Managing an EMS With Curtailed Resources

1. Managing an EMS With Curtailed Resources

2. Practical Advice for Managing EMSs in Today’s Economy • Many of us were not not originally environmental scientists • Many of us inherited our jobs • Many of us perform several other jobs • Environmental is sometimes out-prioritized by other domains • Many employees don’t understand “environmental” • Things got much worse when the recession hit

3. THE GOOD NEWS: • We all want to protect our environment • Methods exist for doing a good job environmentally despite these challenging circumstances

4. Cleaning up Issues as HSE Specialists Leave • Understand the scope – get macro data • Understand consequences • Immediate health hazards • Clear violations of regulations • Potentially serious pollution • Big fines • 14001 non-conformances • Risk to certificate renewal • Loss of sales • Work Instruction violations: CARs • Bad housekeeping: more aggressive audits or inspections

5. Cleaning up Issues as HSE Specialists Leave • Triage your issues – find out what your most risky environmental aspects are: • Hazardous waste? • Storm water? • Used oil? • Reporting? • Walk through with someone who knows some environmental – inside AND everywhere outside • Maintenance • Savvy operators • Facilities engineering • Quality • Manage your time to address risky items first

6. Document for a Smooth Transition - Crucial as Downsizing Occurs • Give experts time to document and train others before they go • If Work Instructions are incomplete, request a series of cheat sheets: • Hazardous waste procedures • Outfall sampling procedures • Used oil recycling • Universal waste procedures • Environmental reporting files • Filing system indexes

7. Establish and Maintain an Environmental Filing System • Why? • Reduce risk in audits and inspections • Save time finding data daily • Spend less of consultants’ time looking for your data • Simplify delegating tasks • Stand-alone documentation survives turnover of employees

8. Establish and Maintain an Environmental Filing System • Get a fireproof, locking file cabinet for paper, permits, certifications, training log signatures • Establish a detailed outline (don’t hesitate to copy someone else’s): • Compliance top level: water, air, RCRA, CERCLA, EPCRA, etc. • Conformance top level: elements of 14001 standard • Mirror the filing system digitally: • Server directories • Intranet applications – BEWARE THE I.T. GUYS • Email folder structures • Back up hard drives, servers, email

9. Reduce Paperwork in 14001 Compliance • Interpretations of ISO 14001 conformance have been modernized • ANAB (governing body) re-reinterpretations of standard promote more effective EMSs • Focus is on results, less time wasted on paperwork • Increase your EMS’s effectiveness with LESS time investment • Remember: entire ISO 14001 is 9 pages long • Intended to be robust • Compliance methods subject to interpretation • You are your registrar’s customer

10. Revise Paper-intensive Conformance Procedures • Replace numerical schemes for assessing significance of environmental aspects with criteria • Significant if training, monitoring or measurementand controls are needed • Significant if had recent issues with aspect • Labor-intensive “competency” evaluation • Take credit for all forms of competency assessment: • Routine supervisory interaction • Other existing performance measures

12. Utilize your Existing Procedures to Conform to 14001 • Don’t internally over-audit • Delegate internal auditing • Audit significant aspects, elements in manageable chunks • Avoid onerous management review meetings • Implement a system of meetings – not one huge meeting • Include all relevant management exposure to EMS

14. Train for Effectiveness • Remember who your audience is • In many cases they are legally required to have awareness only • You are obligated to make them environmentally effective • Reduce time spent on esoteric topics • Focus on training that will help them comply with regulations • Delegate some training to supervisors, line chiefs

15. Make Sure Trainees Internalize the Message • Increase the frequency of exposure to topics • Use supervisor safety briefings • Spread training across the year • Infer training priorities from your auditors, inspectors • Assess real competency, not just test-taking ability

16. Managing Environmental and Safety • Many small facilities combine functions – it’s unavoidable • Many areas of safety / environmental overlap • Hazard Communications • Management systems – VPP, SHARP • Safety documentation and file organization is as important as environmental – for same reasons • Use OSHA website resources • Good inspection checklist : “small business” • Good list of training topics: • BLR 7-minute safety table of contents • KellerOnline toolbox talks

17. Safety and Environmental Culture: Employees Need to Know Why They Need Both • Quality of their environment at home • Non-compliance means money out of THEIR pockets and less job security • Fines • Insurance costs • Lost new sales • Less job security • Poor product quality • Reduced quality of life due to injury

18. Your Best Hope: Use THE TEAM • Plant management • Start here • Do not proceed without management backing • Managing consultants • Write specific statements of work • Support them with good data and files to minimize your expenditures • Corporate resources • Sometimes invaluable • Sometimes irrelevant • Always: Understand and plan for their role

19. Use THE TEAM • Quality Assurance • Good for help learning 14001 • Similar methodology to 9000, TS • “Show Me the Shall” blog • Maintenance managers - you’re lost without them • Key technology person in plant • Learn to communicate • Pick your battles • Learn to compromise • Earn their respect • GTRI • In GA, invaluable free expert resource • Look for counterparts in your state • Confidential is good

20. Use THE TEAM • HR • Closer to environmental than you may think • Environmental incidents require same HR support as safety: • Investigation • Accountability • Vendors • Reporting quantities • Tier II usages, maximums • Ozone depleting substances (refrigerants) • Waste haul records • Most important: the employees

21. EMS – Environmental MANAGEMENT System • This job is managing • Management skills required • People skills • Time management • Persuasion • Prioritization • Investment of time up front • Personal organization • Organizational dynamics • Contract management • 80% management, 20% technical • THANK YOU FOR YOUR TIME!

22. CON UNDERWOOD Con Underwood Consulting, LLC 706-338-9096 conunderwood1@gmail.com conunderwood.com