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Integrating Green Purchasing Into Your Environmental Management System (EMS) - Section 2: Integrating Green Purchasing Into Your EMS

As published by the EPA in April 2005.

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2. INTEGRATING GREEN PURCHASING INTO YOUR EMS

By targeting enhanced green purchasing within the EMS, a facility or installation can comply with Federal green purchasing legal and other requirements, raise awareness of procurement as a pollution prevention tool, and facilitate continual improvement in environmental performance through proactive green purchasing and contracting activities. The table below addresses the elements of ISO 14001 in the context of green purchasing and provides links to examples and success stories from Federal government organizations that support recommendations for integrating green purchasing into your EMS.

EMS Element
(ISO 14001)
Green Purchasing Component Federal Facility Examples
4.2 Environmental Policy

A conforming Federal Facility Environmental Policy Statement can include green purchasing, by reference, in the commitments to compliance with legal and other requirements and prevention of pollution. An organization also may include a more direct green purchasing commitment, such as:

[Facility] will consider environmental factors in all purchasing decisions and will give preference to those products and services designated by or recommended in Federal green purchasing preference programs, as well as those products and services that have a lesser or reduced effect on human health and the environment when compared with competing products or services that serve the same purpose.

4.3.1 Environmental Aspects

The procedure to identify environmental aspects and significant impacts must be applied to procurement (purchasing) and contracting as activities you control or influence. Other activities also may have procurement-related aspects, such as the purchase of products or services that consume resources and/or generate wastes.

Include procurement and contracting personnel and key purchasers on the EMS Cross Functional Team identifying and ranking aspects and impacts.

Consider Including compliance with procurement-related legal and other requirements among the criteria for determining significance.

4.3.2 Legal and Other Requirements

A conforming legal and other requirements procedure should identify all procurement-related laws, regulations, and Executive Orders. Any agency-specific procurement requirements, including your agency's Affirmative Procurement Plan and Green Purchasing Strategic Plan7 are considered “other requirements” and should be incorporated into any list or register of legal and other requirements for the EMS.

4.3.3 Objectives and Targets

Determine realistic green purchasing objectives for each appropriate significant aspect, based on the commitment to pollution prevention, legal and other requirements, significant aspects, and mission requirements. Consider targeting all purchases over a threshold amount, based on environmental impact and the amount of influence your facility has over the product or service provider(s) (See Environment Agency of Great Britain).

Establish measurable green purchasing targets that can be accomplished within a reasonable timeframe.

For example:

Objective: Improve green purchasing practices.

Targets:

  • Provide green purchasing training to procurement staff.
  • Identify opportunities to purchase green products and services.
  • Consider requiring the use of FAR clause 52.223-10 in all relevant service contracts.
  • Create Green Purchasing SOPs for Buildings, Power, Electronics, Vehicle Fleets, Office Supplies, Copy Paper, Cleaning Products, Meetings, and Landscaping and provide management emphasis to these initiatives.
  • Conduct employee awareness training on the purchase and use of green products and services and participation in recycling programs.

Remember, objectives and targets are documented and reviewed and updated on an established schedule.

4.3.4 Environmental Management Program

Establish programs to pursue green purchasing objectives and targets and define a timeframe within which each should be achieved. Identifyboth human and financial resources to ensure that green purchasing programs are effective, as well as metrics to determine progress.

Establish a procedure to review new and modified contracts and contract renewals to ensure the contract language includes requirements for green purchasing.8

4.4.4 Structure and Responsibility

Include procurement and contracting personnel on the EMS Implementation Team. Designate staff responsible for green purchasing program management and establish reporting relationships within the program, with EMS Manager and with top management.

Assign staff to identify the products and services currently purchased to support your activities, who purchases them and how they are purchased. See the EPA ESC procurement summary in Appendix A.

Assign responsibility and resources for Environmental Management Programs to achieve green purchasing objectives and targets.

4.4.2 Training, Awareness and Competence

Identify procurement training needs based on significant aspects and legal and other requirements for Federal green purchasing preference programs. Train procurement and contracting staff and product users on green purchasing and encourage them to request goods and services that reduce environmental impacts and meet performance standards.

Consider requiring that key procurement and contracting personnel take the Office of Personnel Management's “What is Green Purchasing, Anyway?” training course available at the Gov Online Learning Center website: www.golearn.gov/ 9 The DOD Green Procurement Strategy10 offers a list of green purchasing training resources.

4.4.3 Communication

The Communication Procedure should include guidance on who is responsible for internal communication on significant aspects, including those related to green purchasing, as well as how often and to whome information will be disseminated.

4.4.5 Document Control

Document control procedures will apply to all green purchasing documentation, including Affirmative Procurement and EPP plans, specifications, purchase orders and contracts and list of green products approved for purchase.

Procedures and responsibilities for creation and modification of purchasing documents maapplicable.

4.4.6 Operational Control

Ensure that all significant aspects related to green procurement are addressed by operational controls. Develop and implement control procedures to ensure that product users, specification writers and the procurement and contracting personnel include an evaluation of environmental considerations, along with price, performance and availability, in the criteria for purchasing decisions. Green contract language for more than 600 products and services is available at http://yosemite1.epa.gov/oppt/eppstand2.nsf.

Operational control procedures should ensure that purchases of designated and mission-appropriate green products and services support the environmental policy, legal and other requirements and green purchasing objectives and targets.

Communicate green purchasing procedures and requirements to suppliers and contractors, especially those that provide goods and services for activities that have significant environmental aspects

4.4.7Emergency Response

Emphasize the purchase of environmentally preferable products to reduce the potential for incidents requiring emergency response.

Consider including green spill response material specifications in the Emergency Response Procedure.

4.5.1 Monitoring and Measurement

A conforming procedure will document what green purchasing data to collect and how to collect and manage the data related to significant environmental aspects and requirements for reporting on green purchasing.

Per Federal green purchasing program requirements, monitor purchases of recycled content products, bio-based products, alternative fueled vehicles, alternative fuels, and non-ozone depleting products. Your organization may also want to monitor purchases of any other product or service that has a reduced impact on the environment when compared with competing products that serve the same purpose.

When possible, measurements should quantify positive environmental impacts as well as progress toward meeting established green purchasing objectives and targets. For example measure reductions in solid waste associated with purchases of environmentally preferable products, reductions in hazardous waste disposal associated with substitution of less toxic products, as well as reductions in energy and water use associated with products to increase efficiency.

The paper calculator at http://www.ofee.gov/ allows the user to compare the environmental impacts of papers made with different levels of postconsumer recycled content, ranging from 0% (i.e., virgin paper) to 100%.

Greenhouse gas measurement tools are available atEPA

The DOD Green Procurement Strategy includes a description of DOD Green Procurement Metrics http://www.ofee.gov/gp/gppstrat.pdf [PDF]

The ENERGYSTAR® Program offers a calculator to demonstrate how much new energy efficiency equipment you can purchase with anticipated energy savings at www.energystar.gov.

4.5.2 Nonconformance and Corrective and Preventive Action

Designate responsibility for investigating and correcting findings of nonconformance with the green purchasing EMS requirements, in accordance with facility corrective action procedures.

4.5.3 Records

Identify green purchasing recrods, such as training, purchases of specific products, reports to management and government agencies and audits. Maintain these environmental records in accordance with facility EMS procedures.

4.5.4 EMS Audit

Ensure that green purchasing EMS elements are included in the activities to be considered in either internal or external audits of the EMS.

4.6 Management Review

Ensure that progress toward achieving green purchasing objectives and targets and any green purchasing operational controls are discussed as part of the EMS Management Review.

Ensure that the management review considers recommendations to improve facility green purchasing efforts.

 

 

4.2 ENVIRONMENTAL POLICY

ISO 14001 Element

Section 4.2 of the ISO 14001 Standard requires that Top Management define the organization's environmental policy and ensure that it:

  1. Is appropriate to the nature, scale and environmental impacts of the organization's activities, products or services.
  2. Includes a commitment to continual improvement and prevention of pollution.
  3. Includes a commitment to comply with relevant environmental legislation and regulations, and with other requirements to which the organization subscribes.
  4. Provides a framework for setting and reviewing environmental objectives and targets.
  5. Is documented, implemented, maintained, and communicated to all employees.
  6. Is available to the public.

Annex A.2 of 14001 notes that “top management” may consist of an individual or a group of individuals with executive responsibility for the organization.

Federal Facility Examples

Federal Agency/Facility Environmental Policy

US Department of Agriculture (USDA), Agricultural Research Service (ARS), Beltsville Area

USDA's ARS Beltsville Area operation already has implemented a separate EPP Policy in support of its EMS. BA Policy #03-04, Environmentally Preferable Products and Affirmative Procurement Policy, dated February 6, 2003 states: “It is the responsibility of all employees of the Beltsville Area to ensure that environmentally preferable products and services are actively pursued when purchasing. Green purchasing/affirmative procurement includes, but is not limited to, recycled-content products, biobased products, and energy-efficient products. This applies to all purchases including micro-purchases (less then $2,500).”

Department of the Interior (DOI), National Park Service (NPS)

The National Park Service expects each park-level organization to adopt and implement an EMS according to guidance provided in The National Park Service Park-level Model Environmental Management System. This guidance document states that each facility shall develop and document a commitment statement affirming the facility's intent to strive for exemplary environmental management. The statement must include a commitment to environmental leadership by “incorporating pollution prevention, waste reduction, best management practices, and environmentally preferable purchasing in all park management activities.”

http://www.doi.gov/ - The_Park_Level_Model_EMS

DOI, NPS, Intermountain Region

As part of their model EMS, each national park in the Region must develop a “green purchasing” park policy that expresses the Superintendent's commitment to establishing criteria for “green” products and a directive to avoid hazardous products altogether.

Department of the Interior (DOI), National Park Service (NPS), Concession Environmental Management Program (CoEMP)

Concession contracts issued by the NPS to businesses (concessioners) to provide visitor services, such as retail, food and lodging services, in the national parks, include a requirement to develop and implement an EMS. While NPS concessioners are not subject to EO and FAR requirements, the EMS policy requires that each concessioner provide a clear statement of the commitment to Best Management Practices in its operation, construction, maintenance, acquisition, provision of visitor services and other activities. The BMPs may include environmentally preferable purchasing and reduction in the purchase and use of hazardous substances.

Environmental Protection Agency (EPA), Environmental Science Center (ESC) at Fort Meade, MD

The EPA Environmental Science Center (ESC) at Fort Meade, MD issued an Environmental Policy statement that includes a commitment to consider environmental factors when making planning, purchasing, and operating decisions.11 This commitment is supported by the statement: “We will adopt cost-effective practices that eliminate, minimize or mitigate environmental impacts and we will use environmentally preferred materials if those materials meet technical specifications.”

Environmental Protection Agency (EPA), Region 3 (Mid-Atlantic Region)

EPA Region 3 (Mid-Atlantic Region) issued an Environmental Policy on September 16, 2003. This policy includes a commitment to “Consider environmental impacts when making planning, purchasing and operating decisions.”

National Aeronautics and Space Administration (NASA)

The NASA Environmental Management Policy (NPD 8800.16, April 6, 2000), Section 1 c, includes language directing consideration of environmental factors in selection of materials and processes. NASA Centers and other organizations are required to consider environmental factors throughout the life cycle of a program, including planning, development, execution, and disposition activities. Examples of environmental factors include the proposed use of hazardous materials, the potential for waste generation, and the overall environmental preferability of selected materials and processes.12

Department of Defense (DOD)

The Pentagon's Affirmative Procurement Plan includes the following: “The Engineering & Technical Services Division (ETSD) and the Defense Facilities Contracting Office (DFCO) are committed to the implementation of a procurement program that ensures compliance with all applicable laws, executive orders, instructions and regulations for the acquisition of Environmentally Preferable and Energy-Efficient Products and Service (EPP). The intent of the program is to meet the Department of Defense policy on procurement of EPA-designated items. That policy states that 100% of such purchases will meet or exceed the guideline standards unless written justification is made part of the procurement file . . .”

4.3.1 ENVIRONMENTAL ASPECTS

ISO 14001 Element

Environmental Aspects are the components of a Federal facility's activities, products, or services that can have an impact, beneficial or adverse, on the environment. Environmental impacts are the changes that take place in the environment as a result of the aspect. For example, stormwater runoff is an aspect; the resulting environmental impacts may include erosion and degradation of surface waters. Solid waste generation or disposal is an aspect with impacts including degradation of the land and air quality.

Section 4.3.1 of ISO 14001 requires that an organization establish and maintain procedures to identify the environmental aspects of its activities, products or services that it can control and over which it can be expected to have an influence. Aspects are identified to determine those that have or can have significant impacts on the environment. The Standard further requires that the organization ensure that the aspects determined to be significant are considered in setting environmental objectives.

Federal Facility Examples

Federal facilities have determined that procurement and contracting activities can have an impact on the environment. Many Federal facilities have defined all procurement activities as an environmental aspect or have defined procurement of specific products or services as aspects. In addition, compliance with procurement-related legal and other requirements and identification of the potential to reduce or eliminate environmental impacts through product substitution, new equipment or changes to contractual requirements may be included in the criteria used to determine the significance of environmental impacts. Examples of these approaches are included in the chart, below:

Federal Agency/Facility Environmental Aspects

DOI, NPS, Grand Canyon National Park

Dr. Mary Ann McCloskey, Environmental Protection Specialist at the Grand Canyon noted that procurement was identified as a significant aspect during the EMS Team's first aspect/impacts analysis. One of the team's main concerns was the reduction of hazardous waste and the use and storage of hazardous materials. Dr. McCloskey noted, “The team felt that we needed to go to the source — procurement and reducing materials stored in the warehouse.”13

DOI, NPS, Grand Canyon National Park, Xanterra Parks and Resorts

Xanterra Parks and Resorts, the concessioner providing some visitor services for the South Rim of Grand Canyon National Park, identified Recycled and Reused Materials Use as a significant environmental aspect for their EMS.

DOI, NPS, CoEMP

Environmental aspects of concessioners providing visitor services, such as retail, food and lodging, at National Parks include generation of solid waste, generation of hazardous waste, and purchasing activities.

EPA Region 9

Heather White of EPA Region 914 noted that in determining the significance of their environmental aspects, Region 9 considered the life cycle of activities and services and their potential impact on the biosphere. Because Region 9 plans to use its EMS to move toward sustainability, they evaluated significance based on four system conditions derived from The Natural Step15, three of which address material use: SC#1 Material Use: Materials that originate from the Earth's crust (i.e. metals, petroleum products); SC#2 Material Use: Materials of a synthetic origin (i.e. manmade chemicals, plastics, and other synthetic products); SC#3 Material Use: Materials that originate from the biosphere (i.e. paper); and SC#4 Community/Employee Concerns: Issues of concern for the well-being of community stakeholders and/or our employees.

USDA, ARS, Beltsville Area

David Prevar from USDA, ARS, Beltsville Area states that green purchasing was among the criteria used to evaluate the significance of their environmental aspects. The aspects and impacts analysis allowed them to identify opportunities to create an alliance between their ongoing agricultural research and the use of biobased products in their day-to-day operations.

4.3.2 LEGAL AND OTHER REQUIREMENTS

ISO 14001 Element

Section 4.3.2 of ISO 14001 requires that an organization establish and maintain a procedure to identify and have access to legal and other requirements to which the organization subscribes that are applicable to the environmental aspects of its activities, products, or services.

The procedure for review of legal and other requirements should effectively identify all of the Federal green purchasing preference program legal and other requirements listed in the chart, below. In addition, local environmental requirements, such as recycling programs, are considered other requirements and should be included in the list or register of legal and other requirements for the EMS.

FEDERAL GREEN PURCHASING LEGAL AND OTHER REQUIREMENTS

Product Category Legal and Other Requirements

Recycled Content
http://www.epa.gov/cpg/about.htm

Section 6002 of the Resource Conservation and Recovery Act (RCRA); EO 13101, Greening the Government through Waste Prevention, Recycling and Federal Acquisition; Federal Acquisition Regulation (FAR), Parts 7, 11, 23.

Environmentally Preferablehttp://www.epa.gov/epp/

EO 13101, Greening the Government through Waste Prevention, Recycling and Federal Acquisition; FAR, Parts 7, 11, 23.

Energy efficient http://www.energystar.gov

http://www.eere.energy.gov/femp/procurement/

EO 13123, Greening the Government through Efficient Energy Management; Federal Acquisition; Federal Acquisition Regulations (FAR), Part 23; EO 13221, Energy Efficient Standby Power Devices

Biobasedhttp://www.biobased.oce.usda.gov/fb4p/

Section 9002 of the 2002 Farm Security and Rural Investment Act; EO 13101, Greening the Government through Waste Prevention, Recycling and Federal Acquisition

Alternative fuels Fuel efficiency

http://www.eere.energy.gov/vehiclesandfuels/epact/federal/

http://www1.eere.energy.gov/vehiclesandfuels/

Section 303 of The Energy Policy Act of 1992 (EPAct); Executive Order 13149, Greening the Government through Federal Fleet and Transportation Efficiency

Non-ozone depleting substanceshttp://www.epa.gov/ozone/snap/general/index.html

Section 613 of the Clean Air Act

Federal Facility Examples

 

Federal Agency/Facility Legal and Other Requirements

DOD, U.S. Army, Ft. Lewis WA

The Fort Lewis WA Legal and Other Requirements Procedure requires Program Managers to “Maintain a list of the legal and other requirements that are applicable to your program(s); communicate this list to the EMS Management Representative. Monitor legal and other requirements applicable to your program(s) for new requirements and actual or proposed changes. Use pertinent information sources as needed.” The list of legal and other requirements includes Executive Orders that address green procurement requirements.

NASA

NASA includes its list of applicable legal requirements as an Appendix to its EMS Policy documentation. The list includes all relevant laws, regulations, and Executive Orders as well as NASA requirements including NPG 8830.1, Affirmative Procurement Plan for Environmentally Preferable Products.16

USDA, ARS, Beltsville Area

The Agricultural Research Service's Beltsville Area specifically calls out its Drivers for Affirmative Procurement stating, “Laws, regulations, and Executive Orders combine to provide the authority and requirements for Federal AP programs.”17 The drivers cited include: the Resource Conservation and Recovery Act, Executive Order 13101, Comprehensive Procurement Guidelines, 40 CFR, Part 247, the Federal Acquisition Regulation, and Public Law 107-171 and OFPP Policy Letter 92-4.

EPA, ESC, Fort Meade MD

ESC progress in meeting Executive Orders applicable to environmental management at Federal facilities included environmentally-preferable paper and recycling goals listed in E.O. 13101, “Greening the Government through Waste Prevention, Recycling, and Federal Acquisition,” and E.O. 13148, “Greening the Government through Leadership in Environmental Management,” as well as other applicable EPA directives.18

DOI, NPS, CoEMP

Concession contracts issued by the NPS for visitor services such as retail, food and lodging, include a requirement to develop and implement an EMS. Each concessioner must describe how its staff will maintain knowledge of applicable laws and Best Management Practices (BMPs). Both NPS contracts and BMPs may include requirements for environmentally preferable purchasing and reduction in the purchase and use of hazardous substances.

4.3.3 OBJECTIVES AND TARGETS

ISO 14001 Element

Section 4.3.3 of ISO 14001 requires that an organization shall establish and maintain documented environmental objectives and targets at each relevant function and level within the organization. It further requires that when establishing these objectives, legal and other requirements, the significant environmental aspects, technological options and the financial and operational requirements of the business shall be considered. Further, the standard states that the views of interested parties shall be considered in the selection process. The objectives and targets shall be consistent with the organization's environmental policy and must include the commitment to pollution prevention.

Federal Facility Examples

These agencies have included a commitment to green purchasing in their Environmental Policy, identified procurement as a significant aspect and established formal, green purchasing objectives and targets.

Federal Agency/Facility Objectives and Targets

DOI

DOI has included green purchasing goals in EMS implementation and environmental auditing at a variety of field sites. In the Strategic Plan for Greening the Department of the Interior through Waste Prevention, Recycling and Federal Acquisition19 and in the Department's Annual Performance Plan, the focus is on increasing purchases of nine targeted products, which are viewed both as high priorities for wide-spread use as well as indicators of broader compliance with green purchase program objectives. The nine targeted products include: Re-refined engine lubricating oil, Reclaimed engine coolant, Retread tires, Copy paper (recycled content and made without chlorine bleaching), Bathroom tissue (recycled content and made without chlorine bleaching), Paper towels (recycled content and made without chlorine bleaching), Plastic trash bags (recycled content), Carpeting (recycled content or refurbishable, and Biobased, biodegradable lubricating and hydraulic oils.20

DOI, NPS, Cape Cod National Seashore (CACO)

Cape Cod National Seashore (CACO) included the following Procurement and Purchasing Goal in their EMS Environmental Goals and Action Plan for FY 04:

Goal I: Reduce wastes generated through improved procurement practices. A goal champion is assigned to oversee the following targets:

  • Develop Authorized Use List of products approved for purchase and use by park staff;
  • Conduct employee awareness training on green products; and
  • Create a Green Procurement SOP and provide management emphasis to this initiative.21

DOD, U.S. Army, Fort Lewis WA

The Fort Lewis EMS is part of a larger Installation Sustainability Program. Current Fort Lewis EMS Objectives and Targets support Green Purchasing.

Objective: Cycle all material use to achieve zero net waste by 2025.

  • Target: Change procurement practices to introduce only cyclable22 materials to Fort Lewis.
  • Target: Achieve 100% cradle-to-cradle hazardous material management.
  • Target: Achieve 40% reduction in waste stream leaving Fort Lewis by the end of calendar year 2005

Objective: Reduce installation traffic congestion and traffic air emissions by 85% by 2025.

  • Target: Purchase 25 Neighborhood Electric Vehicles (NEV) for on post use by 2007.
  • Target: 50% of the GSA fleet will be alternate fuel vehicles (CNG, Bio-Diesel, E-85) by 2007

Objective: Sustain all activities on post using renewable energy sources and generate all electricity on post by 2025.

  • Target: Encourage innovative use of energy systems by developers.
  • Target: Encourage acceptance and use of innovative energy systems
  • Target: Generate 20% energy on post by 2008
  • Target: 25% of electricity from renewable sources by 2008

DOI, Fish and Wildlife Service, Bosque de Apache National Wildlife Refuge, NM

TheFish and Wildlife Service's Bosque de Apache National Wildlife Refuge in New Mexico established the following EMS green procurement goals:

  • Use reduced mercury (e.g., “Green Tip” Phillips Alto brand) fluorescent lamps as new lamps are installed or replaced.
  • Conduct pilot study to evaluate use of bio-diesel fuel in vehicles and equipment at Refuge.
  • Conduct pilot study to evaluate use of biobased lubricants and hydraulic fluid for vehicles and equipment.
  • Conduct pilot study to evaluate use of "green" at Mechanics Shop.
  • Emphasize the use of recycled and other "green" materials in all remodeling and new construction (e.g. Fire House office expansioproposed new visitors center).
  • Continue to work with the Friends of the Bosque to identify and sell environmentally preferable bookstore products such as organic cotton clothing and other materials. Work with the Friends of the Bosque to provide interpretive signage for products being sold.
  • Review and revise if opportunities exist, current purchasing procedures to enhance centralized purchasing and/or approval process in order to reduce purchase of duplicate materials, minimize hazardous material stock, maintain hazardous materials inventories and MSDSs, and encourage environmentally preferable materials.23
DOI, NPS, CoEMP

Concession contracts issued by NPS for visitor services, including retail, food and lodging, include a requirement to develop and implement an EMS. Each concessioner is required to identify environmental goals consistent with legal and other requirements and Best Management Practices. Each concessioner also must identify specific targets to achieve these goals, incorporating measurable results and schedules. Targets include environmentally preferable purchasing including organic and locally grown foods, green cleaners, energy- and water- efficient appliances, recycled content products, and reduced purchase and use of hazardous substances.

EPA

To reduce EPA's environmental footprint by increasing and promoting recycling, reducing materials entering EPA's waste stream, promoting and achieving increased and preferential use of materials with recycled content and emphasizing and increasing the purchase and use of environmentally preferable products. Specific goals in the following categories: green buildings, green janitorial/maintenance services, copy paper/publications, green meetings, green office supplies, green electronics, green fleets, green landscaping, green power, and waste prevention can be reviewed at http://www.epa.gov/greeningepa/

EPA Region 1, New England EPA Region 1's Green Team has established a goal of purchasing green substitutes for three high impact janitorial products.

EPA, Region 5

EPA Region 5 will reduce life-cycle environmental impacts associated with purchased office furnishings and equipment with a target of incorporating “green” specifications into market surveys and bid requirements for electronic equipment purchased post FY 2004. Text of the procedure, Appendix B.

EPA Region 10

EPA Region 10 has established objectives for energy use and hazardous waste reduction. Target provide for staff to include Energy Star requirements in the special terms and conditions in 30% of all grants and contracts and use environmental factors, including Energy Star compliance, in determining which electronic equipment to purchase.

California EPA

In support of their EMS Environmental Policy, Cal EPA has established the following green purchasing goals, endorsed by top management of the Boards, Departments, and Offices of Cal/EPA:

  • Achieve gold or higher certification for headquarters building from United States Green Building Council (USGBC) Leadership in Energy and Environmental Design (LEED) Existing Building prograby end of 2003.
  • Procure 100% postconsumer content and process chlorine free printer/copier paper by early 2004.
  • Formally adopt EPP, Energy, and Transportation policies supporting EMS Environmental Policy by early 2004.
  • Fully comply with SABRC reporting requirements (California Statute) in paper categories by FY 2003/2004 and provide written explanations for noncompliance in other categories.
  • Adopt initial agency-wide electronic equipment procurement, use, and end-of-life management standards by 2004.
  • Reduce greenhouse gas emissions by 20% by 2010 in partnership with the Sustainable Silicon Valley Initiative and continue participation in California Climate Action Registry.
  • Divert 75% of our headquarters waste stream by 2010 with a future goal of zero waste.24

Environment Agency of Great Britain

The Environment Agency of Great Britain has implemented an EMS and, since the Agency spends more than half of its budget on supplies and Services, identified procurement as a significant aspect. Their Agency Environmental Procurement Strategy includes the following objectives and targets:

The Agency conducted an Agency Environmental Risk Assessment which identified the following key procurement targets:

Strategic Security

 
Chemicals₤125K
Hardwood Groynes₤500K
Monitoring Instruments₤870K
Lab Consumables₤980K

Strategic Critical

 
Construction₤120M
Energy₤3.5M
Vehicles/Plant₤18M
IT Hardware₤15M

Tactical Acquisition

 
100% PCW Paper₤320K
Furniture₤900K
Eco Stationery₤990K
LPG Fuel for Hybrids₤800K

Tactical Profit

 
Consultancy₤70M
Cartography₤1M
Software₤12M
FSC Softwood₤1M

 

Key suppliers must respond to the following questions:

.

4.3.4 ENVIRONMENTAL MANAGEMENT PROGRAM

ISO 14001 Element

Section 4.3.4 of ISO 14001 requires that the organization establish and maintain programs for achieving its objectives and targets. These plans include the designation of responsibility for achieving the objective and meeting the target at each relevant function and level of the organization. The standard further requires that the plans define the means and time frame by which this is to be achieved. The standard also states that if a project relates to new development and new or modified activities, products, or services, programs shall be amended where relevant to ensure that environmental management applies to such projects.

Federal Facility Examples

Federal Agency/Facility Environmental Management Programs

U.S. Postal Service (USPS)

Chapter 3 of the US Postal Service Handbook AS-552, Pollution Prevention Guide (August 1996) discusses the link between pollution prevention and purchasing, and provides guidance on participating in USPS's affirmative procurement program. It explains the concept of affirmative procurement and provides information sources for identifying products with recycled materials. The AS-552 Guide highlights USPS policy and “addresses goals and objectives that should go into facility plans and procedures. Official adoption of these at the facility level, either by reference to AS-552 or by restating them in a plan or SOP, is what becomes part of the EMS for the facility.”25

EPA, Region 1

The EPA Region 1 Green Team focuses on the objectives and targets established by the Agency's EMS. The Regional Administrator has allocated 0.05 FTE to each Green Team Member, thus Green Team participation is included in each member's performance review. The Green Team is tasked with the following activities:

  • Continue to coordinate with the development of the EMS
  • Launch a Green Cleaning Pilot Project
  • Establish an Affirmative Purchasing Policy
  • Take advantage of the BPA for an E-catalog and ordering system for Office Supplies
  • Report on procurement of recycled content products
  • Assist the purchasing department in addressing environmental issues.26

EPA, Region 5

Region 5 has established an Environmental Management Program to achieve documented objectives and targets for the purchase of electronic equipment. Elements of the EMP:

Green specifications in requests for bids from vendors include

-Reduction in toxins (lead, mercury, cadmium, chromium),

-Postconsumer recycled content.

-Large plastic components are labeled and not painted or varnished.

-No mechanical tools are required to remove batteries.

-The use of non-separable connections is minimized.

-IT representatives trained in green electronics

-Identify products that have received certification by third party eco-label organizations, received a manufacturer's internal self-certification, or have an eco-declaration.

-Total cost of ownership will be used in the procurement decision. See Appendix B.

EPA, Region 9

To meet their green purchasing objectives and targets, Region 9 has established a cross-functional Affirmative Procurement team including two Affirmative Procurement Coordinators, one from the Facilities Program Office and one from the Contracts Office, as well as staff from P2, Solid Waste and the EMS Team. The Team reviews current procurements and develops lists of products currently purchased, their environmental attributes (recycled content levels, energy and water efficiency, low VOC, etc.), and approximate annual purchases using budget and purchasing records. The Team meets to determine research needs and priorities. The Team will conduct research and develop vendor lists and specifications on priority products and services. 27

Environmental Management Program (DRAFT May 27th) 28

EPA Region 9 also developed the following Environmental Management Program to designate responsibility and time frames for achieving its Environmentally Preferable Purchasing (EPP) objectives and targets. For additional information, visit their website:
www.epa.gov/Region9/cross_pr/ems/objectives.html

Waste - Environmental Preferable Purchasing (EPP)
EMP 5B-03

Dept: R9 EMS Team

Responsible Person: Heather White

Implementation Start Date: March 15, 2003

Objectives:

Study EPP priorities for FY04 Study best approach for inclusion of green meeting clause in all R9 contracts

Target:

Complete studies and plans by December 31, 2003

Strategy

Develop partnership with WasteWise (WW); study best areas / products to focus on; determine baseline; identify best approach for inclusion of green meeting clause in all contracts; work with PMD on green meeting language / policy; work with PMD to educate bank card holders on EPP.

Actions to Achieve Objective and Target:Target Date:Completion:
1) Create Waste Team1) March 15th 1) March 1st
2) Meet with WasteWise and Affirmative Procurement to discuss common goals 2) March 20th 2) March 11th
3) Identify study plan and measurement methods3) May 5th 3) May 22nd
4) Confirm approach with EMS Team & Advisory Committee 4) May 29th 4) May 29th
5) Meet with WasteWise and Affirmative Procurement to gather information on background 5) May 15th 5) April 23rd
6) Document EPP purchases to establish a baseline 6) June 2nd - Sept.19th 6) Ongoing
7) Study which products will be priorities in FY04 7) May 7th - Sept. 1st 7) Nov. 19th
8) Study best way to incorporate green meeting language in all contracts 8) Aug. 20th 8) May 1st - ongoing
9) Work with PMD and HQ to write green meeting language/policy for R9 9) Sept. 1st9) May 1st-ongoing
10) Work with PMD to research best way to educate bank card holders 10) July 15th 10) July 17th (mtg. with B. Bycsek)
11) Present EPP information/requirements at AO meeting 11) Aug. 29th 11) Sept. 10th
12) Present EPP information/requirements at bank card training 12) Sept. 1st12) On going-
13) Prepare study 13) Sept. 1st 13)
14) Review EMP and revise as needed 14) Sept 15th 14)

4.4.4 STRUCTURE AND RESPONSIBILITY

ISO 14001 Element

Section 4.4.1 of ISO 14001 requires that roles, responsibilities and authorities shall be defined, documented, and communicated to facilitate effective environmental management systems. Management must provide resources essential to implementation and control of the EMS. The organization's top management must appoint a specific management representative who shall have the defined role, responsibility and authority to ensure that the EMS requirements are established, implemented and maintained in accordance with the standard and must report on the performance of the EMS to top management.

Federal Facility Examples

Government agencies wisely have included procurement and contracting personnel on their EMS Team. This allows the personnel with purchasing responsibilities for the organization to become aware of the potential for green purchasing solutions to pollution prevention challenges. It also is important to designate responsibility for pursuing and achieving each green purchasing objective and target.

Federal Agency/FacilityStructure and Responsibility

EPA Region 1

Rob Guillemin of EPA Region 1 notes that “more communication needs to take place between the Green Team/EMS efforts and the purchasing department.” Originally, the head of the purchasing department was on the EPP subgroup but she was unable to attend meetings due to her hectic schedule. Consequently, full buy-in and coordination has yet to occur with the purchasing office. This is a major issue. Ideally, I would like to see a regular meeting schedule between members of the Green Team's EPP group and the purchasing office to identify areas of concern and identify areas where the EPP group could bring their time and expertise.29

EPA Region 9

Region 9 has an Affirmative Procurement/EMS Team consisting of Affirmative Procurement Leads from Purchasing and Contracts as well as representatives from the Office of Pollution Prevention and Solid Waste and the EMS staff person responsible for EPP. Management has provided documented support for EPP, even if the costs are higher, and offers awards and recognition for EPP leadership.

USDA, ARS, Beltsville Area

David Prevar notes, “The EMS at BA brings together all components of the research center into an alliance aimed at environmental protection. All employees and programs are directed to comply with affirmative procurement requirements, under a policy promulgated by the Area Director. The Biobased Products Program is integral with the Environmentally Preferable Products and Affirmative Procurement Program. In essence, all elements of the EMS involve green purchasing.”

DOD, U.S. Army, Ft. Lewis WA

Ft. Lewis found that staff lacked understanding of the Affirmative Procurement Program and how to effectively integrate it into the EMS. They also found that organizations and activities outside the environmental program were not taking responsibility for green procurement.30 To address this concern, an individual is appointed as the Program Management Team Lead for each objective.

DOI, NPS, CoEMP

The NPS Concession Environmental Management Program has emphasized that individuals responsible for purchasing should participate in the EMS. Concessioners have following through by appointing central purchasing representatives to EMS teams.

4.4.2 TRAINING, AWARENESS AND COMPETENCE

ISO 14001 Element

Section 4.4.2 of the ISO 14001 standard requires that the organization must identify training needs. It further requires that all personnel whose work may create a significant impact upon the environment receive the appropriate training. The organization shall further establish and maintain procedures to make its employees at each relevant function and level aware of: the importance of conformance with the environmental policy and procedures and with the requirements of the EMS; the significant environmental impacts, actual or potential, of their work activities and the environmental benefit of improved personal performance; their particular roles and responsibilities in achieving conformance including emergency response; and the potential consequences of departure from specified operating procedures. The standard further states that personnel performing the tasks that can cause significant environmental impact shall be competent on the basis of appropriate education, training, and experience.

Federal Facility Examples

Federal agencies traditionally have identified and implemented training to meet regulatory responsibilities. The EMS encourages evaluation of training responsibilities based on employee awareness of the environmental impacts of job performance, as well as knowledge of the organization's significant impacts and objectives and targets.

Federal Agency/FacilityTraining

NASA

Christel Van Arsdale, EMS Manager for NASA's Ames Research Center says, “We are doing training across the Center to achieve our objectives of improved CPG compliance and promotion of the 100% recycled paper product.” Training is conducted for targeted groups as well as one-on-one with bank card holders.31

USDA, ARS, Beltsville Area

To enforce the Beltsville Agricultural Research Center's Affirmative Procurement Program, staff developed an online training program. This APP training assures that all BA government purchase card users are aware of and participate in the Program. Names of employees completing the training are monitored by the Safety, Occupational Health and Environmental staff to assure that everyone is “on board.” A manual detailing the program to serve as a reference for decision makers, such as procurement and contracting officials, has been developed and distributed.32

EPA Headquarters

To meet the stated goal of buying all office supplies through EPA's tailored green online ordering system by 2005, EPA Headquarters has provided electronic and face-to-face training on how to use the online ordering system for all EPA credit card holders and office supply purchasers.33

EPA, Region 9

The Region 9 Affirmative Procurement Plan states, “The Solid Waste Program will provide training to PMD on environmentally preferable purchasing resources and guides to enable PMD to share research responsibilities beyond the first year of the program. In addition, both PMD Affirmative Procurement Coordinators and Solid Waste Program Staff will attend at least one outside training program on environmentally preferable purchasing annually to learn about new products and procurement practices. The Team will provide training to other procurement staff, purchase card holders, and program staff.”34

EPA, ESC, Fort Meade, MD

The Environmental Science Center's Procedure for EPP includes in its scope a statement that “The ESC will train its staff to purchase goods and services that reduce impacts associated with ESC's identified significant environmental aspects. The ESC will communicate specific procedures and requirements to those suppliers and contractors that provide goods and services associated with significant environmental aspects.” The Procedure also includes the following training commitment: “Members of the EMS Team will train all ESC staff who make purchases (all types of purchases, including contracts) on this procedure, EPA's EPP Goals, the resources covered in this procedure, and reporting of environmentally-preferable purchases to the EMS Team.”35

DOD, U.S. Army, Fort Lewis, WA

The Fort Lewis Director of Contracting conducts a training course for all individuals designated as purchase card holders. The class includes a section on Affirmative Procurement requirements.36

DOI, NPS, CoEMP

NPS concession contracts for visitor services, including retail, food and lodging, include a requirement for EMS training. Each concessioner must describe the training program, including staff to be trained, training subjects, including environmentally preferable purchasing, frequency of training and how training will be documented.

4.4.3 COMMUNICATION

ISO 14001 Element

Section 4.4.3 of the ISO 14001 standard requires that: with regard to its environmental aspects and its EMS, the organization shall establish and maintain procedures for internal communication among the various levels and functions of the organization; receiving, documenting, and responding to relevant communication from external interested parties; and that it shall consider processes for external communication of its significant environmental aspects and record its decision.

Federal Facility Examples

Federal Agency/Facility Communication

EPA Region 9

The Region 9 Affirmative Procurement Plan states: “ The Affirmative Procurement Program will be publicized by the Affirmative Procurement Team through EMS, WasteWise, and Pollution Prevention speakers on environmentally preferable purchasing, and through affirmative procurement training for credit card holders and contracting officers. An electronic Affirmative Procurement Annual Report will be provided to the Region, and significant purchases will be publicized in electronic WasteWise Bulletins. Information on environmentally preferable purchasing practices or products tested will be shared by the Affirmative Procurement Team, as appropriate, with EPA headquarters, other EPA regions, and Region 9 stakeholders.”37

DOI, NPS Intermountain Region

The National Park Service Intermountain Region developed a Green Purchasing Program (GPP) based on quantifiable criteria for what a product must be to be “green.” Staff is trained in the use of an internet-based program that lists products that have been screened and organized by category for easy access. Special emphasis is given to GSA, JWOD, and DLA-listed products. The program also provides features for a user to screen new products.38

DOI, NPS Grand Canyon

At the Grand Canyon, green purchasing was the first initiative selected for implementation by the EMS Team. The Team is developing a pamphlet for park-wide distribution to visitors, staff, employees and concessionaires with information on recycled content products and how they can be purchased.39

DOI, NPS, CoEMP

NPS concession contracts for visitor services including retail, food and lodging, include a requirement that each concessioner describe how the environmental policy, goals, targets, responsibilities and procedures will be communicated throughout the concessioner's organization. Each concessioner also must describe and implement a system for reporting environmental information to the Director.

USDA, ARS, Beltsville Area

The Beltsville Guide to Affirmative Procurement describes the promotion program for location employees and potential contractors or vendors: Familiarize all purchasers with APP requirements; Conduct workshops or training sessions to educate employees about their responsibilities under the APP; Distribute APP policies to all organizations along with APP training resources; Publish a list of local vendors of recycled content and biobased products that meet EPA's CPG requirements or comply with USDA's biobased product guidance; Publish articles in organizational newsletters; Update local operating instructions to include APP requirements; Seek volunteer organizations for limited trials of new products, get feedback on the cost and performance of the products, and publicize the results location wide; Consider using a facility construction or renovation project as a showcase for recycled-content and biobased building materials; Provide periodic updates through the e-mail system; Recognize outstanding efforts of personnel toward AP.40

4.4.5 DOCUMENT CONTROL

ISO 14001 Element

Section 4.4.5 of the ISO 14001 standard requires that procedures must be established and maintained for controlling documents required by the standard to ensure that: the documents can be located; the documents are periodically reviewed, revised as necessary, and approved for adequacy by the authorized personnel; the current versions of relevant documents are available at all locations where operations essential to the effective functioning of the system are performed; obsolete documents are promptly removed from all points of issue and use, or otherwise assured against unintended use; and any obsolete documents retained for legal and/or knowledge preservation purposes are properly identified.

Federal Facility Examples

This element ensures that documentation, including, for example, product specifications, purchase and contract documents, justification for the purchase of green products and/or lists of green products approved for purchase is readily available to product users and procurement and contracting personnel.

Federal Agency/Facility Document Control

DOD, U.S. Army, Fort Lewis WA

At Fort Lewis, the EMS Implementation Team placed all EMS documentation, such as plans, manuals, procedures, and forms, onto the Public Works Intranet. No paper copies are maintained, and all changes are updated and communicated automatically. The Document Manager estimates that hundreds of labor hours and reams of paper have been saved through avoidance of annual document updates and changes. This approach has been so successful that other, non-environmental programs have adopted the EMS document control model within their programs.

DOI, NPS, Grand Canyon

Xanterra Parks and Resorts maintains the official copy of its EMS on the Company intranet site. Any paper copies printed from this site are designated unofficial copies.

DOI, NPS, CoEMP

Concession contracts issued by NPS for visitor services include a requirement for an EMS that includes a Document Control and Information Management System. Each concessioner should identify how it will manage environmental information including plans, permits, certifications, reports and correspondence. NPS recommends that concessioners maintain specifications for all products purchased, especially those that are environmentally preferable, and make these specifications readily available to employees responsible for purchasing.

4.4.6 OPERATIONAL CONTROL

ISO 14001 Element

Section 4.4.6 of the ISO 14001 Standard requires that operations and activities associated with the identified significant environmental aspects must be identified in line with policy, objectives, and targets. These operations and activities, including maintenance, must be planned in order to ensure that they are carried out under specified conditions by: establishing and maintaining documented procedures to cover situations where their absence could lead to deviations from the environmental policy and the objectives and targets, stipulating operating criteria in the procedures and establishing and maintaining procedures related to the identifiable significant environmental aspects of goods and services used by the organization, and communicating relevant procedures and requirements to suppliers and contractors.

Federal Facility Examples

Many organizations have established Operational Controls for green purchasing and contracting activities. These procedures include boilerplate contract language and product specifications to ensure that green purchasing activities are implemented.

Federal Agency/Facility Operational Control
EPA Region 1

EPA Region 1 identified significant aspects including use of resources, use of energy, and air emissions. For three activities, Fleet Management, Environmentally Preferable Electronics and Environmentally Preferable Purchasing, Region 1 has established formal operational controls to ensure green purchasing. The Operational Control Procedure directs Managers to use environmental considerations as the basis for award, as appropriate. Fleet Management staff is directed to “select and procure fleet vehicles based on fuel efficiency, usage requirements and costs and national and regional policies.” Purchasers of electronic equipment are directed to purchase only Energy Star compliant computers and to purchase duplex printers for networks. Paper purchases are limited to 100% recycled content paper for printers and copiers. Recycled paper is required for business cards and name tags and recycled content for plaques and awards. These operational controls ensure that EPA New England's staff has clear direction on how to carry out green purchasing activities that may control significant aspects and reduce or eliminate environmental impacts. The complete EPA Region 1 Operational Controls Procedure is included in Appendix B.

EPA Region 5

Region 5 established the following requirements for procurement of electronic equipment:

Reduction in toxins: (lead, mercury, cadmium, chromium)

Postconsumer recycled content

Large plastic components are labeled

Plastic components are not painted or varnished

No mechanical tools are required to remove batteries

The use of non-separable connections is minimized

Processor can be upgraded

Memory can be upgraded

Storage devices can be upgraded

Spare parts are available for at least 5 years after the end of production

Total cost of ownership will be used in the procurement decision

EPA, ESC, Ft. Meade, MD

EPA's Environmental Science Center at Fort Meade, MD has developed an Operational Control Procedure specific to the process of communicating with suppliers and contractors. The procedure is designed to help ESC staff purchase goods and services that reduce impacts associated with identified significant environmental aspects and to communicate information and/or requirements related to the identifiable significant environmental aspects of goods and services used by the ESC to suppliers and contractors in accordance with the requirements of the ESC Environmental Management System (EMS).41 The procedure includes green purchasing criteria for specific products and services. For example, under Janitorial Services, contractors are directed to consult a variety of resources, including Green Seal's Choose Green Report, “General Purpose Cleaners,” March 1998, GSA's Environmental Products and Services Guide: “Cleaning Products” and “Hardware Products: Miscellaneous” sections (and any other applicable sections). In addition, the Facility Manager is directed to consult the Pennsylvania Green Building Operations and Maintenance Manual, “Cleaning Procedures” section to identify additional environmentally-preferable janitorial practices to possibly include as clauses in future ESC janitorial services contracts. This manual incorporates ASTM's Cleaning Stewardship for Community Buildings Standard.

ESC's procedure also includes the following boiler plate language required in all ESC contracts: “Each company offering a cost proposal should provide information on its environmental management system (EMS) and whether it is an EPA National Environmental Performance Track42 member to the ESC. The ESC will use this information as part of its selection criteria.”43 The full text of ESC-EP08, Environmentally-Preferable Purchases, Communicating with Suppliers and Contractors, (DRAFT, September, 2003) may be found in Appendix B.

USDA, ARS, Beltsville Area

The Beltsville Area's Affirmative Procurement Guide includes the following specific operational controls for procurement:

  • Contracts awarded by executive agencies after September 14, 1998 shall include provisions that obligate the contractor to comply with EO 13101 within the scope of their operations.
  • When USDA completes the biobased product designation, every designated biobased product that is purchased will automatically become part of this AP program.
  • If a purchaser finds that a biobased product is more preferable due to environmental attributes, technical performance, or price, it can be selected in place of a similar recycled-content product.

Recycled-content products meeting EPA guidelines will always be purchased unless they are not available competitively within a reasonable period of time; at reasonable prices; or to meet reasonable performance standards in the specifications. A written determination by technical or requirements personnel of the performance standard's reasonableness must be included with the justification. The technical and requirements personnel must base their determination on National Institute of Standards and Technology (NIST) guidelines, if available. If a product is more expensive, but has non-financial environmental or operational benefits, the purchaser is not required to claim the “reasonable price” exemption.44

Department of Defense (DOD)

The has incorporated green purchasing operational controls into contracts for custodial services and O & M as well as Design-Build Task Orders. Custodial contracts include requirements for an environmental stewardship plan, which includes an Affirmative Procurement program for EPP, use of products specified in the Comprehensive Procurement Guidelines (CPG), and a waste minimization and recycling program. The following specific requirements are included: “For the following product types, the Contractor shall use only products with the specified material contents or attributes:

(1) Bathroom tissue - The bathroom tissue shall contain at least 100% recovered materials and 50% postconsumer content.

(2) Toilet Seat Covers - Toilet seat covers shall contain at least 100% recovered materials and 50% postconsumer content.

(3) Paper Towels - The paper towels shall contain at least 100% recovered materials and 40% postconsumer content.

(4) General Purpose Industrial Wipes - The general purpose industrial wipes shall contain at least 100% recovered materials and 40% postconsumer content.

(5) Plastic trash bags - Plastic trash bags shall contain at least 25% postconsumer content.

Waste Collection Carts and Containers. Carts and containers used for the collection and/or storage of waste material shall be of noncombustible or flame resistant construction, shall be constructed of environmentally-preferable materials . . ..

O & M Contracts include requirements for energy efficiency, conformance to the APP, and meeting the goals and objectives stated in Executive Order 13101. Other contracts include the following language:

The Contractor shall integrate the use [of] EPP into the selection process for all materials used in this contract. EPP are products that reduce effects on human health and the environment which consider raw material source, production, manufacturing, packaging, distribution, use of recovered materials, reuse of product, operation, maintenance, disposal, and recyclability. These attributes shall also be balanced with overriding goals of durability, cost effectiveness (based on life cycle cost analysis), and reliability. The Contractor shall comply with requirements of the comprehensive procurement guidelines . . .

DOI, NPS, CoEMP

The NPS Concession Environmental Management Program encourages concessioners to establish, document and maintain and train employees on procedures that should be followed regarding environmentally preferable purchasing.

4.4.7 EMERGENCY PREPAREDNESS AND RESPONSE

ISO 14001 Element

Section 4.4.7 of ISO 14001 requires that an organization establish and maintain procedures to identify the potential for accidents and emergency situations, respond to accidents and emergency situations, and prevent and mitigate any associated environmental impacts. The procedure should be reviewed and revised if necessary, particularly after an occurrence of an accident or emergency situation. The procedure must be tested periodically where practical. This procedure must take into account both normal and abnormal operational conditions.

Federal Facility Examples

Federal Agency/Facility Emergency Preparedness

USDA ARS Beltsville Area

David Prevar notes that, “On occasion, spills of petroleum products occur, despite our spill prevention plans. When this happens, spill kits that are made of environmentally friendly products are used for cleanup. If a larger spill occurs, environmentally friendly containment and absorbent materials are used. One of the absorbent products used is derived from recycled corn cobs. After use on a spill, the cleanup material, instead of being disposed of as hazardous waste, is picked up by a recycling plant for use as a higher BTU fuel. This is a prime example of how products are chosen for life cycle environmental attributes. Even the Radiation Safety Unit uses a biobased product, for surface contamination cleanups. Environmental preferability is part of the culture at BARC.

4.5.1 MONITORING AND MEASUREMENT

ISO 14001 Element

Section 4.5.1 of the ISO 14001 Standard requires that documented procedures be established and maintained to routinely monitor and measure key characteristics of operations and activities that can have a significant impact on the environment. Information should be recorded to track performance, relevant operational controls, and performance with the objectives and targets. Monitoring equipment must be calibrated, maintained, and records of this process must be retained. Furthermore, a documented procedure for periodically evaluating compliance with relevant environmental requirements must be established and maintained.

Federal agencies are required to submit annual reports on their green purchasing activities as described in the chart, below:

Green Purchasing Reporting Requirements

Legal RequirementReporting Requirements

RCRA Section 6002

EO 13101

Annual report on:

Purchases of EPA-designated recycled content products

Progress in solid waste prevention, composting, and recycling

Progress in purchasing environmentally preferable products

Progress in purchasing biobased products other than fuels

Policy or procedure for implementation of the Affirmative Procurement Program (APP)

APP Training

APP compliance audits

Agency goals

http://www.ofee.gov/

Energy Policy Act of 1992 (EPAct)

Annual alternative fuel vehicle (AFV) acquisition report.

http://www1.eere.energy.gov/vehiclesandfuels/epact/state/reporting.html

Farm Security and Rural Investment Act of 2002

Requirements for reporting on purchases of designated biobased products to be determined.

EO 13123

Annual implementation plan, energy scorecard, and energy management data report to the President and Congress.

http://www1.eere.energy.gov/femp/about/annual_report.html

Federal Facility Examples

Federal Agency/Facility Monitoring and Measurement

NASA

EMS staff at NASA's Ames Research Center tracks the use of 100% postconsumer, processed chlorine-free paper to measure progress toward achieving their goal of increasing use of this paper to 10% of total office paper purchases.

DOD, U.S. Army, Ft. Lewis WA

At Fort Lewis, when objectives and targets are identified, a set of metrics is also developed to measure achievement of the objective. The Program Team Manager for the objective is responsible for providing quarterly progress reports to the Organizational EMS Representative who then provides the information to Management.

EPA ESC Fort Meade MD

The ESC included the following measurement requirement in their EPP Procedure: Reporting/Measurement of ESC Environmentally-Preferable Purchases - Whenever a purchase of environmentally-preferable goods is made, the amount purchased (not cost data) should be reported to the EMS Team for inclusion in a spreadsheet or database that will keep track of ESC's annual “green” purchases. This information will help EPA determine its progress in meeting its EPP goals and can also be used in ESC's Annual Environmental Report.

EPA Region 9

EPA Region 9's Affirmative Procurement Plan has been incorporated into their EMS. The APP states that PMD Affirmative Procurement Coordinators will have primary responsibility for overseeing program tracking. The Affirmative Procurement Team will be responsible for compiling and summarizing the information in an electronic Affirmative Procurement Annual Report which will include information on: Type of Product, Verified Recycled Content, Other Environmental Attributes, Total Cost, and any Affirmative Procurement Preference Costs. The Annual Report will also summarize the total dollar amount spent on Affirmative Procurement Products and the portion of the Affirmative Procurement Budget spent. The quantity and environmental characteristics of major purchases under this Plan will be tracked for annual reporting purposes. Purchases that go beyond the minimum requirements for environmentally preferable procurements also will also be tracked.

USPS

The Postal Service Northeast Region receives annual reports on purchases of retread tires and re-refined lubricating oil from each Vehicle Maintenance Facility.

DOI, NPS, CoEMP

NPS concession contracts for visitor services such as retail, food and lodging include a requirement that concessioners monitor and measure their environmental purchasing performance against established EMS goals and targets.

4.5.2 NONCONFORMANCE AND CORRECTIVE AND PREVENTIVE ACTION

ISO 14001 Element

Section 4.5.2 ISO of the ISO 14001 Standard requires that an organization establish and maintain procedures for defining responsibility and authority for handling and investigating non-conformances, taking action to mitigate any impact caused and for initiating and completing corrective and preventive action. Any corrective or preventive action taken to eliminate the causes of actual and potential nonconformance shall be appropriate to the magnitude of the problems and commensurate with the environmental impact. The standard further states that the organization must implement and record any changes in the documented procedures resulting from corrective or preventive action.

Federal Facility Examples

Federal Agency/Facility Nonconformance and Corrective Action

EPA ESC Ft. Meade, MD

EPA's Environmental Science Center at Ft. Meade, MD has an objective and target for Paper Consumption which states that the ESC will “develop a strategy to reduce paper consumption while increasing the recycled content and the percentage of paper recycled.” During FY03, all of ESC ‘s copy paper was changed from 30% recycled-content to 100% recycled-content, process chlorine free paper. When the switch was first made, departmental representatives communicated many complaints that the paper jammed copiers and printers. In response, staff placed individual logs next to all the copiers and printers and people were asked to document when jams occurred. This data was used in conjunction with a “paper consultant” from Boise Cascade, who was able to work with the individual machine settings to reduce the number of jams experienced by ESC staff.45

DOD, U.S. Army, Ft. Lewis, WA

At Ft. Lewis, during an EMS Internal Audit, document control and operational procedures are reviewed. If an auditor finds that a given documented procedure is not being followed, a Preventive Corrective Action Report (PCAR) is written and the activity not adhering to the procedure has to conduct an investigation and recommend a corrective action. Once the root cause of the problem has been determined and a correction implemented, it is verified by the EMS Representative and the PCAR is closed out.46

4.5.4 RECORDS

ISO 14001 Element

Section 4.5.3 of ISO 14001 states that procedures must be established and maintained for the identification, maintenance, and disposition of environmental records. The records must include training records, and results of audits and reviews. Records should be legible, identifiable, and easily traceable and protected against damage and loss. Records must be maintained to demonstrate compliance with the requirements of the standard and the EMS.

Federal Agency/Facility Records

EPA ESC Ft. Meade, MD

ESC included requirements for records management in their Environmentally-Preferable Purchases Procedure. Written communications with ESC suppliers and contractors will be retained in the EMS records. When this procedure is reviewed, records will be maintained on suggested changes, including procedural changes or tools, and why the changes were or were not included. Data on ESC environmentally-preferable purchases also will be retained in the EMS records.47

DOI, NPS, CoEMP

Concession contracts issued by NPS for visitor services, including retail, food and lodging, include a requirement that, as part of their EMS, concessioners identify records maintained to comply with applicable laws and Best Management Practices. These include training records for environmentally preferable purchasing and receipts for purchases of environmentally preferable products.

4.5.4 ENVIRONMENTAL MANAGEMENT SYSTEM AUDITS

ISO 14001 Element

Per the requirements of Section 4.5.4 of ISO 14001, an organization shall establish and maintain a program(s) and procedures for periodic environmental management system audits to be carried out in order to: determine whether or not the EMS conforms to planned arrangements for environmental management, including the requirements of the standard and the EMS documentation; and determine whether the EMS has been properly implemented and maintained and to provide information on audit results to management.

Federal Agency/Facility EMS Audits

EPA ESC Ft. Meade, MD

ESC includes requirements for annual review in its EPP Procedures. Specifically, the EMS Team will meet to review the procedure and EPA's EPP Goals. The EMS Team will discuss the procedure's effectiveness, whether it should be modified, and whether tools (e.g., web site or forms) should be developed to facilitate environmentally-preferable purchasing at ESC. To prepare for the discussion, the EMS Team should survey purchasers and meeting planners at the ESC to discuss the effectiveness of the procedure.

4.6 MANAGEMENT REVIEW

ISO 14001 Element

Section 4.6 of ISO 14001 requires that top management periodically review the EMS to ensure its continual suitability, adequacy and effectiveness. The review process must ensure that all necessary information is collected for the evaluation. The review must be documented. The review will address possible needs for changes to the policy, objectives, and the EMS with consideration for EMS audit results, changing circumstances, and the commitment to continual improvement.


7Section 6002 of the Resource Conservation and Recovery Act requires agencies to establish affirmative procurement programs to implement the buy recycled requirements of that section. EO 13101 repeats this requirement in section 402. Section 9002 of the Farm Security and Rural Investment Act requires agencies to establish affirmative procurement programs to implement the bio-based requirements of that section. The White House's Office of the Federal Environmental Executive strongly recommends that all Federal agencies create green purchasing plans which cover all their green purchasing activities. http://www.ofee.gov/

8 To access green purchasing contract language and specifications used by Federal agencies visit yosemite1.epa.gov/oppt/eppstand2.nsf

9 To register for the Green Purchasing course, log on with your email and password. Click on the Full Catalog button on the top navigation bar, then click on the Free Catalog category and select the Legislatively Mandated and Agency Required Topics category. Choose "What is Green Purchasing Anyway?"(Course ID OPM008), by clicking on its title.

10The Department of Defense Green Procurement Strategy can be accessed at http://www.ofee.gov/gp/gppstrat.pdf

11ESC Environmental Policy Statement is included as Appendix 1 to the ESC Environmental Management System Manualhttp://www.epa.gov/region3/esc/ems/pdf/Manual_ESC_EMS_081307.pdf (PDF) (16 pp, 101K, About PDF)

12 http://nodis3.gsfc.nasa.gov/main_lib.html

13Personal communication, Mary Ann McCloskey, February 4, 2004.

14Personal communication, Heather White, November 6, 2003

15 http://www.naturalstep.org/learn/principles.php

16http://nodis3.gsfc.nasa.gov/main_lib.html

17USDA Beltsville Area, Agricultural Research Service. A Guide to Green Purchasing. (2003) pp. 2-6.

18ESC. The EPA Environmental Science Center Environmental Management System Results Summary From FY 03, First Year After Registration. p. 4.

19 http://www.doi.gov/

20Personal communication, Heather Davies, DOI, November 3, 2003.

21Cape Cod National Seashore, EMS Environmental Goals and Action Plan, July, 2003.

22At Fort Lewis, the term cyclable refers to items that are reused, made of recovered/recyclable material, made of renewable resources, or can be diverted into another beneficial use after its original intended use has been exhausted. To be classified as cyclable, the entire life cycle of product has to be considered from acquisition of raw materials, through manufacture, distribution, use and disposal.

23Personal communication, Heather Davies, DOI, November 3, 2003.

24Personal communication, P.K. Wohl, CIWMB, November 13, 2003.

25Personal communication, Ron Robbins, USPS, March, 2004.

26Personal communication, Rob Guillemin, Region 1, November, 2003.

27Region 9, Affirmative Procurement Plan, p. 6.

28Personal Communication, Heather White, EPA Region 9, November, 2003.

29Personal communication, R. Guillemin, EPA Region1, November, 2003.

30Personal communication, H. Fleming, Ft. Lewis, November, 2003.

31Personal communication, Christel Van Arsdale, Ames Research Center, November, 2003.

32Personal communication, David Prevar, December, 2003.

33Personal communication, Holly Elwood, OPPT/EPP, July, 2004.

34EPA Region 9, Affirmative Procurement Plan. p. 6.

35EPA ESC Draft Procedure ESC-EP08 September 9, 2003. p. 6.

36Personal communication, Harry Fleming, December, 2003.

37EPA Region 9, Affirmative Procurement Plan, Section III (C), p. 6-7.

38Personal communication, J.Craig Erickson, November, 2003.

39Dr. Mary Ann McCloskey, Personal Communication, November, 2003.

40DOI, ARS, Beltsville Area Guide to Affirmative Procurement. (January, 2003) Section 2.2.1.2, p. 12.

41Environmental Science Center: ESC-EP08, Environmentally-Preferable Purchases, Communicating with Suppliers and Contractors, (DRAFT, September, 2003) p. 1.

42EPA's Performance Track program information http://www.epa.gov/performancetrack/program/ems.htm

43Ibid., Attachment 1.

44Beltsville Agricultural Center. Guide to Affirmative Procurement. (January, 2003) Section 2.2.1.2, pp. 6-9.

45ESC

46H. Fleming, personal communication, November, 2003.

47Environmental Science Center. ESC-EP08, Environmentally-Preferable Purchases, Communicating with Suppliers and Contractors, (DRAFT, September, 2003) p. 8.

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