Stepping into EMS

Developing an environmental management system is an organization-wide undertaking that provides tangible results.

Building an Environmental Management System (EMS) might sound like an overwhelming task for a smaller organization, but it need not be. Taken in steps it’s a job that small- and medium-sized organizations can tackle. This article takes you through those basic steps:
■ Plan: Identifying environmental aspects and establishing goals
■ Do: Training and operational controls
■ Check: Monitoring and corrective action
■ Act: Progress reviews and making needed changes to the EMS

Plan
Building an EMS might sound like an overwhelming task for a smaller organization, but it need not be. Time and resources are limited in any organization, and it is important to use resources wisely.

The information below illustrates 10 steps in the EMS planning process. Taking the time to figure out what needs to be done, how to do it, and who must be involved will pay big dividends down the road.

Step 1. Define organization’s goals for EMS: The first step in EMS planning is to decide why you are pursuing development of an EMS. Are you trying to improve your environmental performance (for example, to comply with regulations or to prevent pollution)? Write your goals down and refer to them frequently as you move forward. As you design and implement the EMS, ask “How will this task help us to achieve our goals?” This is a good time to define the project’s scope (i.e., What is the “organization” that the EMS will cover? Is there one location or multiple locations? If more than one, should we “pilot” the EMS at one location and implement it at other locations later?)

Step 2. Secure top management commitment: One of the most critical steps in the planning process is gaining top management’s commitment. Management must first understand the benefits and what it will take to put an EMS in place. To develop this understanding, explain the strengths and limitations of your current approach and how those limitations can affect the organization’s financial and environmental performance. Management also has a role in ensuring that the goals for the EMS are clear and consistent with other organizational goals. Management’s commitment should be communicated across the organization.

Step 3. Select an EMS champion: Not all small- or medium-sized organizations have the luxury of choosing among multiple candidates, but your choice of project champion is critical. The champion should have the necessary authority, an understanding of the organization, and project management skills. The champion should be a “systems thinker” (ISO 9000 or ISO 14001 experience can be a plus, but is not necessary), should have the time to commit to the EMS-building process and must have top management’s support.

Step 4. Build an implementation team: A team with representatives from key management functions (such as engineering, finance, human resources, production and/or service) can identify and assess issues, opportunities and existing processes. Include contractors, suppliers or other external parties as part of the project team, where appropriate. The team will need to meet regularly, especially in the early stages of the project. A cross-functional team can help to ensure that procedures are practical and effective and can build commitment to and “ownership” of the EMS.

Step 5. Hold kickoff meeting: Once the team has been selected, hold a kickoff meeting to discuss the organization’s objectives in implementing an EMS, the initial steps that need to be taken and the roles of team members. If possible, get top management to describe its commitment to the EMS at this meeting. The kickoff meeting is also a good opportunity to provide some EMS training for team members. Follow up the meeting with a communication to all employees.

Step 6. Conduct preliminary review: The next step is for the team to conduct a preliminary review of your current compliance and other environmental programs/systems and to compare these against the criteria for your EMS (such as ISO 14001). Evaluate your organization’s structure, procedures, policies, environmental impacts, training programs and other factors.

Step 7. Prepare budget and schedule: Based on the results of the preliminary review, prepare a project plan and budget. The plan should describe in detail what key actions are needed, who will be responsible, what resources are needed, and when the work will be completed. Keep the plan flexible, but set some stretch goals. Think about how you will maintain project focus and momentum over time. Look for potential “early successes” that can help to build momentum and reinforce the benefits of the EMS.

Step 8. Secure resources, assistance: The plan and budget should be reviewed and approved by top management. In some cases, outside funding or other types of assistance may be necessary.

Step 9. Involve employees: Ownership will be greatly enhanced by meaningful employee involvement in the development process. Employees are a great source of knowledge on environmental, health and safety issues as well as the effectiveness of current processes and procedures. They can help the project team in drafting procedures.

Step 10. Monitor and communicate progress: As you build the EMS, regularly monitor progress vis-a-viz your goals and project plan and communicate that progress throughout the organization. Communicate accomplishments and describe what happens next. Build on small successes. Keep top management informed and engaged.

Do
This stage describes a logical sequence for planning and implementing EMS elements and explains how this sequence is important in building an effective program.

A few hints to keep in mind as you go:
■ You may already have some EMS elements in place, as indicated by the review that you performed earlier.
■ Make sure to build links between elements. The effectiveness of your EMS depends as much on the strength of its links as it does on the strength of the individual elements.
■ For many EMS elements, you will need to design and implement a process. In these cases, you should consider documenting the process in the form of a procedure.

Step 1. Identify legal and other requirements: A first step in the building process is to understand legal and other requirements that apply to your products, activities and services. It is important to understand compliance obligations and how these obligations affect the overall design. For example, you might have an operation that is covered by an air quality permit or results in the generation of regulated wastes. Your program should ensure that legal requirements are addressed.

Step 2. Identify environmental aspects and related products, operations and activities: Once you understand legal requirements, you should assess how your organization interacts with the environment. Identify environmental aspects and impacts and determine which are significant. Some environmental aspects may be regulated, while others may not.

For example, if you identify the generation of a particular air emission as a significant environmental aspect, it would help to know which operation(s) generate such air emissions. It might also help to know whether these air emissions are monitored or measured in some manner.

Step 3. Define views of interested parties: Gather information on the views of your “stakeholders” or interested parties. Stakeholders may include neighbors, interest groups, customers and others. Their views might show how your organization affects the environment, how well you are meeting environmental obligations, and whether your organization is a “good neighbor,” among other things. Since you have already assessed the legal and environmental aspects, you should be in a good position to have a meaningful dialogue with these stakeholders.

Step 4. Prepare environmental policy: At this point, you should have a sound basis for developing (or amending) an environmental policy. Using the information developed in the previous three steps, your organization can prepare a policy that addresses the key issues. You should understand how well you are currently managing key issues.

Step 5. Define key roles and responsibilities: Once the environmental policy has been written, you can begin to define key roles and responsibilities. At this stage, focus on “higher-level” responsibilities, such as the roles and responsibilities of senior management, key functional leaders and environmental staff (if one exists). Once the key roles and responsibilities have been defined, gather the input of these individuals to establish objectives and targets. Responsibilities for other jobs or functions will be identified later.

Step 6. Establish objectives and targets: Objectives should be consistent with your environmental policy, pertinent legal requirements, environmental aspects and impacts, and the views of interested parties, etc.

This information will help you to determine the relevant functions within the organization for achieving objectives and targets. For example, if you set an objective to reduce hazardous waste generation by 10 percent this year, you should know which parts of the organization can achieve this objective.

Step 7. Develop environmental management programs and identify operational controls, monitoring and measurement needs: This brings us to one of the most challenging (and potentially most valuable) steps. You are ready to tackle several EMS elements simultaneously. You should have a head start on this step, since you identified operations and activities related to the significant environmental aspects (as well as existing control and monitoring processes) several steps ago.

One reason for combining these steps is that they can often overlap significantly. For example, your environmental management program for maintaining compliance with regulations could consist of a number of existing operational controls (procedures) and monitoring activities. Achieving an objective might require a feasibility study or the implementation of certain “new” operational controls.

Compile a list of your operational control and monitoring needs. As you develop your environmental management program, ask yourself the following questions:
■ How do we control this operation or activity now?
■ Are these controls adequate to meet our objectives and to ensure compliance?
■ If additional controls are needed, what types of controls make sense?
■ What type of monitoring/measurement is needed to track our progress and to ensure that operational controls are implemented as designed?

This process is usually iterative. You might need to revisit your management programs, operational controls and monitoring processes over time to ensure they are consistent and up-to-date.

Step 8. Establish corrective action, document control and records management processes: By this point, your EMS will begin to generate some documents (procedures and forms) and records (demonstrating that processes are being carried out). You will need an effective way to manage these records. Establish procedures for corrective/preventive action, document control and records management. These three processes are essentially “system maintenance” functions. You will need a process to correct problems when they occur and to manage records (such as monitoring activities).

Step 9. Establish operational controls and monitoring processes: Refer to the list of operational control and monitoring needs from Step 7. Use a template for the development of work instructions or standard operating procedures.

Employees that work in relevant operations or activities can provide support here.

Step 10. Define job-specific roles and responsibilities: Roles and responsibilities should address the specific operational controls and monitoring processes discussed above. You might want to document these in a responsibility matrix or some other form that is easily communicated to employees.

Step 11. Plan and conduct initial employee awareness: Initial employee awareness training should be conducted to promote understanding of the organization’s EMS efforts and the progress made to date. As a first step, train employees on the environmental policy and other elements of the EMS. Discuss the environmental impacts of their activities, any new/modified procedures, the organization’s objectives and targets, as well as their EMS responsibilities. If you have contractors or others who are not employees of your organization at your site, consider whether these individuals should be included in these EMS awareness sessions.

Step 12. Establish other system-level procedures: Some system-level procedures (such as the procedures for identification of environmental aspects) were developed at earlier stages of the process. At this point, you can establish any other procedures required for the EMS. These additional system-level procedures might include:
■ Employee training and awareness
■ Internal and external communication
■ Emergency preparedness and response
■ EMS auditing
■ Management review

Step 13. Prepare EMS documentation (manual): Once you have established roles and responsibilities and defined all of your system-level procedures, preparing the EMS manual should be a relatively simple matter. The manual should summarize the results of your efforts. It should describe the processes developed and define the roles and responsibilities as well as other EMS elements. It is important to describe the links among system elements and provide direction to other system documents. Keep the manual simple – there is no need to provide great detail on any particular system process.

Step 14. Plan and conduct specific employee training: Once the procedures and other system documentation have been prepared, you are ready to conduct specific employee EMS training. As a first step, identify specific training needs. Employee training should be designed to ensure understanding of:
■ Key system processes
■ Operational controls related to their specific jobs
■ Any monitoring or measurement for which they are responsible

Check
EMS should be built on the “Plan, Do, Check, Act” model so that environmental matters are systematically identified, controlled, and monitored. Using this approach will help to ensure that performance improves over time and that your goals for implementing an EMS in the first place are met. By this time, sufficient processes should be in place to begin to check your EMS. One approach is as follows:

Conduct internal audits: Once internal auditors have been selected and trained, you should design and initiate the internal auditing process. Many organizations find that it is easier to start with smaller, more frequent audits than to audit the entire EMS at once. These early audits can serve as a learning tool. Audit records should be managed in accordance with the records management process. Once the audit results are known, use the corrective and preventive action process to address any problems.

Act
Identify problems and act to resolve them. One approach is as follows:

Conduct management reviews: Use the results of your internal audits (along with other information) to conduct management reviews. Management should consider the need for any changes and assign any necessary changes. Such assignments should be consistent with previously established roles and responsibilities.

After acting on the results of management review, tasks performed in the “Plan” stage should be revisited, thus continuing the “full circle” process.

Take note
EMS should be built on the “Plan, Do, Check, Act” model so that environmental matters are systematically identified, controlled and monitored. Using this approach will help to ensure that performance improves over time and that your goals for implementing an EMS are met.

Information for this article courtesy of the U.S. Environmental Protection Agency.