brookhaven science associates u.s. department of energy 1 george a. goode and john selva...

Brookhaven Science AssociatesU.S. Department of Energy 1

George A. Goode and John SelvaGeorge A. Goode and John SelvaEnvironmental & Waste Management ServicesEnvironmental & Waste Management Services

DOE/EFCOG EMS Workshop – March 8-9, 2005Lessons Learned from a Maturing EMS


Lessons Learned from a Maturing EMS - AgendaLessons Learned from a Maturing EMS - Agenda

BNL Operations Overview Evolution of BNL’s EMS Lessons Learned by ISO 14001 Element

• What worked?• What didn’t?

Summary of Lessons Learned Results


Brookhaven National LaboratoryBrookhaven National LaboratoryBrookhaven National LaboratoryBrookhaven National LaboratoryMission: Basic and applied research in a variety of Basic and applied research in a variety of

scientific fields: Physics, Chemistry, Materials scientific fields: Physics, Chemistry, Materials Science Biology, Medicine and forefront technologyScience Biology, Medicine and forefront technology

Facts:Operated by Brookhaven Sciences Associate (BSA) for DOEOperated by Brookhaven Sciences Associate (BSA) for DOE

3000 employees; 4,000 visiting scientists annually 3000 employees; 4,000 visiting scientists annually 5,000 acre site located on eastern Long Island, NY5,000 acre site located on eastern Long Island, NY


BNL Facilities, Programs, OperationsBNL Facilities, Programs, Operations BNL MACHINESBNL MACHINES

Collider-AcceleratorsRelativistic Heavy Ion ColliderAlternating Gradient SynchrotronBooster Applications FacilityLinear Accelerator

National Synchrotron Light Source

SCIENTIFIC ACTIVITIESSCIENTIFIC ACTIVITIESCenter for Functional NanotechnologyMedical Research OperationsComputational Research CenterMaterial Science ResearchBench-top ExperimentsEnvironmental Research

FACILITY OPERATIONSFACILITY OPERATIONS• Physical Plant Operations

– Sewage Treatment Plant– Central Steam Facility– Major Petroleum Facility

• Waste Management Facility• Environmental Restoration

SUPPORT PROCESSESSUPPORT PROCESSES• Radiation Source Material Storage• Machining Operations• Photography• Fleet Operations• Bulk Chemical Distribution Operations


Historical Environmental ManagementHistorical Environmental Management Small, centralized Environmental support organization within

Safety & Health Physics Division Environmental risk overshadowed by health and safety risks Limited jurisdiction of EPA regulation at federal facilities Proliferation of regulations exceeded BNL response

capability Staff reactive to “urgent” environmental issues Scientific staff shielded from regulatory requirements External communication when and if required by law; limited

“marketing” of accomplishmentsREACTIVE ENVIRONMENTAL MANAGEMENT


Achieving Environmental ExcellenceSystematic Approach of ISO 14001 EMSAchieving Environmental ExcellenceSystematic Approach of ISO 14001 EMS

BNL embarked on a project to implement an ISO 14001 EMS in 1999• Phased approach

BNL Registered to ISO 14001 standard in 2001• First DOE National Lab

Key Elements• Unwavering Sr. Mgmt Support• Commitment of resources

– Financial and people• “Systems Thinkers”• Robust assessment• Prevention based programs


Planning EMS ImplementationKey Decisions: Level of ImplementationPlanning EMS ImplementationKey Decisions: Level of Implementation

Implementation at the Laboratory Level• Benefits: Least documentation, consistency, one management review,

consolidated list of aspects, objectives/targets, transparent to line, easier to manage and audit

• Drawbacks: Less line involvement and ownership, tends to be “bottled up” in Environmental Dept, fewer focused objectives/targets, little culture change

Implementation at the Directorate Level• Benefits: Less documentation than division level, good ownership and line

management involvement, limited number of management reviews, good focused objectives/targets, promotes teamwork and achieves culture change

• Drawbacks: More documentation than Lab level, more meetings, less consistent and more difficult to audit

Implementation at the Division Level• Benefits: Most ownership and focus• Drawbacks: Most documentation, least consistent, most difficult to manage/audit


Directors OfficeHR, ITD, OMC

HENP BES NSLS EENS Life Sciences

F&O CEGPAP&GA

Ed Programs

Finance ESH&QRadConSHSD

EWMSDQuality

EM

CAD

Physics

Instrum

Number of EMS Programs at Line Level: 11(down from 14 originally)

All Have EMS Representatives and Core Teams

EMS Overview:Current OrganizationEMS Overview:Current Organization

Magnet


Planning EMS ImplementationKey Decisions: IntegrationPlanning EMS ImplementationKey Decisions: Integration

Integrate EMS Elements with existing management systems• Most important and powerful strategy for success• Obtain ownership by other Management System owners

1. Aspects: Work Planning and Control2. Legal & Other Requirements: SBMS3. Objectives/Targets: Planning4. Resources/Roles: Planning and HR5. Competence/Training: Training6. Communication: Communication/PR7. Documentation: Quality Assurance8. Control of Docs: Quality Assurance

9. Operational Control: Work Planning10. Emergency Prep: Emergency Mgmt11. Monitoring/Measuring: Integrated Assessment12. Evaluation of Compliance: Environmental13. Nonconformance: Quality Assurance14. Control of Records: Quality Assurance15. Internal Audit: Integrated Assessment16. Management Review: Integrated Assessment


Element by Element ReviewElement by Element Review

What worked…what didn’t

John Selva, EMS Program Manager

Environmental & Waste Management Services Division

Brookhaven National Laboratory


Environmental PolicyEnvironmental Policy

Policy writers were well versed in BNL operations, ISO language and had full management commitment

Policy is direct and to the point Commitments translated well

into an acronym (P2C4) Policy reflected real changes

(not too lofty) Lots of Posters, Training Aids,

and reminders

P2C4P2C4Pollution PreventionPollution Prevention

ComplianceComplianceCommunity InvolvementCommunity Involvement

CleanupCleanupContinual ImprovementContinual Improvement

EMS Policy evolved EMS Policy evolved to include Safety, to include Safety,

Security and HealthSecurity and Health

Issues EncounteredIssues EncounteredWhat workedWhat worked Policy awareness fades over

time• Frequent reinforcement needed• Heightened attention prior to

audits needed Integration with safety, health,

and security blurs message


Environmental AspectsEnvironmental Aspects

Integrated into Work Planning• Experimental Safety Reviews• ECR involvement a must!!!!

Process Assessment Approach• Key for routine processes• Identified aspects, operational

controls, and led to many P2 opportunities. Big $ savings

BNL Products not initially addressed• Especially “intellectual property”

Procedure criteria specific to negative impacts• Did not consider positives

Criteria may be too focused and may be missing obvious (everyday) aspects• Skill of the craft not fully captured

P2 Award WinnerP2 Award Winner

Issues EncounteredIssues EncounteredWhat workedWhat worked


Legal and Other RequirementsLegal and Other Requirements

EMS Manual is very descriptive• Lists Key requirements

SBMS ROD process • Very effective system for capturing lab

level requirements• Departments can rely on Lab level

program Requirements (subject areas)

developed by cross-functional teams lead by Subject Matter Expert All significant aspects have subject area

to flow requirements to line and guide employees

High level of effort to revise a Subject Areas• Simple procedures may also do

the trick Information overload



Objectives, Targets and ProgramsObjectives, Targets and Programs

Integration with Lab Planning processes• Demonstrates connection to

institutional priorities ESH&Q Environmental Priorities

• Helps line focus on key objectives Divisions personalize EMS with

specific O&T’s• Well documented using Operational

Control Forms and Planning Forms at Division level

Use of Self Assessment Plan Feedback at Management

reviews – Key• Management involvement flowed

down into objectives

Flowdown not always clear Departments needed to learn

how to develop measurable O&T’s (They were often based on routine work)• Needed Training

Planning could be integrated with existing Self Assessment Program



Objectives, Targets and Programs


Resources, Roles, Responsibilities and AuthoritiesResources, Roles, Responsibilities and Authorities

Created “Agent R2A2’s”, roles documented by procedure• Lab Director• EMS Representatives• 90-Day Area Managers• ECRs

Operational Controls/Planning Forms force line management to assign responsibility• Planning forms identify responsible

personnel

Flow down to relevant personnel is challenging

Employee Reminders needed on E Issues

R2A2’s must be E-Specific Supervisors were not playing

needed role in delivering message



Competence, Training and AwarenessCompetence, Training and Awareness

Training tailored to ‘need to know’• All Employees: Gen Env Training (Policy,

Emergency Response)• All Managers: EMS Overview Briefing• EMS Representatives: Overview,

Obj/Targets, Audits• Staff involved with significant aspects:

Job Specific Training• Contractors: Contractor/Vendor

Orientation (Policy, Emergency Response)

Web-based CBT

Maintaining Awareness is a constant challenge• Need constant vigilance

(Advertising)• Constant reminders by EMS

Reps and Lab director Skill of the craft may assume

that they understand E issues and may be outside of training systems. This was recognized in recent OHSAS Project



CommunicationCommunication

Dedicated Communication Staff Lots of avenues to promote

• (Bulletin)• (Monday Memo)• (Interoffice Bulletins)

Mature Well established communication with Public

Extremely open forums We tell the public everything We offer information rather then wait to be

asked Used lots of tools (Posters, Charts, Cards) Policy is posted in obvious places.

Hard to communicate to all employees due to the diverse job base.



DocumentationDocumentation

Major program elements documented in SBMS• Helps reduces duplication• One Aspects Procedure

ISO 14001 elements linked in EMS Manual• Serves as good roadmap

Tendency to duplicate in Departments still exists• Try to stick to common website

Opportunities for right sizing



Control of DocumentsControl of Documents

Web-based documentation• Reduces doc control problems

- Out of date- Current revisions

Large number of documents, procedures, and forms• Lots of opportunities for

nonconformance No common Lab-wide system

• Difficult for auditors to understand

Lack of common understanding of what documents need to be controlled



Operational ControlOperational Control

Well addressed through Work Planning• Experimental Safety Reviews• Process Assessments• Non-routine work planning

Dedicated forms• Provides a road map for Departments• Lists environmental records and

assigns responsibility• Links operating procedures to aspects

Distinguishing between Operational Controls• Aspects• Significant Aspects

Tough to manage Facilities and Operations work• Assuring the work permit system

is implemented • Missing Skill of the craft items



Emergency Preparedness and ResponseEmergency Preparedness and Response

Integration with existing Emergency Response systems

Improved awareness of staff• Spill Reporting• Effluent monitoring• RCRA• SPCC

Most existing systems meet the intent but must be sure all EMS concerns are addressed• Be sure to properly address

compliance (spills) issues well. • Routine drills must be up to

date- will be included in EMS Audits



Monitoring and MeasurementMonitoring and Measurement

Lab Level: Leverage the Annual Site Environmental Report

Line Level: Use Self Assessment Plan to monitor progress

Systems are centralized at the Compliance group level• Detailed environmental monitoring plan• Dedicated Field Sampling Team

Management reviews roll up information for Sr. Managers

Line management tendency to not understand where this applies• Tendency to use routine

requirements as a measure of success

• Linkage to Significant Aspects Supervisors and EMS Reps

needed better training



Evaluation of ComplianceEvaluation of Compliance

BNL ISO 14001 Plus• Plus = compliance and community

Dedicated procedure requires compliance assessments• Targeted Assessments based on past

performance and importance• Common format and scope

Self Assessment process includes compliance

Regulatory (external) assessment results well communicated

Reliance on other management systems can lead to vulnerabilities• Management system owners

must take responsibility for implementation effectiveness

Results of Self Assessments not rolled up effectively



Nonconformity, corrective and preventative actionNonconformity, corrective and preventative action

Integration with existing systems• NCR• ORPS

Excellent Assessment Tracking System (ATS)• Tracks all actions to closure

Developed two specialized SOPs• Groundwater Contingency Plan• Environmental Event Response

Effectiveness of corrective actions• Fighting the next fire

Stigma associated with NCR and ORPS• Reluctance to report based on

response by DOE and Management

Trending not well established



Control of RecordsControl of Records

One common procedure• Defines what a record is• Establishes records inventory

One common database of records

Variability concerning what constitutes an Environmental record• Training required

Records storage is not uniform



Internal AuditInternal Audit

Rolled up to Lab Level• Eliminated 14 audits at line level

Ensure scope involves line input• Documented on audit planning forms

Initially used industry experts• Helped get system up to speed• Now only occasionally use external

auditors Trained Internal Staff

• Line and Environmental staff Share Internal Auditor resources with

other Labs• Allows staff to see how it’s done at other

sites

Started out making all departments audit themselves• Too many and low quality

Awareness of ISO auditing standards• ISO 19011• ANSI/ISO 14010• ANSI/ISO 14011• ANSI/ISO 14012



Management ReviewManagement Review

Lab Level Mgmt Review• Reviews major trends and issues

with Sr. Mgmt Department level Mgmt Review

• Specifically reviews performance• Creates very good ownership

Good opportunity to show Value Lots of metrics Tool to document Senior

Management input and continual improvement.

Hard to maintain focus when things are going well• Competing with the issue of the day

Multi-level management reviews sometimes considered redundant

Slow to get effective input from management• Significant improvement as

Managers realized the value



Lessons LearnedLessons Learned

Summary of Lessons Learned

George A. Goode, Division Manager

Environmental & Waste Management Services Division

Brookhaven National Laboratory


EMS managed as an integrated project• Formal Project Management Plan• Established scope, schedule, cost, tasks, project controls and tracking systems

Tap expertise when designing EMS• Project manager was ISO 14001 expert• Used top consultant to get Sr. Management on board

Implementation Strategy• Decide what level: Lab, Directorate, or Division• Phased implementation using Pilot Project works well• Design for success: Pick a winner to start, celebrate victories, recognize teams• Integrate EMS with Management System Initiatives (ISM, QA, IA)

Tap invaluable resource: People• Systems Thinkers on Team, Pilot process first• Team approach -- increases ownership, innovation, and value• Senior Managers-- unwavering commitment & support

EMS Implementation at BNL

Lessons LearnedEMS Implementation at BNL

Lessons Learned


EMS Implementation at BNL

Lessons LearnedEMS Implementation at BNL

Lessons Learned Use Web-based systems

• Procedure and documentation delivery Patience…maturation of system takes time

• Anticipate “Requisite floundering” stage • Expect resistance to organizational change

Self-Examine, Self-Identify & Self-Correct• Test programs & provide feedback• Minimize external audit costs by minimizing findings - be prepared• Set & prioritize your own improvement agenda

Challenges• Change operations, Change image, Change culture


Today at BNLToday at BNL

All BNL facilities, experiments & operations certified to ISO 14001 Unprecedented knowledge of environmental aspects & comprehensive

system to control/minimize impact EPA Performance Track member Improving compliance status Pollution prevention projects saving millions Survey shows managers believe environmental stewardship important Openly communicating on issues & progress; highlighting science Regaining reputation & receiving independent recognition

• Awards this year: L.I. Pine Barrens Society Env Stewardship award, EPA Environmental Quality award, White House ‘Closing the Circle’ award, DOE Office of Science ‘Best in Class’ Pollution Prevention award and Stony Brook Univ WRMI Env. Stewardship award


Resources Resources

Web ResourcesP2 Web Page, http://www.bnl.gov/esd/pollutionpreveEMS Web Page, http://www.bnl.gov/esh/ems/

People ResourcesGeorge Goode: [email protected], 631-344-4549John Selva (EMS): [email protected], 631-344-8611Bob Lee (Performance Track): [email protected], 631-344-3148

brookhaven science associates u.s. department of energy 1 george a. goode and john selva...

Documents

brookhaven science associates

department of energy

ems bnl

maturing ems slide

n results

ny slide

n summary of lessons

materials science biology