An Environmental Management System (EMS) is a set of processes and practices that enable an organization to reduce its environmental impacts and increase its operating efficiency. Basic Elements of an EMS:Reviewing the company's environmental goalsAnalyzing its environmental impacts and legal requirementsSetting environmental objectives and targets to reduce environmental impacts and comply with legal requirementsEstablishing programs to meet these objectives and targetsMonitoring and measuring progress in achieving the objectivesEnsuring employees' environmental awareness and competenceReviewing progress of the EMS and making improvements
An Environmental Management System (EMS) is a framework that helps a company achieve its environmental goals through consistent control of its operations. The assumption is that this increased control will improve the environmental performance of the company. The EMS itself does not dictate a level of environmental performance that must be achieved; each company's EMS is tailored to the company's business and goals.
An EMS encourages a company to continuously improve its environmental performance. The system follows a repeating cycle (see figure). The company first commits to an environmental policy, then uses its policy as a basis for establishing a plan, which sets objectives and targets for improving environmental performance. The next step is implementation. After that, the company evaluates its environmental performance to see whether the objectives and targets are being met. If targets are not being met, corrective action is taken. The results of this evaluation are then reviewed by top management to see if the EMS is working. Management revisits the environmental policy and sets new targets in a revised plan. The company then implements the revised plan. The cycle repeats, and continuous improvement occurs.
1. Commitment and PolicyTop management commits to environmental improvement and establishes a company environmental policy. The policy is the foundation of the EMS.
2. PlanningA company first identifies environmental aspects of its operations. Environmental aspects are those items, such as air pollutants or hazardous waste, that can have negative impacts on people and/or the environment. A company then determines which aspects are significant by choosing criteria considered most important by the company. For example, a company may choose worker health and safety, environmental compliance, and cost as its criteria. Once significant environmental aspects are determined, a company sets objectives and targets. An objective is an overall environmental goal (e.g., minimize use of chemical X). A target is a detailed, quantified requirement that arises from the objectives (e.g., reduce use of chemical X by 25% by September 1998). The final part of the planning stage is devising an action plan for meeting the targets. This includes designating responsibilities, establishing a schedule, and outlining clearly defined steps to meet the targets.The devised action plan for meeting the targets must include: Responsibility designationAn established scheduleClearly defined steps to meet targets
3. ImplementationA company follows through with the action plan using the necessary resources (human, financial, etc.). An important component is employee training and awareness for all employees. Other steps in the implementation stage include documentation, following operating procedures, and setting up internal and external communication lines.Follow throughEmployee awareness and trainingDocumentationStandard Operating ProceduresCommunication
4. EvaluationA company monitors its operations to evaluate whether targets are being met. If not, the company takes corrective action.5. ReviewTop management reviews the results of the evaluation to see if the EMS is working. Management determines whether the original environmental policy is consistent with company values. The plan is then revised to optimize the effectiveness of the EMS. The review stage creates a loop of continuous improvement for a company.
Environmental Management System Development
To provide up-to-date, controlled documentation of all programs, procedures, documents, etc. To provide user-friendly, around the clock access to ensure proper implementation of all EMS programs and procedures. Proactive approach to help a company address regulatory demands systematically and cost-effectively
Policy and CommitmentReview Planning Continuous Improvement Evaluation Implementation
Example Company EHS policy is dedicated to: Meeting or exceeding all regulatory requirements Pollution Prevention wherever feasible Continuous Improvement Consider Environmental factors when making purchase and operational decisions Establish, track and review specific goals
Identify Environmental Aspects E.g. air pollutants Determine most important to company E.g. worker health & safety, compliance and cost Legal and Other Requirements Objectives and Targets Objectives – Overall Goal, e.g. minimize use Target – Detailed, Quantified, e.g. minimize by 10% by specific date Management Actions to Support Objectives and Targets
Structure and Responsibility Training, Awareness, Competence Communication EMS Documentation Document Control Operational Control Emergency Preparedness and Response
Example EMS Structure/Hierarchy Policy; System Description Operational and Management Procedures Standard Operating Procedures or work instructions Plans and Reference Documents Records
Air Pollution Control Programs Air Emissions Standard Risk Permit Operating Management (Title V Permit) Procedures Plan Prescribed Refrigerants ComplianceMonitoring and Management Plan Analysis Procedure
CLEAN AIR ACTExample Applicable Legislation: Title V Operating Permit Program Amendments of 1990 ○ National Ambient Air Quality Standards (NAAQS) ○ National Emission Standards for Hazardous Air Pollutants (NESHAP) CAA Title I Section 112 40 CFR Part 63 - Maximum Achievable Control Technology (MACT) - the 1990 amendments to the CAA changed EPAs approach to regulating HAPs, so that NESHAPs are now established based on the "maximum achievable control technology" (MACT) for an industry group or source category (for example, hazardous waste combustors). Risk Management Plan Title III of CAA, 40 CFR Part 68
Wastewater Oil Spill Discharge Prevention, Contr Permit ol and (NPDES Permit) Countermeasures Plan Stormwater Monitoring and Best Sludge Bulk Liquid Pollution Recordkeeping Drum Handling andManagement Management Prevention Data Management StoragePractices Plan Plan Procedures Plan
CLEAN WATER ACTExample Applicable Legislation: Code of Federal Regulations - Title 40 - Protection of Environment Chapter I - Environmental Protection Agency ○ Subchapter D--WATER PROGRAMS NPDES (CWA Section 402) ○ 40 CFR Part 122 Toxic Pollutant Effluent Standards ○ 40 CFR Part 129 Water Quality Standards ○ 40 CFR Part 131
Waste Management ProgramsHazardous Waste Spill Solid Waste PollutionPrevention, Control & Management Prevention PlanCountermeasure Plan Waste Analysis Recordkeeping and Reporting
WASTE MANAGEMENTExample Applicable Legislation: Resource Conservation and Recovery Act (RCRA) Non-hazardous waste/Solid waste 40 CFR Part 239-259 Hazardous waste 40 CFR Part 260 [-279] ○ Details – Part 261 Ignitable Waste (I) Corrosive Waste (C) Reactive Waste (R) Toxicity Characteristic Waste (E) Acute Hazardous Waste (H) Toxic Waste (T) = Characteristic waste Specific wastes such as, slop oil emulsion solids from the petroleum refining industry [K049] = Listed waste Pollution Prevention Act Toxic Substances Control Act
Safety and Occupational Health and Respiratory Hearing Radiation SourceEnvironmental Industrial Hygiene Protection Conservation Control Program Programs Program Program Program Hazardous Substances Hazard Workplace Management Exposure Fit-testing Communication Sampling [Asbestos, PCB, Solven Standards Database ts, Bloodborne Program Program Pathogens MSDS Respiratory Protection Against Airborne Lead Contractor Database Program Safety Company Industrial Emergency and Hygiene Disaster MSDS Database Response New Product Embryo-Fetus Approval Protection Procedure Chemical Inventory MSDS Update Procedure
WORKPLACE ENVIRONMENTAL HEALTHMANAGEMENTExample Applicable Legislation: Occupational Safety and Health Act Occupational Safety and Health Administration (OSHA) National Institute for Occupational Safety and Health (NIOSH) CFR Title 29 Part 1910 - Labor ○ Subtitle B--Regulations relating to Labor, Chapter xvii--OSHA, Department of Labor The 1910 Standards cover a myriad of topics: Personal Protective Equipment (PPE), Occupational Noise Exposure, Emergency Planning and Response…
Other Environmental Program ManagementCorporate Citizenship EHS Management EMS Manual Program Tier II Reports [Inventory of Programs, Procedures Environmental Calendar Substances for Compliance Reviews Policy and work instructions and Training Schedule Emergency Responders] Descriptions of Roles, Toxic Release Inventory Responsibilities, Lists of Objectives and Reports Authorities and Lines of Targets Communications Community Relations Equipment Calibration Environmental Aspects and Communications Procedure and Impacts Inventory
OTHER ENVIRONMENTALPROGRAM MANAGEMENTExample Applicable Legislation: Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Hazardous Substances [Superfund] Superfund Amendments and Reauthorization Act (SARA) Emergency Planning and Community Right-to- Know Act (EPCRA) [also known as SARA Title III] ○ Tier II Report [SARA 311/312] – Inventory of Substances for Emergency Responders, 40 CFR Part 370 ○ Toxic Release Inventory Report – [SARA 313] Tier III Report
Monitoring and Measurement E.g. Use of Checklists to determine compliance with applicable regulations Plating bath temperature Amount of hazardous waste generated Amount of solvent used for parts cleaning Nonconformance, Corrective and Preventative Action Records
EMS Audits Management Review Determines if original policy is consistent with company values Possible revisions to optimize effectiveness This final review stage creates a loop of continuous improvement for a company
Environmental Management System (EMS) Example This presentation is an Environmental, Safety and example and not site Health Programs, Plans specific and Procedures overlap Each company - industry - For example, Drum site requires specific Management is a stand alone SOP, but also a part programs, plans, practices of the OSPCC Plan and procedures Again, Best Management Intended for an overview - Practices (BMP) is stand example - general idea - alone, but also part of the demonstration purposes NPDES permit only OSHA 1910, in particular, addresses health and safety, but overlaps with environmental aspects ○ i.e. HazCom, Hearing Conservation, Respiratory Protection, PPE usage…