EPA EMS General Awareness Training

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 Policy Planning Implementation and Operation Checking and Corrective Action Management Review

EMS Flow Policy Review Planning 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

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

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 consider • significant environmental aspects • legal and other requirements • technical options • financial and operational requirements • views of interested parties

Environmental Management Program Allows the organization to achieve its objectives and targets. An effective program should include • timeframe • methods to achieve objective • designation of responsibilities

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

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 Responsibility • Training Awareness and Competence • Communication • EMS Documentation • Document Control • Operational Control • Emergency 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 entail • potential environmental impacts of their activities • importance of conforming with the organization’s EMS • their roles and responsibilities for EMS compliance • consequences 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 EMS • identify the location of related documents

Document Control All EMS documents should be • readily located • available 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 procedures • Specify operating/performance criteria in procedures

Emergency Preparedness & Response Establish and maintain procedures for • identifying potential accidents • responding to emergencies and accidents • preventing and mitigating emergencies

Emergency Preparedness & Response (cont.) Preparedness and response procedures should be • maintained and updated • periodically tested

IV. Checking & Corrective Action Procedures that establish requirements for monitoring the EMS and correcting deviations including • Monitoring and measurement • Nonconformance and corrective and preventative actions • Records • EMS 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

Records Procedures must be maintained for the identification, maintenance and disposition of environmental records. Records should • be legible, identifiable and traceable to the activity, services or product involved • be stored and maintained to be easily retrievable and protected from damage, deterioration or loss • have the retention time marked and recorded

EMS Audit Establish and maintain programs and procedures for audits to • determine if the EMS conforms with all requirements • determine if the EMS is properly implemented and maintained • provide 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.

V. Management Review Top management must Ensure EMS continues to be • suitable • adequate • effective Address possible changes to policy, objectives and other elements

Benefits of EMSs

Benefits of an EMS • Cost Savings • Reduced Liability/ Improved Compliance • Continued 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 Tools In 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 Manufacturer 70% reduction in waste disposal costs • Ford Company Projects a savings of hundreds of thousands of dollars over a five-year period.

Reduced Liability/ Improved Compliance • 3M Significant reduction in fines and violations • Apple Computer Improved compliance Legal and ethical obligations are met in a more timely fashion

Continued Improvement in Environmental Performance • Financial Services Institute reduced electricity, heat & paper consumption • Xerox 13% reduction in energy consumption • Electronic Controls & Communications Company 85-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 Manufacturer Employees are more willing to mention potential environmental improvements.

An Effective EMS Integrates Environmental Management into Everyday Business Activities

EPA EMS General Awareness Training