Environmental Management System Training: United States Forest Service July 6, 2004

Environmental Management
System Training
United States Forest Service

July 6, 2004
Ed Pinero, Acting Federal Environmental

Executive
EMS Implementation Workshop
An Overview of Environmental
Management Systems (EMS)
and the ISO Standard
EMS Implementation Workshop 2

WHAT IS AN ENVIRONMENTAL
MANAGEMENT SYSTEM?
The ISO 14001 Definition
• “The overall management system that includes
organizational structure, planning activities,
responsibilities, practices, procedures, processes and
resources for developing, implementing, achieving,
reviewing and maintaining the environmental
policy.”

“ems” vs. “EMS”
• All organizations have some type of
environmental management system regardless of
what they do
• For this discussion, the focus is a more formalized,
recognized, and structured approach defined in the
international EMS standard, ISO 14001
• In most cases, additional effort is needed to
transition from existing environmental activities to
the more formal ISO 14001-type EMS

An Effective EMS is:
• Flexible
• Transparent
• Useful to the “practitioner”
• In harmony with mission focus
• Focused on continual improvement

EMS and ISO 14001
• 14001 is one of the standards in the 14000 series
• Created by International Organization for
Standardization (Geneva, Switzerland)
• Each participating nation has a committee that
develops consensus and contributes (one vote
each, for US it is ANSI)

Important EMS Terms
• “Shall”
• “Establish and Maintain”
• “Responsibility and Authority”

Plan Do Check Act
Continual Improvement
Management Environmental
Review Policy
Checking & Corrective Planning

Action
Implementation &
Control

Planning
Identify Determine
Environmenta Significant Develop
l Aspects and Environmental Establish
Identify
Impacts Aspects Environmenta
Activities, Objectives
l
Products and Management
and Targets
Service Determine Legal and Other Progra
s Requirements m

Environmental Aspects and
Impacts-ISO 14001 Definition
ENVIRONMENTAL ASPECTS
Elements of an organization’s activities, products or services
which can interact with the environment. (For example:
wastewater discharges, air emissions, resource consumption,
energy usage, ecosystem alterations, etc.)
ENVIRONMENTAL IMPACTS
Any change to the environment, whether adverse or
beneficial, wholly or partly resulting from an organization’s
activities, products, or services (based on the aspects, for
example: air emissions impacts the air by degrading the air
quality).
Implementation and Operation
Organization & Capabilities & Controls
Accountability Communications
Document
Control
Training,
Awareness and
Competence
Operational Control
Structure and
Responsibility
Communication
Emergency
Preparedness and
Response
Checking and Corrective
Action
Non-conformance,
Monitoring and Corrective and
Measuring Preventive Action Records
Periodic Internal EMS Audits

Management Review
To Assess the
• suitability,
Take account of: • adequacy, and
• audit findings • effectiveness of the EMS
• progress records on objectives
changes to facilities
• changes in activities,
products or services In order to determine the need
• changes in technology for change and improvement to:
• concerns of interested parties • the environmental policy
• other relevant information • the objectives and targets
• other elements of the EMS

Plan Do Check Act
Review Policy

Action
Implementation &
Control

Keep in mind…
• The EMS and related measurement tools are just
that, tools. Alone, they will not guarantee success.
The organization must use the tools, not just have
them.
• An effective EMS is “alive”; constantly measuring
performance, making adjustments, and looking for
opportunities for continual improvement
• Accountability is critical

Why Implement an
System?
The Drivers - Why EMS?
History/perspective
• EMS responded to “root causes” for poor
environmental program management and
compliance problems
• EMS has corollary benefits of management
systems to mission and environmental stewardship
• EMS represents the next step in evolution from
compliance, to pollution prevention (for
compliance), to EMS

EO 13148
• Establishes EMS as environmental management
policy for the Federal government
• Requires agencies to incorporate EMS into agency
environmental directives and policies
• Requires facilities to develop and implement EMS
by December 31, 2005

What an EMS is
• A formal, structured framework of policies, procedures
and practices to manage and reduce an organization’s
environmental footprint
• Based on a PLAN-DO-CHECK-ACT framework
• An approach that reflects the relationship between

environmental issues and core mission

What an EMS is NOT
• A one-time project, plan or initiative
• Focused solely on regulatory compliance
• An effort solely for the environmental shop

Benefits of an EMS
• Improved environmental awareness, involvement
and competency across organization
• Better communication of environmental issues -

internal and external
• Positive effect on regulatory compliance and

environmental performance

Benefits of an EMS
• Improved efficiency, reduced costs, greater
consistency in environmental program
• Flexibility and opportunity to correct

imperfections through “continual improvement”
• Identification of risk and prevention of problems

outside of regulatory - e.g., aging infrastructure,
known unregulated hazards

Barriers - What stands in the
way of EMS?
• Organizational change - natural resistance to
change in any organization
• Lack of top management involvement and
visibility
• Organizational issues - “that’s an environmental
responsibility”
• “That’s my responsibility” from the environmental
shop

Potential Barriers
• small p and BIG P political uncertainty - is EMS
here to stay?
• Perception that EMS already exists - systems exist
now, why change?
• Misunderstanding of relationship to mission
“environment only gets in the way of mission”

The Three C’s of an Effective
EMS
Conformance
Meets the requirements (Implements the “shalls”)
Consistency
Various elements inter-related (i.e., Significant
aspects reflected in emergency planning, etc.)
Continual improvement
Mechanisms are in place to improve the EMS
and organizational performance, supported by
management commitment and support

Keep in mind - AN EMS
• Is a management system -
– THAT’S WHAT MAKES IT WORK!!
• Is more than compliance - includes safety, energy,
water etc. and non-regulated impacts
• Supports mission!
• Takes time - it is a process, not an event
• Requires the environmental people to get out of
their box -
• EMS requires commitment - its not a part-time
job!
Using Measurement as a
Management Tool
• Knowing existing conditions allows informed
management decisions.
• An EMS identifies, directs and facilitates relevant
measurements.
• Measurements include environmental conditions,
status of programs, compliance, and the EMS
itself.

Examples of Metrics to
Measure Benefits
• Improves the environmental condition (environmental
indicators)
• Facilitates meeting your mission (how often environmental
issues interfere with your mission)
• Minimizes accidents and problems (incidents, losses)
• Reduces redundant paperwork (time spent per task)
• More efficient use of resources (investment per unit activity)
• Facilitates compliance with requirements (number of non-
compliances, penalty costs, missed EO deadlines)
• Responds to public scrutiny trends (complaints,
communications)

Managing Aspects vs. Impacts
• It is more prudent and more efficient to manage
“how” you interact with the environment than to
manage “what” you have done to the environment
• An EMS is built around identifying, prioritizing,
controlling, and improving upon, those elements
of the organization that interact with the
environment

Fixing the Root Causes
• An EMS is designed to identify the root causes of
non-conformances and initiate corrective and
preventive action.
• This helps minimize the “bandage” syndrome,

where the fixes are simply superficial.

Achieving and Maintaining
Compliance
There is “compliance management system”
embedded within the broader “environmental
management system”
– First- the theme of compliance is seen
throughout the plan-do-check-act elements
– Second, there are specific compliance-related
requirements in an EMS (such as periodic
compliance audits) that help address
compliance issues before they occur.

Supporting Mission
• An EMS identifies and addresses environmental
issues that can hamper mission through
emergencies or non-compliance
• The EMS perspective identifies opportunities that
ultimately support mission through increased
efficiency

Connecting the Environment
and the Process Owners
• An EMS helps each member of the organization
understand their role in the environment, and to
see how their role at the facility impacts the
environment
• An EMS provides for responsibility, ownership,
and accountability of actions and related impacts
• Results? People that are more aware, better
trained, more motivated, and more enthusiastic

Connecting the Organization
With the Public
• An EMS allows an organization to identify issues
which may become a concern to the public
• An EMS indicates to the public that an
organization is aware and responding to
environmental issues
• An EMS provides a forum for discussion and
reaction to environmental interests of the public

Selecting and Preparing the

EMS Team
Function of the Team
• Conduct the gap analysis
– Gather and analyze existing data
– Identify needs
– Develop implementation plan
• Initiate early stages of EMS
– Policy, Aspects/Impacts, Objectives/Targets
Environmental Management Program
• Monitor implementation of EMS

Responsibilities of the Team
• Collect input and information from employees and
Management
• Educate members of the organization or facility on
the EMS
– Awareness training
– Activity specific training
• Brief and advise Management
• Interact with local community

Knowledge and Skills
All
• EMS knowledge and understanding
• Enthusiasm and energy
• Organizational / (p)olitical savvy
Specialists
• Communication skills
• Project management skills

The Team Members
• Keep numbers manageable
• Strong leadership
– Known ability to communicate with
management
– Good people skills
– Best leadership may be outside of
environmental shop

Team Members
• Broad base - Include resource (budget) personnel,
facilities, representative process owners, on- site
contractors, management representative

Process
• Get commitment and authority to act
• Find appropriate members
• Provide initial background information of EMS
• Get commitment from Team
• Get fully trained
• Consider consultants help
• Keep management apprised of progress

Level of Effort
• Leverage existing resources - budget/ planning
cycles etc.
• Depend on Team champions
• Don’t underestimate effort needed and ensure

commitment is there

Defining Your Fenceline:

What is the scope of an
EMS?
EMS Fenceline
• Link to aspects - “can control” or are “expected to
have an influence”
• Define the scope of your EMS -alternatives
– Use physical boundaries of facility
– Reflect existing management systems
– Reflect organizational structure

EMS “Boundaries”
• Geographic fenceline or boundary
– Consider where activities primarily occur
– Reflect of top management control
• Management boundaries previously established
– Existing management plans or systems
• Corporate boundaries
– Reflect existing management structure

Don’t forget to consider!
• Non mission activities
– Visitor and personnel support, housing, food
service, recreation
• Contractors and services
• Geographically separate areas
• Local governments and neighbors

Use caution:
• Don’t artificially exclude processes that you
clearly control but are “unmanageable”
• Don’t artificially exclude something because you
believe you can’t control it organizationally
• Contracted processes are still within your control -
they can’t be excluded

Questions to ask
• Are all organizations associated with activities,
products, and services included?
• Will the boundary include process owners and
those with authority to improve processes?
• Is there management control available for the
selected boundary?
• Is primary mission covered?

Gap Analysis and

Implementation Plans
Gap Analysis
• A gap analysis is an assessment process used to
compare the current state of your facility’s EMS
against a standard. It is not an audit; you cannot
“fail” a gap analysis
• Other similar processes are “Initial Environmental
Reviews (IERs)” or “Environmental Management
Reviews (EMRs).”

Purpose of a Gap Analysis
• To identify gaps between your current
management systems and the EMS standard
• To identify existing policies, procedures,
programs, metrics, and personnel that can be part
of the EMS
• To assist in establishing a list of actions to achieve
the desired EMS

Conducting a Gap Analysis
• Use tool or checklist that identifies requirements
• Analysts must be familiar with EMS framework
and site activities
• Allow several days to complete data collection
• Prepare a summary report that explains what the
gaps are and what must be done to fill them

Steps in a Gap Analysis
• Facility walk-through
• Document review
• Staff interviews
• Compare with desired EMS elements
• Identify and document gaps (be specific, yes or no
answers are not helpful)

Developing the Implementation
Plan
• Uses the Gap Analysis findings
• Intended to logically plan for the implementation
• Requires assessing what needs to be done, and
assigning time frames, resource needs, and
milestones to do so
• Provides a tool to ensure management
commitment and “staying the course”

Planning the Level of Effort
• Estimate level of effort based on gap analysis
• Leverage existing resources
• Don’t underestimate!
• Obtain management commitment for
implementation early

EMS Policy
ISO 14001 Policy Statement
Requirements
• Be appropriate to the nature, scale and environmental
impacts of the organization’s activities, products and
services
• Provides framework for setting objectives and targets
• Be documented, implemented, maintained and
communicated to all employees
• Include a commitment to:
– Continual improvement
– Prevention of pollution
– Compliance with environmental regulations and other
requirements to which the organization subscribes
• Be available to the public
Policy Statement Importance
• Is the foundation of the EMS
• Demonstrates management commitment
• Communicates the “environmental culture and
commitments” of the organization
• Gives the entire organization a statement to rally
around

Timing the Policy Statement
Policy statement may not be first step:
• Review your agency’s current environmentally-
related policy for adaptability
• Determine level of awareness of EMS with senior
managers and level of understanding of
importance of the policy
• Make a case for EMS first
• Use initial EMS development information to help
formulate policy

Writing the EMS Policy
Statement
• Is a short, concise statement that includes the
requirements as well as additional information to
meet stakeholder expectations
• Does not need to summarize or repeat EMS details
• Signed by senior-most management within the
defined EMS scope
• Is consistent with EMS framework and aspects
• Needs to be “ memorable” to staff

Legal and Other

Requirements
Examples of Legal
Requirements
• RCRA • NEPA
• CAA • OSHA
• CWA • Pollution Prevention
• SDWA Act
• CERCLA
• EPCRA

Examples of “Other”
Requirements
Unique to Federal Voluntary programs
Community
• Executive Orders and • Performance Track
Memoranda • LEED Certification
• Parent Agency • Energy Star facility
Policies

Identify - Initial materials
should be in place
• Identify existing permits, licenses, reports
• Use compliance programs of parent agency or
service
– Agency general counsel and legal advisors
• TEAM guide
• On line tools
• Compliance assistance materials -documents

Providing Access and
Maintaining
• Ensure easy access
– Hardcopy, web access, database
• Identify and support process to receive and
include updates
– Headquarters audit programs and other tools
including tools used by other agencies
– TEAM guide
– WEB sites and listserves
Access
• Ensures there is a process that keeps regulatory
and other information up-to-date
• Ensures that there is a process to direct any new

information to that part of the organization where
it is relevant

Process - When things
change
• Remember - when aspects change, legal and
other requirements need to be checked!
• Recognize relationship between aspects,
activities and legal or other requirements
• Recognize relationship between regulated
activity process owners and requirements

Aspects, Impacts, and

Significant Aspects
Specific Benefits
• Prompts your organization to identify issues not
typically managed; particularly non-regulated
issues
• Integrates environmental issues into operations
• Makes for proactive planning

Environmental Aspects and
Impacts-ISO 14001 Definition
ENVIRONMENTAL ASPECTS
Elements of an organization’s activities, products or services
which can interact with the environment. (For example:
wastewater discharges, air emissions, resource consumption,
energy usage, ecosystem alterations, etc.)
ENVIRONMENTAL IMPACTS
Any change to the environment, whether adverse or beneficial,
wholly or partly resulting from an organization’s activities,
products, or services (based on the aspects, for example: air
emissions impacts the air by degrading the air quality).
ISO 14001 requires
organizations to:
• Develop procedures to identify environmental
aspects in order to determine those which have or
can have significant impact on the environment
• Keep aspects information up-to-date (regularly,
and whenever changes occur), not once and done.
• Necessary records will include aspects lists, and
significant aspects list

Role of Aspects in the EMS
• Significant aspects drive the EMS and are a subset
of the full list of aspects
• EMS is designed to identify, control, manage, and
improve upon the significant aspects
• Compliance with Legal and Other Requirements is
a part of the system that does relate to the aspects
• Elements such as operational control (procedures
and work instructions), training, monitoring and
measurement, emergency planning, and setting
objectives all depend on significant aspects.
More on Environmental
Aspects
• Aspects are “cause”, impact is the “effect”
• Control and influence of aspects is a factor
• Aspects can be:
• direct or indirect
• normal, abnormal, or emergency
• past, present, or future
• Aspects address not only waste stream, but
resource consumption, energy, and other “non-
traditional” factors (noise, odor, visual)

Going About the Aspects
Process
• Identify who and how this will be done (aspects
procedure)
• List and characterize activities, products services
• Identify aspects and impacts for each A/P/S -Tap
into your knowledge base!
• Determine significance
• Maintain records

Activities, Products and
Services
• This is where you describe what you do at your
facility – mostly “activities” for Feds
– Consider mission – what ‘facility’ is designed
to do - e.g. visitor center
– Consider activities that support the mission –
e.g. vehicle maintenance
– Consider actions that are both regulated and not
regulated e.g. commuting to work

Aspect Analysis - Examples of
Activities
• Mission related operations
• Maintenance
• Motor vehicle fleet operations
• Wastewater treatment
• Solid waste handling and disposal
• Raw material and chemical handling
• Bulk storage of fuels
• Administrative and employee activities
• Engineering
• Purchasing
List Aspects
• Can sort and organize aspects, for example:
– Releases to air
– Water consumption, pollution
– Land contamination
– Use of raw materials, natural resources
– Other local environmental, community issues
• Will be able to “re-sort” later to better manage the
aspects

Examples of Aspects
• Aspect: • Not an aspect:
– Waste generation – Improve air quality –
– Material usage this is an objective
– Fuel usage – P2 – this is an
objective
– Air emissions
– Vehicle maintenance
– Chemical – this is an activity
consumption
– Water pollution – this
– Energy is an impact
consumption

Examples
Activity, Product, or Service Environmental Aspect
• Aircraft operations • Jet fuel consumption
• Jet fuel releases (potential)
• Noise generation
• Bus transportation and • Gasoline consumption
maintenance • Electricity consumption
• Solid waste generation
• Water consumption
• Waste water generation

Examples
• Vehicle maintenance • Hazardous waste generation
• Gasoline consumption
• Noise generation
• Electricity consumption
• Release of volatiles

Examples
• Store • Raw material consumption
• Fuel consumption for transport
• Food waste generation

• Cafeteria
• Release of ammonia from
refrigeration equipment
(potential)
81
Examples
• Office work • Electricity consumption
• Release of ozone depleting
substances in air cooling
units (potential)
• Heavy metals “use” in
computers

Examples
• Cleaning offices • Hazardous material release
• Playing field upkeep
(golf course, softball field, • Runoff from pesticide usage
parade ground) • Gasoline consumption
• Grass clipping generation

Identify the Impacts of Aspects
• Once the aspects are identified, you must identify
the impact(s) associated with each one.
• This can be done using the same process you used
for aspects, except there might be more
involvement of environmental staff to assess
impacts
• List impacts along with aspects

Examples of Aspects & Impacts
Aspects Impacts
• Air emissions (exhaust) • Air quality degraded
• Water consumption • Water resource depleted
• Fuel release (accidental spills) • Storm water contaminated
• Fuel release (accidental spills) • Soil contaminated
• Noise generation • Area nuisance
• Energy consumption (lights • Increased CO2 from coal-
left on) fired power plant emissions
• Paper recycled • Landfill space conserved, raw
materials conserved

Determine Significant Aspects
• A significant aspect is one that has or can have a
significant impact on the environment (you define)
• Site selects the criteria for significance rating and cutoff
value
• Significance can be determined by numeric cutoff value
or subjective assessment based on yes/no answers
• Significance could be tied to: environmental
degradation concerns, natural resource concerns,
regulatory or legal exposure, concerns of interested
parties

EMS Requirements
• ISO 14001 uses “significant” aspects and impacts
as the basis for developing objectives and
preparing programs.
• The organization chooses which aspects are
“significant,” based on applying their own criteria,
to the related impacts. However, once significant,
the EMS must address the aspect.
• Process and criteria for significance described in
procedure.
Many Methods for Determining
Significance Criteria
• Staff judgment
• Risk Assessment
• Organizationally-derived criteria and/or hybrid
approaches based on staff judgment and risk
assessment
• Key is to be consistent, and in line with “reality
check” – are you capturing what makes sense?
• Criteria must relate to environmental impact

Examples of Significance
Criteria
• Magnitude - How big of a problem is it?
– Global, regional, local?
• Severity - How bad will it get?
• Probability - How likely is it to occur?
– Daily, weekly, monthly, annually, in emergencies, only
when a certain event happens, when a new project
starts?
• Regulated?
• Of concern to interested parties?

Applying the Criteria
• Each aspect must be evaluated in terms of the
criteria
• Significant ones listed
• Each time a new aspect enters the system for
whatever reason, it must be evaluated for
significance
• ALL significant aspects must be carried forward
into the system

Identify
Aspects
no Remains on
Significant?
aspect list
yes
Significant
aspect
No, or yes
but want to
Objectives and do more? Under yes Operation
targets Control? controls
Address No (still must have controls)

now?
Yes
EMPs, and
Deployed
Operational
in EMS
Control 91
Setting Objectives and

Targets

Definition
An EMS objective is an overall goal that reflects the
environmental policy statement set by the
organization.
An EMS target is a detailed, measurable

performance metric related to the objective.

Examples
Objective: Reduce use of hazardous chemicals
Target: Reduce use of EPA listed Toxic Release
Inventory chemicals by 5% annually based on
calendar year 2001 use figures

Examples
Objective: Reduce energy consumption
Target: Reduce energy consumption by 25% by the
year 2005 based on a 2000 calendar year baseline.

Examples
Objective: Improve environmental compliance
Target: Reduce the number of internal environmental
compliance audit findings by 50% on an audit-to-
audit basis.

Examples
Objective: Reduce transportation congestion
Target: Increase the number of employee-days of
mass transit use by 50% by the year 2006 based on
a 2002 calendar year baseline.
Target: Purchase 25 bicycles for use within the
facility by the year 2004.

ISO: Organizations Shall
Consider
• Policy
• Legal and other requirements
• Significant environmental aspects
• Technological options
• Financial, operational and business requirements
• Views of interested parties

Setting Objectives and Targets
• Begins with initial planning data
– Policy
– Legal and other requirements
– Significant environmental aspects
• Consider
– Technological options
– Financial, operational and business requirements
– Views of interested parties

• Other drivers for consideration
– Agency mission
– Agency / management priorities
• This is where you can reflect “reality”
– What can be done
• You will do this again

• Some organizations set compliance as an objective
to help remind them that the remainder of the
system reflects that commitment
• Significant aspects can be deferred if they are
controlled and get no worse because of their
deferral

Targets - How aggressive?
• It depends:
– Stretch targets - you may not meet them but
trying may get you further
– Minimal targets - you will get there - likely to
only maintain status quo - little improvement
• Be Realistic: you may need additional info to
address ability to measure success towards
objective

REMEMBER
• Setting objectives and targets must be true to
policy statement commitments - pollution
prevention, continual improvement and
particularly compliance with regulations, are not
negotiable considerations
• Objectives and targets drive your management
plan
• You will do this exercise again and again ...

Setting objectives and targets;
the process
• Prepare summary of issues to be considered
– community concerns
– agency/ management priorities
– cost data
– future missions of facility or agency
• Provide information to decision makers

Considerations
• Use what will work best but keep in mind:
– You will need buy-in from management AND
the organization
– The objectives and targets selected will be the
basis for the environmental management
program for this cycle

Closing the Loop
• Objectives and Targets must ultimately be
established at each relevant function and level of
the organization
• Targets identify how progress will be measured

The Environmental
Management Program

Program
The Management Program defines how the
Objectives and Targets are to be achieved -
including:
– Assignment of responsibility at each relevant
function and level - the who
– Description of means - the how and what
– Identification of time frame - the when

Assignment of Responsibility:
• Function
– Reflects relationship between activity and
impact - ensures that impact is addressed where
it occurs
– Reflects support structure to ensure program is
enabled - procurement, budget, training

Assignment of Responsibility:
• Level
– Ensures that program reflects and recognizes
hierarchy and structure of the organization
– Reflects necessity of accountability -
Organizational levels above direct process are
generally supervisory and management and
must be engaged

Identification of Means
• The “how” an organization intends to achieve a
given objective and target
– Will reflect the activity(ies) that has prompted
the “significance” and Objective and Target
determination
– Will define what is to be done to manage and
improve processes to address the ongoing or
potential impact of the activity

Definition of Time-frame
• Simply the schedule for addressing the objective
and target
– Should reflect temporal nature of activities
prompting target - how soon can things be
altered
– Recognize the ability to address both short and
long-term issues as well as ongoing
responsibilities

Example
Objective: Increase solid waste diversion
Target: Increase to a 60% diversion rate for all solid
waste by the year 2005 based on a 40% diversion
rate in 1996.

EMP - Example
EMP - Increase recycling at cafeteria
Function - Cafeteria tray handlers, cafeteria
purchasing agent, facility solid waste handler
Level - In addition to above - cafeteria line
supervisor and manager, budget officer, and
facilities manager

EMP - Example
Means - Purchase more recyclable containers, post
signs and improve disposal behavior - separate
and recycle more cans and bottles
Time-frame - Starting next purchasing cycle and
targeting to reach 10% annual reduction

EMP - the Process
• Begin with Objective and Target and activities list
that drives significance determination
• Determine necessary changes to activity to address
impact and draft a means to achieve
• Determine who is directly and indirectly linked to
the impact - who are the process owners?

EMP - the Process
• Determine others that affect or enable the process
or activity - identify their roles and how the
organizational structure provides accountability
• Determine factors affecting time-frame for the
activity or process and factors that may control
changes

EMP - the Process
• Develop metrics that reflect target to allow
“checking”
• Develop program ensuring that individuals critical
to implementing change are included
• Review information to identify gaps - ensure
connections between means, responsibilities and
schedule are each identified and addressed

New Developments
• The EMP must be established and maintained.
– Changes in activities or other new
developments that affect Objective and Targets
must be reflected in the EMP
– Since aspects must be kept up-to-date - changes
will flow to EMP

EMP Implementation
• EMP may be stand alone or integrated into
existing planning processes
– Important to ensure that wherever it lands it
will be effective
– Important that those responsible for
implementation are aware of ensuing change
• Ensure that Management embraces the EMP!

Initial Awareness Training

Why EMS Awareness Training
• The initial stages of the EMS depend on
individuals within the organization
– The EMS Team will include a range of
representatives from within the organization
– Information gathering will depend in part on
contributions from across the organization
– Something new - people need to know
• Knowledge and understanding build ownership

Why Employee Awareness?
• The EMS is deployed by the practitioners
– Practitioners are more aware of the day-to-day
impacts of their activities than anyone
– Practitioners know the best improvements
• Ultimately, the Standard requires awareness of the
impacts of the organization’s activities
– Start the process

Awareness Training
Process
• Process similar to obtaining management support
– Recognize issues important to all entities within
the organization
• Mission
• Improved health, safety and security
• Improved efficiency
• Improved environmental footprint
• Don’t overwhelm
Awareness Training
Process
• Timing - Early enough to facilitate gap analysis
and other early stages of EMS
• Support - Ensure adequate management support -
authority and responsibility
• Message - Like Management, reflect issues of
importance to audience
• Presenter(s) - Ensure adequate knowledge of EMS
elements

Awareness Training
Process
• Keep it simple
• Goals is to inform and solicit assistance
• Use familiar tools
– Email
– Cafeteria notices
– Managers briefings
• Remember - this is the initial effort

EMS Conformance Audit

System Audit
A systematic and documented verification process of

objectively obtaining and evaluating evidence to
determine whether an organization’s environmental
management system conforms to the environmental
management system audit criteria set by the organization,
and for communication of the results of this process to
management.

EMS Audits
• Purpose of an EMS Audit
– Does the system conform to set criteria?
– Has EMS been properly implemented, maintained?
– Provide information to management and
organization to allow continual improvement
• Addresses all of EMS (documentation and
implementation)
• Not a performance audit or a compliance audit

Purpose of an EMS Audit
• Evaluates conformance of EMS to framework,
policy commitments
• Addresses management components
• Doesn’t explicitly address compliance
• Includes all personnel and activities associated
with significant impacts

What do you need to do?
• Develop audit procedure(s) and programs that
describe the “when, how, who, and where” of how
the EMS auditing will be done
• Conduct audits
• Keep proper records
• Feed audit information into rest of EMS

Audit Outcomes
• Assessment tool to provide for corrective action
and continual improvement of system- which
leads to improved performance
• Report to management

Management Review
Management Review
• Specific requirement of ISO 14001; to occur
periodically and must include top management
• Distinct from checking or EMS audit
• Designed to ensure ongoing and practical
involvement by top management
• Essential part of management commitment and
continual improvement

Management Review
Components
• Full system overview
• Status of objectives and targets
• EMS Performance
• Audit findings
• Evaluation of environmental policy

Towards Continual
Improvement
• Identify areas for improvement of EMS
• Review and approve corrective or preventive
action plan
• Verify effectiveness of action plans
• Make changes to procedures
• Add or adjust Objectives and Targets
• Revise Environmental Policy
• Provide support and resources

Ensuring Effective
Management Reviews
• Develop a procedure and schedule; with set
agenda, sign in process, minutes, and follow up
action items
• Make sure top management attends
• Keep good records
• Ensure you follow up!!!!!!

Synchronizing Planning
with the Other Elements
Deploying the EMS
Plan Do Check Act
Review Policy

Action
Implementation &
Control

Organization & Capabilities & Controls
Accountability Communications
Document
Control
Training,
Awareness and
Competence
Operational Control
Structure and
Responsibility
Communication
Emergency
Preparedness and
Response
• Structure and responsibility - define general
responsibility
• Training, awareness and competence - train to
policy, environmental impacts
• Communication - inform relative to aspects and
the EMS
• EMS Documentation - develop, maintain and
provide access to core directions

• Operational control - provide standard direction to
address impacts and goals
• Emergency preparedness and response -provide
direction to address extraordinary situations

Action
Non-conformance,
Monitoring and Corrective and
Measuring Preventive Action Records
Periodic Internal EMS Audits

Action
• Monitoring and measurement - determine if the
EMS is working, goals are being met and
compliance is assured
• Non-conformance - define responsibility for
addressing issues raised from monitoring and
measurement
• Records - develop and maintain body of
knowledge from EMS

Action
• EMS audit - determine if EMS is properly
developed and deployed

Management Review
To Assess the
• suitability,
Take account of: • adequacy, and
• audit findings • effectiveness of the EMS
• progress records on objectives
changes to facilities
• changes in activities,
products or services In order to determine the need
• changes in technology for change and improvement to:
• concerns of interested parties • the environmental policy
• other relevant information • the objectives and targets
• other elements of the EMS

EMS Conformance Auditing

System
The part of the overall management system that includes

organizational structure, planning activities,
responsibilities, practices, procedure, processes and
resources for developing, implementing, achieving,
reviewing and maintaining the environmental policy.

System Audit
A systematic and documented verification process of

objectively obtaining and evaluating evidence to
determine whether an organization’s environmental
management system conforms to the environmental
management system audit criteria set by the organization,
and for communication of the results of this process to
management.

EMS Audit
• Not a compliance audit
• Done by those with EMS auditing
training/experience
• Periodic “snap-shot” assessment to verify system

Internal vs. External Audits
• Internal audits (First Party audits) are those done by
participants of the EMS being audited (can be
employees, or consultants as agents of the
organization)
• Second party audits are those done by auditors from
outside the EMS in question (but could be from same
organization)
• Third party audits are done by independent, registrars
• In all cases, audit should cover same elements!!!!

Certification vs. Self
Declaration
• In both cases, a representation is made to outside
parties of conformance to EMS criteria.
• Certification is done by accredited, third party
registrars
• Self-Declaration is any other claim of
conformance other than certification
• Self-Declaration should be more than internal
EMS audit

EMS Auditing and ISO
• ISO created companion auditing guidance
standards (14010, 14011, 14012 (soon to be
19011), but these are not required for certification
• Registrars must adhere to these at a minimum
• ISO issues guidance to certification and
accreditation bodies (but can be used to guide self
declaration programs)
• US accrediting body is ANSI-RAB

EMS vs. Compliance
vs. EMR Auditing
• Different criteria- EMS looks at system,
compliance looks at regulatory requirements
• EMS audit is a system, or process audit, a
compliance audit looks at compliance
performance (compliance status), EMR looks at
pieces of the system or a very broad perspective

Self Declaration and EO 13148
• Protocol developed by EO Workgroup
• EMS verification procedures will rest with each
Agency/Bureau
– Procedures due by December 31, 2004
– Updated at least every five years
• Procedures will require an independent basis
• Facilities may self declare prior to procedures
using protocol guidance

Agency Self Declaration
Procedures
• Will include
– Selection and direction for use of evaluation
guide
– Frequency of internal evaluations
– Requirement for management declaration
– Frequency of independent review
– Makeup of review team including qualifications
of independent reviewers
Resources
• www.ofee.gov - EMS section - slides,
presentations, briefing papers
• http://p2library.nfesc.navy.mil/ems/index.html
Exceptional EMS tools - including roadmap and
decision assistance
• www.epa.gov/ems General tools - Federal facility

site being upgraded

Environmental Management System Training: United States Forest Service July 6, 2004

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Environmental Management

United States Forest Service

Ed Pinero, Acting Federal Environmental

EMS Implementation Workshop 2

EMS Implementation Workshop 3

EMS Implementation Workshop 4

EMS Implementation Workshop 5

EMS Implementation Workshop 6

• “Establish and Maintain”

• “Responsibility and Authority”

EMS Implementation Workshop 7

Checking & Corrective Planning

EMS Implementation Workshop 8

EMS Implementation Workshop 9

Periodic Internal EMS Audits

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Checking & Corrective Planning

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• Based on a PLAN-DO-CHECK-ACT framework

• An approach that reflects the relationship between

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• Focused solely on regulatory compliance

• An effort solely for the environmental shop

EMS Implementation Workshop 20

• Better communication of environmental issues -

• Positive effect on regulatory compliance and

EMS Implementation Workshop 21

• Flexibility and opportunity to correct

• Identification of risk and prevention of problems

EMS Implementation Workshop 22

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• This helps minimize the “bandage” syndrome,

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Selecting and Preparing the

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• Depend on Team champions

• Don’t underestimate effort needed and ensure

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Defining Your Fenceline:

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EMS Implementation Workshop 48

Gap Analysis and