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Guide to Developing an Environmental Management System

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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 job that small and medium sized organizations can tackle. This page takes you though those basic steps as they are outlined in the 2001 Second Edition of Environmental Management Systems: An Implementation Guide for Small and Medium Sized Organizations (PDF) (201 pp, 1.4MB, About PDF). This Web page pulls out the guide's specific steps and points back to specific pages in the guide to fill out worksheets and get additional materials. See additional online EMS training, which also helps to understand the material below.

Plan
Planning, including identifying environmental aspects and establishing goals

Do
Implementing, including training and operational controls

Check
Checking, including monitoring and corrective action

Act
Reviewing, including progress reviews and acting to make needed changes to the EMS.

Plan

Plan Plan Act Check Do

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, it is important to use resources wisely.

The information below illustrates 10 steps in the EMS planning process. Take 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 the development of an EMS. Are you trying to improve your environmental performance (for example, compliance with regulations or prevent pollution)? Write your goals down and refer back to them frequently as you move forward. As you design and implement the EMS, ask: How is this task going to help us achieve our goals? This also is a good time to define the project scope (i.e., what is the "organization" that the EMS will cover? One location? Multiple locations? Should we "pilot" the EMS at one location then implement the system 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 to support EMS development and implementation. Management must first understand the benefits of an EMS 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 performances. 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 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 Kick-Off Meeting

Once the team has been selected, hold a kick-off 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 kick-off meeting also is a good opportunity to provide some EMS training for team members. Follow-up this 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. See the NSF ISO 14001 Self-Assessment Tool (PDF) (63 pp, 134.7K, About PDF) Exit EPA Disclaimer or Incorporating Design for the Environment into Your Gap Analysis (PDF) (5 pp, 30 K, About PDF) for gap analysis tools.

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, there may be outside funding or other types of assistance that you can use (from a trade association, a state technical assistance office, etc.). See Appendix F of the Environmental Management Systems: An Implementation Guide for Small and Medium Sized Organizations (PDF) (201pp, 1.4MB, About PDF) for more ideas on possible sources of help.

Step 9: Involve Employees

Ownership of the EMS will be greatly enhanced by meaningful employee involvement in the EMS development process. Employees are a great source of knowledge on environmental and health and safety issues related to their work areas as well as on 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, be sure to regularly monitor your progress against the goals and project plan and communicate this progress within the organization. Be sure to communicate the accomplishments that have been made and describe what happens next. Build on small successes. Be sure to keep top management informed and engaged, especially if additional resources might be required.

Before beginning the Do section review the key elements of an EMS, with worksheets and examples, see pages 15-77 of Environmental Management Systems: An Implementation Guide for Small and Medium Sized Organizations (PDF) (201 pp, 1.4MB, About PDF).

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Do

Plan Plan Act Check

Several up front EMS planning tasks (such as gaining top management commitment) were described in the "Plan" stage and should be completed prior to putting the elements of an EMS into place.

This stage begins the step by step action plan for developing and implementing the elements of an EMS. It describes a logical sequence for planning and implementing EMS elements and explains how this sequence can be important in building an effective EMS.

The Roadmap for EMS development, page 79 of Environmental Management Systems: An Implementation Guide for Small and Medium Sized Organizations (PDF) (201 pp, 1.4MB, About PDF) outlines the steps in the Do process in a diagram.

Keep in mind that this is just one way to do the job-you might find other approaches that work just as well. Each step of the suggested implementation process flow (and a rationale for its sequence) is discussed below.

Hints

A few hints to keep in mind as you build your EMS:

Step 1: Identify Legal and Other Requirements

A first step in the EMS-building process is understanding the legal and other requirements that apply to your products, activities and services. This step is important for understanding compliance obligations and how these obligations affect the overall EMS design. For example, you might have an operation that is covered by an air quality permit or might provide a service that results in the generation of regulated wastes. Your EMS should include processes to 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. Identifyi environmental aspects and impacts and determine which are significant. Some environmental aspects may be regulated, while others may not be.

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 otherwise measured in some manner.

Collecting this information at an early stage will help you implement subsequent EMS elements. You can use a form to capture this information (such as Figure 15 found on page 81 in Environmental Management Systems: An Implementation Guide for Small and Medium Sized Organizations (201pp, 1.4MB, About PDF)). One caveat: just because you identify an existing control and/or monitoring activity related to a particular operation or activity, do not assume that these controls are adequate for EMS purposes. The adequacy of these controls will depend on several factors, including the EMS goals and objectives.

Step 3: Define Views of Interested Parties

Gather information on the views of your "stakeholders" or interested parties. Stakeholders might include your neighbors, interest groups, customers and others. Their views might address how your organization affects the environment, how well you are meeting environmental obligations, and whether your organization is a "good neighbor", among other topics. Gathering this information allows you to consider stakeholder input in the development of your environmental policy. Since you have already assessed your legal and environmental aspects, you should be in a good position to have meaningful dialogues 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 allows your organization to prepare a policy that is relevant to the organization and the key issues that it faces. You should understand how well you are currently managing key issues. For example, information on the views of your stakeholders might be valuable in developing an environmental policy.

Step 5: Define Key Roles and Responsibilities

Once the environmental policy has been written, you can begin to define key roles and responsibilities within the EMS. At this stage of implementation, 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, obtain the input of these individuals in the next step of the process - establishing objectives and targets. EMS responsibilities for other specific jobs or functions will be identified in a later step.

Step 6: Establish Objectives and Targets

These objectives should be consistent with your environmental policy and the analyses you carried out on legal requirements, environmental aspects and impacts, and the views of interested parties, etc.

You have identified the operations and activities related to environmental aspects and impacts and key roles and responsibilities. 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 also should know which parts of the organization must be involved in order to meet this objective.

Step 7: Develop Environmental Management Programs, Identify Operational Controls, and the Identify Monitoring and Measurement Needs

This brings us to one of the most challenging (and potentially most valuable) steps in developing and EMS. You are ready to tackle several EMS elements simultaneously. These elements include the design of environmental management programs, the initial identification of necessary operational controls, and the initial identification of monitoring and measurement needs. You should already have a head start on this step, since you identified operations and activities related to your 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 achieving a certain objective (such as maintaining compliance with regulations) might 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. Determining progress on achieving objectives often requires some form of monitoring or measurement.

Compile a list of your operational control and monitoring needs. As you develop your environmental management programs, ask yourself the following questions:

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, & Records Management Processes

At this stage of implementation, your EMS will begin to generate some documents (such as procedures and forms) and records (that demonstrate that various processes are being carried out). You need an effective way to manage the records that your EMS generates. Establish procedures for corrective/preventive action, document control, and records management. These three processes are essentially "system maintenance" functions. As you develop and implement procedures, work instructions, and other EMS documents, you need a process for controlling the generation and modification of these documents. You will need a process to ensure that you can correct problems when they occur and manage records (such as monitoring activities).

Step 9: Establish Operational Controls & 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 responsibilities in a responsibility matrix or in 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 at your site who are not employees of your organization, consider whether these other 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 other system-level procedures might include, for example:

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, 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:

At this point, you should have sufficient EMS processes in place to begin to check your EMS.

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Check

Plan Plan Act Do

As discussed earlier, your EMS should be built on the "Plan, Do, Check, Act" model to ensure that environmental matters are systematically identified, controlled, and monitored. Using this approach will help to ensure that performance of your EMS improves over time and that you meet your goals for implementing an EMS in the first place.

This stage continues the step by step action plan for developing and implementing the elements of an EMS. At this point, you should have sufficient EMS processes in place to begin to check your EMS. One approach is discussed below.

Conduct Internal EMS Audits

Once internal auditors have been selected and trained, you should design and initiate the internal auditing process. At this point, you should have sufficient EMS processes in place to conduct meaningful audits. 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 identified problems.

Act

Plan Plan Check Do

This stage continues the step-by-step action plan for developing and implementing the elements of an EMS. At this point, you should have identified problems with your EMS and should act to resolve these issues. One approach is discussed below.

Conduct Management Reviews

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

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

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