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Section 1 — Environmental Management System (EMS)
3. Planning and Environmental Aspects
4. Legal and Other Requirements
5. Objectives and Targets
6. Management Programs and Workplans for Achieving Objectives and Targets
7. Roles, Authorities and Responsibilities
8. Training, Awareness and Competence
10. Documentation and Document Control
11. Operational Control
12. Emergency Preparedness and Response
13. Monitoring and Measurement
14. Evaluation of Compliance
15. Non-conformance and Corrective and Prevention Action
17. Internal Audits
18. Management Review
Section 2 — Procedures
A. Significant Aspects
B. Legal and other Requirements
C. Document Control
D. Objectives and Targets
E. Environmental Management Programs
G. Emergency Preparedness and Response
H. Identifying Operational Controls
I. Management Review
J. Internal Auditing and Evaluation of Compliance and Status
K. Environmental Training of Employees
M. Non-Conformances, Corrective and Preventive Actions
N. Monitoring and Measuring
Section 3 — Programs and Operational Controls
A. Audit Program
B. Suggestions and Non-Conformance Reports
C. Management Programs and Work Plans Achieving Objectives and Targets
D. Operational Controls
Section 4 — Records
Section 5 — Definitions
Section 6 — References
Section 7 — Appendices
SECTION 1 — ENVIRONMENTAL MANAGEMENT SYSTEM
This Manual is a repository for documentation related to the Environmental Management System including:
- EMS Procedures that describe how we carry out key tasks within the EMS such as training, identifying environmental aspects, or managing records.
- Programs & Controls that operate under the EMS, such as work plans and programs for achieving EMS objectives and targets and carrying out audits.
- EMS Records or directions that enable individuals to locate appropriate records that confirm the completion of specific EMS activities such as, the identification of Environmental Aspects, EMS training that has been given to specific employees, or the completion of management reviews.
- Definitions, References, and Appendices that contain additional information useful to individuals reviewing the EMS.
Our EMS is managed and maintained by the EMS Coordinator/Management Representative and the Mid-Atlantic Multi-Site Workgroup as well as facility specific EMS teams.
A printed or hard copy version of this Manual is available in the EMS Coordinators office. However, this is not the controlling copy of the EMS Manual. The controlling copy and all other major EMS documentation is maintained on our portal site. The Revision History on documents is used to include a brief description of changes and why they were made.
This Manual documents the environmental management programs, the operational controls, the EMS audit program, procedures, records and other descriptive information useful to anyone interested in our Multi-Site EMS as well as for our employees/occupants and for those responsible for maintaining this EMS.
Our EMS works on an annual schedule of planning, doing, checking and acting.
Multi-Site EMS Implementation Start Date: February 2010
Multi-Site EMS Implementation Completion Date: Ongoing
We are implementing this EMS to focus on reducing or eliminating environmental impacts. Our EMS conforms with:
- EPA’s Commitment to EMS Statement, October 2006
- EPA Guidance on Implementing EMS “at all appropriate levels” of a Federal Agency Pursuant to EO 13423, October 2008
- EO 13514 - Greenhouse Gas (GHG) accounting/reductions goals, October 2009
- EPA 2020 25% GHG reduction goal for Scope 1 and 2 emissions, December 2009
- EPA Organizational EMS Manual, June 2010
- Strategic Sustainability Performance Plan FY2010-FY 2020 (PDF) (41 pp, 1.25MB, About PDF )
- Agencywide Objectives, Targets and Metrics (OTMs), December 20, 2011
We have been a leader within EPA for the development and implementation of EMS for our facilities and operations.
- The Environmental Science Center (ESC) in Fort Meade, MD piloted EMS at EPA and in 2002 had the first third party certified EMS in the agency. The ESC helped created guidance, templates, documents and other materials ultimately used at 34 EPA facilities nationwide.
- In 2005 our Philadelphia office became the first EPA office to have a third party certified EMS. The Philadelphia office also developed an extensive website that provided an example of a complete EMS and EMS documents for our employees and the public.
An EMS is a cycle of planning, doing, checking and acting with the goal of continuous improvement and prevention of pollution.
The organization identifies how its operations might harm the environment, and develops methods to reduce this harm.
Phase 2: Doing
The organization implements these methods to reduce harm and operates them for a designated time period.
Phase 3: Checking
The organization assesses whether the methods that it is operating to reduce environmental harm and ensure regulatory compliance are proving to be effective.
Phase 4: Acting
The organization determines what changes are necessary based on the performance assessment of the methods (see Phase 3) designed to reduce environmental harm.
The findings of Phase 4 may indicate that adjustments to methods already in place are necessary or that entirely new methods are needed to achieve established environmental objectives. Output from this phase is fed back into Phase 1 Planning, to make necessary changes and additions designed to bring the EMS to the desired level of effectiveness. This system feedback propels the continual improvement of the EMS.
The EMS continually moves through this cycle, fine-tuning its management of those areas of the organization's operations that harm the environment. This "continual improvement cycle" is a core tenet of the EMS; it allows the system to adapt to the dynamic nature of the organization's operations.
The scope of the EMS is for our facilities (listed below), activities, products and services and the commuting and business travel of our employees.
Our vision, aspirations and commitment to the environment are specifically expressed in EPA's mission statement and environmental policy. Section 2 below contains the EPA Mid-Atlantic office EMS policy.
EPA Mission Statement
EPA's mission is to protect human health and to safeguard the natural environment - air, water, and land - upon which life depends.
A list of our aspects, impacts and significant aspects for EPA Mid-Atlantic office that might result in an environmental risk or impact is maintained on this website.
Our EMS Policy is signed by the Senior Managers and is located on our EMS website.
Our Safety, Health and Environmental Policy for the Middle Atlantic Region is a declaration of our senior management's commitment to the environment, and serves as the foundation for the EMS. Everyone in our organization is expected to be familiar with and understand our policy. Our policy is considered when setting EMS objectives and targets, and it is understood that the implementation of the EMS serves to operationalize the commitments in the policy. Our environmental policy statement is, therefore, a vehicle for communicating our organization's aspirations for environmental protection as well as a functional tool for establishing the operational boundaries of the EMS. Our policy is aligned with our organization's core mission and includes a commitment to continual improvement, pollution prevention, and regulatory compliance. Our policy statement reflects management consensus on its content and aims, and was formally endorsed by having these senior managers be signatories of the policy.
Our Environmental Aspects are listed on our EMS website. Procedures for identifying our significant aspects are located on our intranet website.
Our organization's interactions with the environment are shown in our environmental aspects. They are identified by reviewing all the activities, products and services of our organization and assessing the possibility each of them have for an environmental impact. Our EMS is designed to control and reduce, where possible, the impacts associated with the identified aspects.
The legal and other requirements that apply to our operations are a combination of federal, state and city statutes, regulations, executive orders, as well as internal EPA policies. Our current Table of Legal and Other Requirements is posted on our intranet website and is available to the public upon request through our contacts page.
Our EMS recognizes that certain environmental aspects are significant for an organization because they are regulated or the subject of certain legal or other requirements, which can affect our organization's ability to carry out its mission. These may include federal, state and city laws, regulations, executive orders, as well as, industry standards, and organizational policy, guidance and memoranda. We have a procedure to identify these requirements. In most cases it is prudent for all environmental aspects with legal implications to be designated as significant. Our procedures for identifying legal and other requirements is posted on our intranet website and is available to the public upon request through our contacts page.
Current Objectives, Targets and Metrics for our EMS are listed on this website. Our procedure for determining our objectives and targets is posted on our intranet website and is available to the public through our contacts page. Our objectives and targets are established to address our significant environmental aspects and are integrated at all levels and functions of our organization. Objectives and targets are set by considering, in part, the legal and other requirements, the views of interested parties, as well as, technological, financial and other operational considerations. This ensures that our objectives and targets are robust, that they respond to legitimate concerns, that they are realistic for the organization, and that it is possible to develop strong management programs to achieve them.
Our Environmental Management Programs or EMPs and Work Plans contain information describing our program approaches and strategies for achieving our objectives and targets, as well as the performance indicators, and the roles and responsibilities for accomplishing tasks, and the competency of individuals associated with those tasks. Our EMPs tie many elements of the EMS together (e.g., significant aspects, objectives and targets, resources, responsibilities, and capabilities) and provide a link to our Work Plans that describe how we will strive to achieve our objectives and targets. The Work Plans contain details on the resources (e.g., financial, human, and technological) and timeframes and milestones to accomplish the objectives and targets. The Work Plans are accessible from links on Objectives and Targets page on our EMS intranet website. The procedure for developing our EMPs and Work Plans is also located on the intranet website.
7. Roles, Authorities and Responsibilities
The roles and responsibilities for activities under the EMS are clearly defined and as stated above; many of these appear in the EMS programs and operational controls. While our EMS is largely sustained by the voluntary participation and commitment of our employees, certain duties are assigned with clear roles and responsibilities and with attendant accountability for performance and results. For example, senior management must appoint an EMS Coordinator/Management Representative to be responsible for leading the creation, implementation, and maintenance of the EMS. Senior management must approve our EMS goals, provide the necessary resources to achieve our objectives and targets, be champions in communicating goals to employees and, at least annually, approve adjustments recommended or needed for continuous improvement of our EMS. We have integrated our EMS into our operations and other roles are assigned to people at various levels and functions throughout our organization where their responsibilities relate to our significant environmental aspects or where they may track data on metrics that monitor and measure our progress on achieving our objectives and targets. Finally, our EMS Multi-Site Work Group and local EMS Teams, consisting of representatives of all major organizations in our offices/facilities, also play a major role in ensuring the success of our EMS. Additional information regarding roles, authorities and responsibilities is provided in related procedures F, J, Q, and R. that are posted on our intranet website and available to the public upon request through our contacts page. The organizational table below also shows roles and responsibilities of key Multi-Site Team members.
|Tier 1||Office of Administration and Resources Management||Agency–wide|
|Tier 2||Mid-Atlantic Multi-Site Environmental Management Systems||Region 3||Greg Allen, Frank Borsuk, Pat Bourgeois, Franklin Bueno, Robin Costas, Nicholas DiNardo, Jeff Dodd, Steven Donohue, Ann-Heng Jen, Patrick Lantzy, Lynda Podhorniak, Skip Weisberg|
|Environmental Science Center||Jeff Dodd (lead) and 8 members|
|Philadelphia||Nick DiNardo (lead) and 14 members|
|Chesapeake Bay Program Office||Greg Allen (lead) and 5 members|
|Wheeling||Frank Borsuk (lead) and 7 members|
Our EMS requires two types of training: general awareness, and competence training. General awareness training for all our employees focuses on the importance of the environmental policy, the role of employees, and the potential consequences of failing to provide environmental care. Competence training is prescribed for our employees that have specific roles and responsibilities related to the EMS significant environmental aspects, the objectives and targets for those aspects, and/or the operational controls in place to avert the actualization of the potential impacts.
Competence training is detailed in the EMS programs and in the documentation of operational controls. Most of our competency training on our operational controls is done in email messages sent to all our occupants. The EMS Management Representative/Coordinator ensures that both types of training are conducted as appropriate to satisfy these requirements. For additional information and a description of the approach taken to identify EMS training needs, see procedure F that is posted on our intranet website and is available to the public upon request through our contacts page.
Most of the documents comprising our EMS are posted on the internet or intranet to make them readily accessible in a convenient format for our employees. Documents not on our internet are available to the public and our external stakeholders through our contacts page upon request. Clearly, effective integrated environmental management demands effective communications to coordinate staff internally and to liaise with external stakeholders. Maintaining employee awareness of EMS initiatives, motivating them, and supplying them with knowledge of their roles and responsibilities all require communication. It is also true that communication is a two-way process; that employees can make recommendations to management and give their views when necessary.
We have tried to consider the views of interested parties in our EMS by first making our information readily available on the internet and where we are tenants in a building, meeting with the building manager and the other main tenants. These face to face meetings provide for effective two-way communication between external stakeholders and our facility.
Interested parties can communicate their views to our facility, and we will respond to these parties. The EMS Work Plans provide for outreach to external stakeholders including our building landlords, our buildings' other tenants, as well as suppliers and vendors, to make them aware of our EMS. For additional information and a description of the approach taken to provide internal and external communications, see procedures J, K and L that are posted on our intranet website and available to the public upon requrest through our contacts page upon request.
Our readily available documentation on the internet and intranet and document control procedures ensure that we are maintaining information in a manner that would allow someone with a legitimate interest in the EMS to understand how it is designed and implemented. Our web based EMS also provides all the information that is essential for employees to know about EMS issues, as well as providing this information for external parties such as contractors, vendors, other regulators, registrars and other interested parties. This EMS Manual provides an overview or our EMS documentation and refers to and links out to other essential EMS documents. However it is likely that some documents will be maintained outside the web based EMS and EMS Manual in which case they will just be referenced in the Manual.
Due to the wide variety of documents used in the EMS it is essential that a formal approach be developed to control and organize them. Our web based system and document control procedure ensures that documents being used are the most up-to-date versions. Since the controlling copy of the EMS is on the internet or intranet, and printed copies are unofficial, removing obsolete documents from circulation is not necessary. For additional information the creation, review and approval of documents and a description of the approach taken to provide document control, see procedure N that is posted on our intranet website and is available to the public upon request through our contacts page.
It is important to control those activities, products or services that might cause a deviation from our organization's environmental policy or result in significant impacts. Our Operational Controls are designed to support the achievement of EMS objectives and targets. Our operational controls specify engineering or administrative measures implemented to reduce the risk that an impact will occur. Our Operational Controls document describes who, what, how, when and where for activities we want to manage that are related to our EMS. For development of our operational controls, see procedure D that is posted on our intranet website and is available to the public upon request through our contacts page.
Our EMS provides a systematic method to manage known and expected elements of our organization's operations. However, despite best efforts there is the possibility of unpredictable accidents and emergencies.
Our Emergency Procedures and Occupant Emergency Plan (OEP) provide for unexpected occurrences and spell out emergency procedures for occupants of each of our facilities to follow. The OEP is posted on our intranet website and is available to the public upon request from our contacts page. From the perspective of the EMS, it is necessary that measures be included to address the environmental consequences of such occurrences. It is expected that such measures work to control and mitigate those possible environmental consequences. For additional information and a description of the approach taken to provide emergency preparedness and response, see procedure G that is posted on our intranet website and is available to the public upon request through our contacts page.
Monitoring and measurement is fundamental to our EMS, it ensures that management plans, controls, and training are effective. Furthermore, it enables our organization to identify its progress toward achieving objectives and targets, and the reasons for our level of achievement. Without effective monitoring and measurement it would be impossible for us to continually improve - which is the basis of our EMS. We will periodically monitor performance, operational controls, and general conformance with EMS objectives and targets. For additional information and a description of the approach we have taken to provide monitoring and measurement see procedure I that is posted on our intranet website and is available to the public upon request through our contacts page.
Our facilities are routinely evaluated for compliance by several mechanisms. Internal Safety, Health and Environmental Management (SHEM) compliance audits are conducted on each of our facilities annually by EPA SHEM Managers, with written reports produced and shared with all responsible entities and officials. Results and corrective actions from the facility internal audits are discussed with the Assistant Regional Administrator each year, who certifies their completion in writing to EPA Headquarters annually. EPA Headquarters routinely conducts external SHEM compliance inspections on our facilities, typically at three year intervals for laboratories and five year intervals for offices, with formal written reports produced and provided to appropriate EPA senior managers. Corrective actions for each compliance finding are tracked by EPA headquarters, with verification of timely and proper remediation. Additionally, each facility is subject to inspections by other federal agencies, state and local government officials for the evaluation of compliance.
When we identify a weakness in our EMS or an ineffective part of our EMS, we will initiate and effect a correction. Our EMS has procedures to receive, document and investigate problems, understand their root causes, and then implement corrective actions that prevent recurrence. For additional information and a description of the approach taken to address non-conformances in our EMS see procedure P that is posted on our intranet website and is available to the public upon request through our contacts page.
The EPA Mid-Atlantic Office understands it is critical to effectively implement and carry out all the various elements of the EMS, and that it is also important to be able to demonstrate that you have done so. We will do this through the creation and management of records of various implementation activities and other EMS results from training, audits and management reviews. Our records will be managed so that they can be easily accessed and retrieved. Document Retention is done in accordance with EPA records schedule 0089.
We consider all EMS records as administrative records which may be destroyed when they are two years old or no longer needed.
We will conduct internal EMS audit to test whether the system has been implemented and maintained as designed. An internal audit will assess whether the EMS implemented is conforming to the requirements of EPA EMS audit protocol. It will determine if the EMS has been implemented at all our facilities and is operating systematically achieving the desired goal. The audit will also fulfill the requirement for periodic evaluations of compliance to legal and regulatory requirements. The audit will test whether the program that has been implemented is actually working as intended to achieve and maintain compliance. We will use our EMS internal audits to gauge the status on regulatory compliance. For additional information and a description of the approach taken to provide for EMS internal audits, see procedure Q that is posted on our intranet website and is available to the public upon request through our contacts page.
Our EMS reserves a special role for senior management, as well it should. Our Management must not only formulate and articulate the environmental commitments of our organization in environmental policy, but must also render judgment on whether the EMS continues to be suitable, adequate and effective. This is accomplished through the periodic management review that affords our management the opportunity to judge the EMS and its results. On that basis, management is expected to make decisions relative to the EMS so that it continues to perform and deliver as expected.
The Management review is the last phase of our annual EMS cycle. Our EMS works on an annual schedule of planning, doing, checking and acting.
Author: Multi-Site EMS Team / EMS Coordinator
Originally written January 2013
Reviewed and Approved: Senior Management