate associated adverse environmental
impacts
Periodically review and, where necessary, revise the emergency
preparedness and response procedures, in particular, after the
occurrence of accidents or emergency situations
Periodically test such procedures where practicable
 Checking
• Monitoring and measurement
• Evaluation of compliance
• Nonconformity, corrective action and
preventive action
• Control of records
• Internal audit
 Monitoring and Measurement
• Establish, implement and maintain a
procedure(s) to monitor and measure, on a
regular basis, the key characteristics of
operations that can have a significant
environmental impact.
– Must include the documenting of information to
monitor performance, applicable operational controls
and conformity with the objectives and targets.
• Ensure the calibrated or verified monitoring and
measurement equipment is used and maintained
and shall retain associated records.
 Evaluation of Compliance

• Periodically evaluate compliance with

applicable legal requirements. Keep
records of results.

• Evaluate compliance with other

requirements. Keep records of results.
 Nonconformity, Corrective Action
and Preventive Action
• Procedure to deal with actual and potential nonconformity(ies) and for taking
corrective action and preventive action. It shall define requirements for:
– Identifying and correcting nonconformities and taking actions to mitigate
their impacts.
– Investigating nonconformities, determining their causes and taking actions
in order to avoid their recurrence.
– Evaluating the need for actions to prevent nonconformities and
implementing appropriate actions designed to avoid their occurrence.
– Recording the results of corrective actions and preventive actions taken,
and
– Reviewing the effectiveness of corrective actions and preventive actions
taken.
• Actions taken shall be appropriate to the magnitude of the problems and
impacts encountered.
• Ensure that any necessary changes are made to the EMS documentation.
 Control of Records
• Establish and maintain records as necessary to
demonstrate conformity to the requirements of the
EMS, the standard, and the results achieved.
• Procedure for the identification, storage,
protection, retrieval, retention and disposal of
records.
• Records shall be and remain legible, identifiable
and traceable.
 Internal Audit
• Ensure that internal audits of the EMS are conducted at planned
intervals to:
– Determine whether the EMS
• Conforms to planned arrangements of environmental management including
the requirements of the standard.
• Has been properly implemented and is maintained, and
– Provide information on the results of audits to management.
• Audit programs shall be planned, established, implemented and
maintained that address:
– The responsibilities and requirements for planning and conducting audits,
reporting results and retaining associated records,
– The determination of audit criteria, scope, frequency and methods.
• Selection of auditors and conduct of audits shall ensure objectivity and
impartiality of the audit process.
 Management Review

Conduct periodic senior management review of EMS

as a whole.
– Ensure its continuing suitability, adequacy and
effectiveness.
– Include assessing opportunities for improvement and
the need for changes to the EMS, including the policy
and objectives and targets.
– Retain records of the reviews.
 Management Review
• Input to review:
– The results of internal audits and evaluations of compliance with legal
requirements and with other requirements.
– Communications from external interested parties, including complaints.
– Environmental performance.
– The extent to which objectives and targets have been met.
– Status of corrective and preventive actions.
– Follow-up actions from previous management reviews.
– Changing circumstances, including developments in legal and other
requirements related to environmental aspects.
– Recommendations for improvement.
• Output to review
– Any decisions and actions related to possible changes to the policy, objectives,
and other elements of the EMS consistent with the commitment to continual
improvement.
 Self-Declaration

• Federal facilities implementing ISO 14001

EMS standard can “self declare” when they
reach full implementation of the standard.

• Focus should be on implementation unless

there is a compelling reason to register.
 EMS Document Structure

EMS
– Policy

– Aspects Register

– Objectives and Targets

 EMS Document Structure

Environmental Management Programs

– Environmental Management Plan

– Training needs

– Organization Chart
 EMS Document Structure

Day-to-Day Operations
– SOP’s

– Training

– Hazwast Manifests

– Energy Bills
 Ownership of Parts

• Management Provide review and direction.

• Environmental Office Provide technical expertise.

• Line managers Provide knowledge.

• Procurement Purchasing knowledge; contractors.

• Maintenance or Engineering Facilities management.

• Other support groups Knowledge of facility systems.

 Coordinate the System
• Cross reference parts to office.

• Identify parts that aren’t clearly assigned.

• EMS coordinators must demonstrate the linkage

between the part and the office.

The success of the EMS depends on integration into day-to-day

activities with ownership as the key to success.
 The EMS Teams

1. The Working Level Team

2. The Senior Management Team

 The Working Level Team
(You and Me)
• Educate all organizations at the lab.

• Conduct internal assessments and audits.

• Collect input from employees and management.

• Plan and implement EMS (develop EMPs).

• Interact with local community as needed.

 The Senior Management Team
(Advisory)

• LSC
• Brought in at decision making time.
• Approve EMPs.
 Level of Effort
• Estimated based on gap analysis.

• Leverage existing resources.

• Shouldn’t be underestimated.

• Obtain management commitment for policy and

implementation.
 Performance Measures
Translate organization goals and targets into operational
terms.
Not easy for environmental performance.
Pitfalls:
– Overreaching (trying to measure everything)
– Focusing on activities that are easy to quantify rather than on
desired results directly keyed to organization goals.
EMS performance:
– Use environmental attributes
– Gauge how well the EMS is functioning
– Benchmarking against the performance of others
 Performance Measures
Measuring Environmental Attributes
– Quantitative measures of regulated pollutants.
– Help identify when certain regulatory
thresholds have been met or track activities that
can have direct impacts on the environment.
– Can translate directly into environmental
performance.
– Example (emissions control).
 Performance Measures
Measuring EMS Performance
– Can be challenging.
– How does the system respond to changing conditions?
– Example: Regulatory Change
• Determination of regulation’s applicability
• Incorporated into training
• Communicated throughout organization
• Incorporated into operating procedures
• Incorporated into self-assessment protocols
• Use for P2 and continuous improvement and compliance
• Use to adjust objectives and targets
 Performance Measures
Benchmarking
A comparison of programs.
Allows for benefit from experience of peak
performers.
Requires establishment of baseline to measure
progress.
 Performance Measures
Measures Outcomes
Elements tracked as a trend Levels wanting to be
over time. achieved.
Examples: Examples:
• Volume of a key • 5% reduction in volume of
hazardous material hazardous material
purchased. purchased.
• BTUs of energy • Installation of high-
consumed. efficiency lighting in 50%
• Concentration of a of office space.
residual in wastewater • 0 discharge of process
discharged. wastewater.
 Examples of Metrics to Measure Benefits

 Improves the environmental condition (environmental

indicators)
 Responds to public scrutiny trends (complaints,
communications)
 Minimizes accidents and problems (incidents, losses)
 Reduces redundant paperwork (time spent per task)
 Cost savings (dollars per unit activity)
 Facilitates compliance (number of non-compliances,
penalty costs)
 Pollution Prevention
P2 benefits can be significantly enhanced
through the EMS framework.
– Ensure broader awareness of P2 issues.
– Enhance relevant training and communication.
– Strengthen ability to recognize and capitalize
on P2 opportunities.
 NEPA
Already a set of tools to identify the
environmental impacts, to consider the
impacts fully in decision-making, and to
reduce the impacts.
– Addresses new but not ongoing activities.
Development of the EMS allows an
opportunity to build on the strengths and
address the shortcomings.
 NEPA
Integrating existing NEPA activities into the
EMS.
– Use existing staff expertise.
• Educate differences.
– Use existing procedures.
• Identification of impacts and identification and
analysis of alternatives.
– Incorporate public involvement activities.
 NEPA
Building on Past NEPA Analyses.
– Identify Impacts
A good head start of sources for identifying aspects and impacts.
– Use Existing Impact Assessment Tools
Build on skills and methodologies to establish relationships between
actions and potential effects.
– “Significant” Caution
Significant Impacts
NEPA = EIS EMS = threshold set by us
Common:
Direct and indirect impacts, cumulative impacts, and P2.
 Integrated ESH Management
System (IESHMS)

• Provides a formal, organized process to

plan, perform, assess, and improve the safe
conduct of work in the DOE.
 Hazard Analysis
• FESHM Chapter 2060
– Hazard analysis is a process by which personnel can
plan work as well as identify and mitigate the
environmental, safety and health hazards involved in
any work activity.
– Example in table 1: Potential Hazards Guideline.
• Hazardous substances and regulated pollutants
• Chemical usage

• When have environmental aspects been documented in a

HA?
 Hazard Analysis

Expand to include what should also be there.

– the environmental impacts.
 What is Expected of Us

• DOE Status Reporting.

• DOE Order 450.1?
• NSF Annual Audit.
• Tripartite Assessments.
• Effective Use of EP Subcommittee.