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Deputy Administrator's Announcement of EMS Strategy
MEMORANDUM:
DATE: April 12, 2004
SUBJECT: Role of Environmental Management Systems in Permits and Rules
Environmental Management Systems (EMS) are a powerful business tool that help integrate environmental considerations into the day-to-day decisions and practices of different types of organizations and improve environmental performance and compliance. The Agency's policy, pursuant to the EPA Position Statement on EMS (May 15, 2002), is to promote the voluntary adoption of EMS across a wide range of organizations and settings.
In this memorandum, I am reaffirming EPA's commitment to help organizations adopt EMS designed to achieve improved environmental performance and compliance, communication with stakeholders and pollution prevention at reduced cost. Additionally, I am announcing a complementary effort to partner with states to objectively test the role of EMS in environmental permits and rules. Many states have already begun exploring this area and our mutual goal is to gain experience and data about the broader implications of EMS in regulatory programs.
I ask that each program and regional office focus on three EPA priorities:
- Promote adoption of EMS - EPA now actively promotes EMS through a wide array of assistance, recognition and enforcement programs. We should continue to look for opportunities to help organizations in other ways.
- Implement at EPA facilities - Each program and regional office should be working to adopt high quality, effective EMS at our facilities. Under OARM leadership, we are now developing EMS at about 34 EPA facilities and will meet the deadline of full implementation prior to the 2005 deadline contained in Executive Order 13148.
- Integrate EMS into environmental programs - EPA supports ways to use EMS to improve environmental performance, including OECA's use in enforcement settlements, OW's work with municipalities, OPEI's work in Performance Track, sectors and small business programs, and a wide range of regional projects. We should continue these efforts and find additional opportunities to link the power of EMS with our core program work.
Attached is the Strategy for Determining the Role of EMS in Regulatory Programs. This strategy will build on EPA's substantial success working to promote EMS in a wide range of programs and situations. Our intent is to encourage well-designed experimentation in permits and rules based on a defined set of principles and policy ideas to test. EPA does not intend to mandate the use of EMS in permits or rules. Voluntary programs will remain the primary way EPA promotes EMS use.
The National Center for Environmental Innovation will work with all of you to implement the strategy, in partnership with states. Our goal will be a limited number of carefully designed projects that can help inform future policy decisions about the appropriate role of EMS in environmental permits and rules.