EPA EMS General Awareness Training

Presented by David Guest, Esq.

U.S. EPA

Washington, D.C.

Environmental Management Systems (EMSs)

EMSs are used by companies and other entities to focus on environmental

performance and compliance, and also source reductions and system performance.

EPA Policy on EMS

Implementation of an EMS can

Improve environmental performance

Improve compliance with regulatory requirements

“…EPA supports and will help promote the development and use of EMS.”

EMS Basics

Formalization of EMS

EMS formalization transforms an ad hoc procedure into a structured framework specifically designed to achieve continual environmental improvement.

EMS can be designed to integrate business goals

Encourages “out-of-the-box” environmental and management thinking

Establishes protocols for developing time lines, distributing resources, and identifying responsibilities -- sound management

Components of an EMS

PolicyPolicy

PlanningPlanning

Implementation and OperationImplementation and Operation

Checking and Corrective ActionChecking and Corrective Action

Management ReviewManagement Review

EMS FlowEMS Flow

PlanningReview

Policy

Checking Operation

I. POLICY

Top management must define its policy & ensure it is Appropriate Includes a commitment to regulatory compliance Establishes a framework for setting & reviewing

environmental objectives and targets Documented, implemented and maintained Communicated to all employees Available to the Public

EMS FlowEMS Flow

PlanningReview

Policy

Checking Operation

II. PLANNING

An organization must develop a plan to implement its environmental policy

Plan must address environmental aspects/impacts legal and other requirements objectives and targets environmental management program

Environmental Aspects

Establish/maintain procedures to identify environmental aspects of an organizations activities, services and products

Identify aspects with a significant impact Consider significant aspects in determining

objectives

Examples of Aspects and Impacts

Aspects Impacts

VOC emissions Increase in ground level ozone

Discharges to stream Degradation of aquatic habitat and drinking water supply

Spills and leaks Soil and groundwater contamination

Electricity use Air pollution, global warming

Use of recycled paper Conservation of natural resources

Legal and Other Requirements

Establish and maintain procedures for identifying environmental requirements that the organization must follow.

Objectives and Targets

• Establish and maintain objectives and targets at each level and function of the organization.

• Objectives and targets must be consistent with the organization’s environmental policy and commitment to pollution prevention.

Objectives & Targets (cont.)

When determining objectives and targets considersignificant environmental aspectslegal and other requirementstechnical optionsfinancial and operational requirementsviews of interested parties

Environmental Management Program

Allows the organization to achieve its objectives and targets.

An effective program should includetimeframemethods to achieve objectivedesignation of responsibilities

Environmental Management Programs must be updated for new or modified activities, services or products.

EMS FlowEMS Flow

PlanningReview

Policy

Checking Operation

III. Implementation and Operation

An effective EMS requires the development of support mechanisms necessary to achieve environmental policies, objectives and targets, such mechanisms includes

Structure and ResponsibilityTraining Awareness and CompetenceCommunicationEMS DocumentationDocument ControlOperational ControlEmergency Preparedness and Response

Structure and Responsibility

Roles, responsibilities and authorities are properly defined, documented and communicated

Appropriate resources including human and financial are provided

An EMS representative is appointed to ensure that EMS requirements are met and maintained report on EMS performance to management

Training, Awareness & Competence

Appropriate training must be provided to all personnel whose job activities impact the environment. This training should entailpotential environmental impacts of their activities importance of conforming with the organization’s EMS their roles and responsibilities for EMS complianceconsequences of not complying with the EMS

Communication

An organization must establish procedures for

Internal communication

External communication

EMS Documentation

Establish and maintain documentation to

describe the core elements of the EMSidentify the location of related documents

Document Control

All EMS documents should be readily locatedavailable for use where EMS activities occur reviewed and updated periodically removed when obsolete retained for legal or knowledge purposes legible, dated and readily identifiable

Operational Control

Operations that are associated with significant environmental impacts must be identified and controlled by

Establishing & maintaining documented proceduresSpecify operating/performance criteria in procedures

Emergency Preparedness & Response

Establish and maintain procedures foridentifying potential accidentsresponding to emergencies and accidentspreventing and mitigating emergencies

Emergency Preparedness & Response (cont.)

Preparedness and response procedures should be

maintained and updatedperiodically tested

EMS FlowEMS Flow

PlanningReview

Policy

Checking Operation

IV. Checking & Corrective Action

Procedures that establish requirements for monitoring the EMS and correcting deviations including

Monitoring and measurementNonconformance and corrective and preventative

actionsRecordsEMS audits

Monitoring and Measurement

Regularly monitor and measure operations and activities with potential environmental impacts

Calibrate monitoring equipment and log calibration activities

Establish procedures to periodically evaluate compliance with environmental legislation and regulations

Nonconformance and Corrective and Preventive Action

Establish and maintain procedures for handling, investigating and taking action to correct nonconformances

Ensure corrective actions are appropriate and commensurate risk

Record any changes resulting from a corrective action

RecordsProcedures must be maintained for the identification, maintenance and disposition of environmental records. Records shouldbe legible, identifiable and traceable to the activity,

services or product involvedbe stored and maintained to be easily retrievable and

protected from damage, deterioration or losshave the retention time marked and recorded

EMS Audit

Establish and maintain programs and procedures for audits todetermine if the EMS conforms with all

requirementsdetermine if the EMS is properly implemented

and maintainedprovide information on the effectiveness of the

EMS

EMS audits should be scheduled and based on the environmental importance of the activity and results of previous audits.

EMS FlowEMS Flow

PlanningReview

Policy

Checking Operation

V. Management Review

Top management must

Ensure EMS continues to besuitableadequateeffective

Address possible changes to policy, objectives and other elements

EMS FlowEMS Flow

PlanningReview

Policy

Checking Operation

Benefits of EMSs

Benefits of an EMS

Cost SavingsReduced Liability/

Improved ComplianceContinued Improvement

in Environmental Performance

Improved Communication

Cost Savings

Electronic Controls & Communications Company$9,000 annual savings in hauling expenses

Aluminum Products Manufacturer$580,000 annual savings in energy costs

Manufacturer of Electronic Test ToolsIn 1996, $86,816 savings from reduced water use

$49,335 annual savings from increased recycling

$9,600 annual savings from recovered materials

Cost Savings

Testing Equipment Manufacturer70% reduction in waste disposal costs

Ford CompanyProjects a savings of hundreds of thousands of dollars

over a five-year period.

Reduced Liability/ Improved Compliance

3MSignificant reduction in fines and violations

Apple ComputerImproved compliance

Legal and ethical obligations are met in a more timely fashion

Continued Improvement in Environmental Performance

Financial Services Institutereduced electricity, heat & paper consumption

Xerox13% reduction in energy consumption

Electronic Controls & Communications Company85-ton reduction in solid waste

18 tons of office paper have been recycled

Improved Communication Electronic Company

EMS documentation helps employees come up to speed more quickly and makes them perform more effectively.

Established documentation reduced training time.

Semiconductor ManufacturerEmployees are more willing to mention potential environmental improvements.

An Effective EMS Integrates Environmental Management into Everyday Business Activities