Implementation of the EMS and Related Benefits

1
Implementation of the EMS and Related Benefits

• Wednesday, August 13, 2003
• 8th Annual Joint Services P2 HWM Conference
  Exhibition
• San Antonio, Texas

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Drivers for Federal EMS
3
Environmental Issues Facing Government

• Land and natural resource management
• Impacts from site operations
• Policy implications
• Compliance concerns
• Budgetary pressures (enhanced efficiency)
• Public perception

4
What are some of the drivers for government to
adopt EMS principles?

• The need to improve environmental performance
  because of
• Obligation of environmental stewardship
• Public expectations
• The business side of government
• Regulatory compliance issues
• Executive orders

5
What are some of the roadblocks for government to
adopt EMS principles?

• Changing priorities over time
• Political and other non-organizational pressures
• Frequent changes in leadership and their goals
• Budgets and allocations are not typical of
  private sector
• Finding relevant metrics (administrative vs.
  Environmental condition or cost)
• Finding the best element to motivate employees
• Lack of familiarity
• Concern over Flavor of the Month

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Operational Benefits of an EMS
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Benefits of an EMS

• Facilitates meeting your mission
• Improves the environmental condition
• Minimizes accidents and problems, or lessens
  impact and response time if they do occur
• Reduces redundant paperwork
• More efficient use of resources
• Facilitates compliance with requirements
• Responds to public scrutiny trends

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Measurement as a Management Tool

• We need to know what conditions are to make
  management decisions.
• An EMS directs and facilitates relevant
  measurements.
• Measurements include environmental conditions,
  status of programs, compliance, and the EMS
  itself.

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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

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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.

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EMS and 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.

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Connecting the Environment and the People

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

13
Specific Benefits

• Better awareness of impacts, allowing the
  workforce to make more informed decisions
• Increased suggestions and initiatives
• Additional opportunities to recognize and reward
  performance
• More consistency in operations
• Faster response and more effective corrective
  action when problems occur
• Delegates responsibility to more people, and
  where better addressed

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Getting Started - The EMS Team and Gap Analysis
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The EMS Team

• Find a champion
• Draw from all organizations
• Look for volunteers

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Functions of the Team

• Educate all organizations at facility
• Conduct gap analysis
• Collect input from employees, management
• Plan and implement EMS
• Interact with local community as needed

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Knowledge and Skills Needed for Team

• EMS knowledge
• Project management skills
• Enthusiasm and energy
• Excels at training
• Excellent communication skills
• Process/systems knowledge
• Political savvy

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Level of Effort

• Estimate level of effort based on gap analysis
• Leverage existing resources
• Dont underestimate!
• Obtain management commitment for policy and
  implementation

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Gap Analysis

• A gap analysis is an assessment process used to
  compare the current state of your facilitys EMS
  against a standard.
• Other similar processes are initial
  environmental reviews (IERs) or environmental
  management system reviews (EMRs).

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Purpose of a Gap Analysis

• Identify gaps between your current management
  systems and the EMS standard
• Collect policies, procedures, programs, metrics,
  and personnel that support the current EMS
• Establish a list of actions to achieve
  conformance with the standard

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Conducting a Gap Analysis

• Analysts must be familiar with EMS framework
• Allow several days to complete data collection
• Prepare a summary report and provide to
  participants

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Steps in a Gap Analysis

• Facility walk-through
• Document review
• Staff interviews
• Identify and document gaps

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Facility Walk Through

• Identify Activities, Products, and Services
• Main reason for facilitys existence
• Support activities
• Develop Comprehensive Picture of Facility
• Maps
• Pictures
• Lists of buildings and organizations

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Document Review

• Environmental policy statements
• Other policy statements
• Mission statements
• SOPs
• Position descriptions
• Environmental plans (HWMP, P2, INRMP, SPCC,
  SWPPP, EA/EIS, etc.)
• Training materials

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Staff Interviews

• Identify organizational structure
• Identify requirements to fulfill mission
• Determine awareness of staff of EMS
• Awareness of environmental programs and goals

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Identify and Document Gaps

• Compare with EMS elements
• Provide a rough score for installation on EMS
• Make a list of specific actions to close gaps

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First Steps - Policy Development and
Identification of Activities
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Environmental Policy

• An environmental policy is a statement by an
  organization of its intentions and principles in
  relation to its overall environmental performance
  which provides a framework for action and for the
  setting of its environmental objectives and
  targets.
• - ISO 14001

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Policy Statement Importance

• Demonstrates management commitment
• Defines framework for EMS
• EMS standard (e.g. ISO 14001, EMAS 2)
• Registration (3rd party v. self-declare)
• Provides articulation of strategic environmental
  perspective for use in defining objectives and
  targets

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Timing the Policy Statement

• Policy statement may not be first step
• Review DoD and your service branchs policy
• Determine level of awareness of EMS with senior
  leaders
• Make a case for EMS first

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Writing the EMS Policy Statement

• Signed by installation commander or senior
  military official
• Make policy statement consistent with EMS
  framework

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Examples of Policy Statements

• Executive Order 13148
• EMS Implementation Criteria and Metrics, ADUSD(E)
  Memo 30 Jan 2003
• DoD EMS, USD/ATL Memo 5 Apr 2002
• OMB and CEQ letter to SECDEF 1 Apr 2002
• Army EMS Installation Requirements, ACSIM Memo 6
  Aug 2001
• Army EMS Action Memorandum, OASA(IE) 13 Jul 2001
• Navy EMS Policy, CNO Memo 6 Dec 2001
• Air Force ESOHMS, CSAF and SAF Memo 5 Jan 2001

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Identification of Activities

• Define the scope of your EMS
• Physical boundaries of facility
• Incorporation of other management systems
• Mission of facility
• Organizations involved

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Physical Boundaries of Facility

• Contiguous area
• Geographically separate areas
• Participation of tenants
• Encroachment
• Community participation

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Other Management Systems

• Safety
• Occupational Health
• Risk
• Quality
• Government Performance and Results Act

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Activities, Products, and Services

• Core mission of facility
• Flying, training, depot maintenance
• Transient and personnel support
• Housing, food service, recreation
• Facilities Management/Engineering
• Facility maintenance
• Utilities
• Construction

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Organizational Charts

• Include all organizations associated with
  activities, products, and services
• Define the EMS according to responsibility and
  accountability
• Is the EMS large enough to include process owners
  and those with authority to improve processes?

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Other Stakeholders

• Tenants and other agencies
• Suppliers
• Contractors
• On-site
• Off-site
• Regulators
• Public
• Visitors
• Local community

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Understanding the Role of Aspects in the EMS
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Planning

• Establish, Maintain, and Document
• 4.3.1 Procedure to identify Environmental
  Aspects.
• 4.3.2 Procedure to identify legal and other
  requirements.
• 4.3.3 Environmental objectives and targets.
• 4.3.4 Program for achieving objectives and
  targets, including responsible individuals and
  time frames.

41
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

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Environmental Aspects and Impacts

• ENVIRONMENTAL ASPECTS
• Elements of an organizations activities,
  products or services which can interact with the
  environment. Examples include discharges,
  resource consumption, energy usage, ecosystem
  alterations, etc.
• ENVIRONMENTAL IMPACTS
• Any change to the environment, whether adverse or
  beneficial, wholly or partly resulting from an
  organizations activities, products, or services.
  

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Environmental Aspects and Impacts

• Aspects can be
• direct or indirect
• normal, abnormal, or emergency
• past, present, or future
• Aspects are cause, impact is the effect
• Control and Influence
• Activity ?one or more aspects ?one or more impact
• Must be comprehensive! Not only waste stream

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Significant Aspects

• A significant aspect is one that has or can have
  a significant impact on the environment
• Site selects the criteria for significance rating
  and cutoff value
• For example tendency to occur, severity of
  impact, and regulatory issues, are criteria.
• Significance can be determined by numeric cutoff
  value or subjective assessment based on yes/no
  answers

45
Role of Aspects in the EMS

• Significant aspects drive the EMS
• 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.

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Keys to Effective Aspects Identification and
Rating

• Be comprehensive
• Do not pre-judge! Inventory completely you have
  the opportunity to prioritize later
• Sort by activity, product, or service and
  identify impacts
• Significance criteria change over time all
  relative. Should never have a situation with no
  significant aspects (as per continual improvement
  commitment)
• Aspect is considered significant although
  impact is used to make significance determination
• Aspects not considered significant will not be
  carried through the system
• Significant aspects affect and drive all other
  parts of system! If you must control, it must be
  significant.

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Aspect Analysis - Examples of Activities

• Production and manufacturing
• Wastewater treatment
• Solid waste handling and disposal
• Raw material and chemical handling
• Bulk storage of fuels
• PCB transformers
• Administrative
• R D
• Quality Control

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Objectives, Targets, EMPs

• Objectives define what the organization will do
  to address and improve upon relative to the
  policy, aspects, and requirements
• Targets are the specific measureables to drive
  the objectives
• EMPs describe the detail as to what is to be
  done, what will be measured, and how we will know
  when are there

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Overview of Next Steps in Implementation
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ISO 14001 Steps
We are here
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EMS Planning

• Prepared a policy statement
• Put together an EMS team
• Conducted a gap analysis
• Defined your fenceline
• Created an aspects register
• Identified impacts
• Reviewed legal requirements
• Determined the significance of impacts
• Set objectives and targets
• Linked objectives to programs

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ISO 14001 Elements

• Implementation and operation involves
• Structure and Responsibility
• Training Awareness Competence
• Communication
• EMS Documentation
• Document Control
• Operational Control
• Emergency Preparedness and Response

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ISO 14001 Elements

• Checking and corrective action involves
• Monitoring and Measurement
• Nonconformance Corrective and Preventative
  Action
• Records
• EMS Audit

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ISO 14001 Certifications
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Federal Facilities with ISO 14001 Registration

• DOE Brookhaven Natl. Lab, NY
• DOE Idaho Natl. Engineering and Environmental
  Laboratory
• DOE Kansas City Plant, MO
• DOE Savannah River Site, SC
• DOE Strategic Petroleum Reserve, TX and LA
• DOE Waste Isolation Pilot Plant, NM
• EPA Ft. Meade Laboratory, MD
• Fort Lewis, DPW, WA
• NASA Glenn Research Center, OH

• NASA Stennis Space Center, MS
• NASA White Sands Test Facility, NM
• Naval Undersea Warfare Center Newport, RI
• Naval Aviation Depot North Island, CA
• Navy T-AKE program office - Crystal City, VA
• Scranton Army Ammunition Plant, PA
• US Coast Guard, Curtis Bay, MD

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EMS Success StoryDOE Strategic Petroleum Reserve

• Five separate facilities
• 4 salt dome petroleum storage sites
• 1 office facility
• Located in Texas and Louisiana
• Implemented one EMS for all five sites
• ISO 14001 third party certification
• credibility with customers
• instilled discipline and maintenance of system

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SPR Keys to Success

• Management commitment
• Integrated ESH approach
• Integrated with NEPA
• 18-month implementation schedule
• 3rd party certification

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SPR EMS Benefits

• Recognition for SPR leadership (internal and
  external)
• EO 13148 conformance ahead of deadline
• National Performance Track charter member
• Clean Texas member
• Improves relationship with regulators
• Saved 357,856 in 3 years on a 165,000
  investment
• 17, 318 in hazardous waste expenditures
• 154, 243 in sanitary waste expenditures
• 186, 295 in clean up costs

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EMR Success StoryTennessee Valley Authority

• Federal Power Authority
• 11 fossil fuel power plants
• 29 hydroelectric plants
• 3 nuclear plants
• 30,000 megawatts generating capacity
• 17,000 miles of transmission lines

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TVA Keys to Success

• Management commitment
• Process to maintain and develop policies
• ISO 14001
• Emphasis on prevention
• Measure and report
• Defined roles and responsibilities from Board of
  Directors to technicians
• Standardized environmental processes and training
• Internal web site
• Communication, communication, communication

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TVA EMS Benefits

• Reduced 457 environmental training courses to 84
  courses and saved 4 million per year
• Saved 5.7 million at one time and 3 million
  annually by standardizing absorbents, adhesives,
  cleaners, etc.
• Reduced internal audit findings by 50
• Reduced internal repeat findings by 92
• Reduced reportable environmental events by 35
• Lowest SO2 and NOx emissions in 27 years

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Examples of Document Control Systems

• Distribution to offices on as needed basis
• Central file cabinet
• Microsoft Outlook Public Folders
• Use of software version control properties
• Web site with Adobe Acrobat .pdf files
• GIS
• Proprietary software packages

63
Examples of Operational Controls

• Technical Orders Manuals
• Military Specifications
• Unit SOPs
• Individual Development Plans
• Annual Training Plans
• Strategic Readiness System

• Measuring equipment
• Energy meters
• Tank volume meters
• Overflow devices and check valves
• Air flow indicators
• Preventive maintenance

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Federal Facility Emergency Preparedness Programs

• Fire Department
• Safety Office
• EPCRA Program
• Local Emergency Planning Committee
• HAZMAT Response

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Monitoring and Measurement

• Open Enforcement Actions
• Stormwater Monitoring
• Hazardous Waste and Solid Waste Reporting
• Air Permits

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Checking and Corrective Action

• TEAM Guide Compliance Assessments
• IG Audits
• Quality Audits
• Operational Readiness Inspections

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Continual Improvement

• Identify areas for improvement of EMS
• Determine root cause for nonconformance
• Develop corrective or preventive action plan
• Verify effectiveness of action plans
• Make changes to procedures

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Where to Get Help

• DENIX web site (www.denix.osd.mil)
• Office of the federal environmental executive
  (www.ofee.gov) (ed.pinero_at_ofee.Gov)
• EPA (www.epa.gov) (garvey.will_at_epa.gov)
• Agency websites (DoD, EPA, NASA)
• Interagency EMS sub group
• Your agency environmental staff

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Cohos presentation goes here
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Understanding the Role of Management in an EMS
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The Role of Management

• The management system model is built on the
  premise that senior management is consistently
  participating or otherwise involved.
• There are key points where senior management has
  a defined role (e.G., Policy, management review)
• Ongoing support is critical

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Specific Expectations

• Be visible and positive about the message.
• Show your support through organizational policy,
  as well as walk the talk by your words and
  actions.
• Discuss the benefits of using the EMS tool Most
  importantly, verbalize how it supports the
  mission.
• Be up front and honest about the effort needed
  for successful implementation.
• Provide for resources (financial, staff,
  external).

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Specific Expectations (cont.)

• Provide moral support, encourage your team, and
  create a leadership environment that ensures
  success. The staff should feel that you are in it
  with them and committed to success.
• Encourage dialogue among the various offices,
  units and/or facilities. Try to break down the
  silos!
• Share performance results with the workforce.
• Communicate outside the agency to share
  experiences and to learn from others.

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Workshop Summary

• DoD is committed to implementation of
  Environmental Management Systems throughout its
  organizations
• ISO 14001 offers a useful framework for EMS
  implementation
• There are many examples and success stories to
  learn from as you proceed toward implementation