Pacific Southwest, Region 9
Serving: Arizona, California, Hawaii, Nevada, Pacific Islands, Tribal Nations
Environmental Management System
San Francisco, California
Environmental Management System (EMS) Policy Manual
Table of Contents
- Purpose of EMS Manual
- Maintenance of EMS
- Implementation of EMS
- Background and History of EMS
- Description of the EPA Pacific Southwest Regional Office EMS
- Planning and Environmental Aspects
- Legal and Other Requirements
- Objectives and Targets
- Management Programs for Achieving Objectives and Targets
- Roles, Authorities and Responsibilities
- Training, Awareness and Competence
- Documentation and Document Control
- Operational Controls
- Emergency Preparedness and Response
- Monitoring and Measurement
- Non-conformance and Corrective and Prevention Action
- Internal Audits
- Management Review
- Internal Audit Programs
- Suggestions and Non-Conformance Reports
- Environmental Management Programs
- Operational Controls
Section 1—Environmental Management System (EMS)
A. Purpose of EMS Manual
This Environmental Management System Manual is a repository for documentation related to the Environmental Management System (EMS) 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 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 and References that contain additional information useful to individuals reviewing the EMS.
B. Maintenance of EMS
This EPA Pacific Southwest Regional Office (USEPA, Region 9) EMS is managed and maintained by Elyssa Bairstow, the EMS Lead.
The controlling copy of this Manual and all other EMS documentation is on this EPA Region 9 EMS Web site and the internal Region 9 EMS Lotus Notes Database.
The software that is utilized for the EMS Web site automatically generates the date when any edits are made and updates this on the bottom of the Web site files. Major revisions will be identified in the revision history of the document.
This EMS 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 office’s EMS as well as for our employees/occupants and for those responsible for maintaining this EMS.
C. Implementation of EMS
EMS Implementation Start Date: September 26, 2002
EMS Implementation Completion Date: Ongoing
On May 17, 2002, the EPA Administrator issued EPA’s own EMS policy, in which she stated: “With this policy, EPA is committing to implement EMSs for our own employees, operations and facilities. EPA will endeavor to become a leader in executing a model environmental management system within the Agency.” The EPA Southwest Regional Office is implementing this EMS; in order to become more fully aware of the adverse environmental impacts of our facility and our activities with a focus on reducing or eliminating those impacts, to reduce the amount and cost of resources by eliminating wasteful practices, and to comply with the following: Executive Order 13423, Executive Order 13514, the EPA Administrator's Position Statement (issued May 15, 2002 and revised December 15, 2005), and the EPA Administrator’s EMS Commitment Statement issued February 19, 2010. Through this EMS, EPA Region 9 will lead by example.
D. Background and History of EMSs
Formal Environmental Management Systems emerged in the early 1990s to provide organizations with a proactive, systematic approach for managing the potential environmental consequences of their operations. Such systems have been widely adopted by industry and government and have been effective at improving regulatory compliance and environmental performance.
In April 2000, President Clinton signed Executive Order (E.O.) 13148, "Greening the Government through Leadership in Environmental Management" that established a 5-year EMS implementation goal for all Federal Facilities. The Bush administration supported this position. In January 2007, President Bush signed E.O. 13423, “Strengthening Federal Environmental, Energy, and Transportation Management” which requires more widespread use of EMSs as the framework in which to manage and continually improve defined sustainability practices. E.O. 13514, "Federal Leadership in Environmental, Energy, and Economic Performance," was signed by President Obama on October 5, 2009. This EO expands environmental performance requirements and calls for continued implementation of EMSs as a management strategy to improve sustainability.EPA, as the principle steward for the environment, has taken a leadership position by developing an EMS implementation initiative. Although several recognized EMS frameworks exist, most are based on the International Organization for Standardization's ISO-14001 EMS standard. As a result, ISO-14001 is the framework on which organizations most frequently choose to base their EMS, and this is proving to be the case with U.S. Federal Facilities.
Phase 1: Planning
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.
E. Description of EPA Pacific Southwest Regional Office EMS
Every organization has its own goals that stem from the vision and aspirations of its founders and leaders. These may span the gamut from client service to social service to national defense goals. The possibilities can be virtually limitless. An EMS takes this as a fact, as a pre-existing condition from which the awareness and desire to be environmentally responsible emerge. That desire itself becomes an organizational goal when it is transformed into a commitment. Our vision, aspirations and commitment to the environment are specifically expressed in our written environmental policy. Section 2 below contains the EPA Pacific Southwest Regional office EMS policy.
The EPA Pacific Southwest Regional Office EMS Policy “Sustainable Region 9 Policy” was signed by the Region 9 Administrator on May 27, 2010 and is located on our EMS Web site.
Our environmental policy verbalizes our organization's commitment to be environmentally responsible. It 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 environmental policy is aligned with our organization's core mission and includes a commitment to continual improvement, pollution prevention, and regulatory compliance.
3. Planning and Environmental Aspects
The EPA Pacific Southwest Regional Office Environmental Aspects are listed on our EMS Web site.
Our organization's interactions with the environment are our environmental aspects. These interactions are identified by reviewing all the activities, products and services of our organization and assessing the possibility each of them have for an environmental risk or impact. Our EMS is designed to control and reduce, where possible, the impacts associated with our Significant Aspects. The procedure for identifying aspects and determining significance is located in Section 2C.
4. Legal and Other Requirements
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 memorandum. The EPA Pacific Southwest Regional Office has a procedure to identify these requirements. In most cases it is prudent for all environmental aspects with legal implications to be designated as significant. The procedure for identifying legal and other requirements is located in Section 2D.
5. Objectives and Targets
The Objectives and Targets for the EPA Pacific Southwest Regional Office EMS are listed on our EMS Web site. 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. The procedure for determining our objectives and targets is located in Section 2E.
6. Management Programs for Achieving Objectives and Targets
The Environmental Management Programs, or EMPs serve to achieve our organization’s objectives and targets, and are therefore linked directly to them. EMPs contain information describing the approaches and strategies for achieving objectives and targets, as well as the performance indicators, the operational controls, and the actions and timeframes to accomplish the objectives and targets. The EMP ties many elements of the EMS together (e.g., significant aspects, objectives and targets, responsibilities, and operational controls) and provides an integrated view of the disparate requirements in the EMS. The procedure for establishing and documenting EMPs is located in Section 2F.
7. Roles, Authorities and Responsibilities
The roles and responsibilities for activities under the EMS are clearly defined and many of these appear in the EMPs. 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, in the Pacific Southwest Regional office, an EMS Lead is responsible for leading the implementation, maintenance, and continual improvement of the EMS. An EMS Adviory Committee, composed of management from each division / office, plays an advisory role and provides on-going management support. An EMS Implementation Team, composed of staff from each division / office, assists the EMS Lead in the design, implementation and maintenance of the EMS. Other roles are assigned to members at various levels and functions throughout the organization where significant environmental aspects are present. Additional information regarding roles, authorities and responsibilities for the EMS are provided in Sections 2 A, F, K, P, Q.
8. Training, Awareness, and Competence
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 work in proximity to significant environmental aspects and focuses on the possible significant impacts of those aspects, their specific roles and responsibilities, the objectives and targets for those aspects, and the operational controls in place to avert the actualization of the potential impacts. The EMS Lead and the Safety Health, and Environmental Manager (SHEM) ensure 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 Section 2J.
Most of the documents comprising the EPA Pacific Southwest Office EMS are posted on the internet to make them readily accessible in a convenient format for our employees and our external stakeholders. 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 meeting with our building manager. These face to face meetings provided for effective two-way communication between external stakeholders and our facility.
Interested parties can communicate their views to our facility (e.g. through our EMS Web site), and we will respond to these parties. For additional information and a description of the approach taken to provide internal and external communications, see Sections 2K and 2L.
10. Documentation and Document Control
Our readily available documentation on the internet 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 of our EMS documentation and refers to and links to other essential EMS documents. Those documents that can not be made available on the web are maintained outside the web based EMS and EMS Manual and are 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 web, and printed copies are unofficial, removing obsolete documents from circulation is not necessary. For additional information and a description of the approach taken to provide document control, see the Procedure for Document Control in Section 2O.
11. Operational Control
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 specify engineering or administrative measures implemented to reduce the risk that an impact will occur. They are designed to support the achievement of EMS objectives and targets and are included as an integral component of the EMPs. The procedure for establishing operational controls is located in Section 2G.
12. Emergency Preparedness and Response
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. Due to the nature of the activities, products and services associated with the office setting of our EPA Region 9 EMS we have chosen to model our EMS on the basis of a normal condition only.
Our Emergency Procedures for our office at 75 Hawthorne Street provides for the unexpected. From the perspective of the EMS, it is necessary that measures be included in this plan 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 Section 2M.
13. Monitoring and Measurement
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 Section 2H.
14. Nonconformance and Corrective and Preventive Action
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 Section 2I.
The EPA Pacific Southwest 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 that they can be easily accessed and retrieved. Records retention time is 3 years as stated in the procedure for managing records which is located in Section 2N.
16. Internal Audits
The EPA Pacific Southwest Office will conduct internal EMS audits to test whether the system has been implemented and maintained as designed. These audits are not compliance audits. The reason to look at compliance data during an EMS audit, for example, is not to test the organization's regulatory posture, but rather to test whether the programs that have been implemented are actually working as they were intended to work 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 Section 2P.
17. Management Review
Our Management must not only formulate and articulate the environmental commitments of our organization in the 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. For additional information and a description of the approach taken to provide for management review see Section 2Q.
Originally written: January 2004
Author: Laura Bloch, EMS Lead
Section 2—Pacific Southwest Region 9 EMS Procedures
Section 2 contains all the organization's EMS procedures. Each procedure describes the methodology used by the EPA Pacific Southwest Region 9 San Francisco, CA Office to execute various elements of an integrated EMS. The purpose of these procedures is to enable individuals within the EPA Pacific Southwest Office to understand the requirements of the EMS and to ensure a reliable and consistent execution of those requirements for an effective system. Section 2 contains the authorized verbatim version of these procedures. Since these procedures are available electronically on the internet, copies will not be distributed to each relevant function and level in the organization. Individuals that need to reference them should review them via the web.
List of EMS Procedures
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- Establishing and Documenting the EMS Advisory Committee and Implementation Team (PDF) (3 pp, 56K)
- Establishing and Updating the Environmental Policy (PDF) (2 pp, 52K)
- Environmental Aspects / Identification of Aspects and Determination of Significance (PDF) (4 pp, 93K)
- Identification of Legal and Other Requirements for the EMS (PDF) (2 pp, 52K)
- Establishment of Objectives and Targets (PDF) (3 pp, 57K)
- Establishing and Documenting the Environmental Management Programs (PDF) (2 pp, 54K)
- Establishing Operational Controls (PDF) (2 pp, 53K)
- Monitoring and Measurement (PDF) (2 pp, 70K)
- Addressing Non-Conformances, Corrective and Preventive Action (PDF) (2 pp, 52K)
- Environmental Training of Employees (PDF) (3 pp, 58K)
- Providing Internal Communications (PDF) (2 pp, 71K)
- Providing External Communications (PDF) (2 pp, 54K)
- Emergency Preparedness and Response (PDF) (2 pp, 53K)
- Records Management (PDF) (1 pg, 48K)
- Document Control (PDF) (1 pg, 49K)
- Conducting Internal EMS and Compliance Status Audits (PDF) (4 pp, 62K)
- Management Review (PDF) (2 pp, 52K)
Section 3—EMS Programs and Operational Controls
This section of our EMS Manual includes documentation, references and links that allow the user to locate relevant documentation associated with the following EPA Pacific Southwest office EMS areas: our audit program, our Environmental Management Programs and our Operational Controls.
A. Internal Audit Program
The documents that describe the EPA Pacific Southwest office internal EMS Audit program for conducting audits, including our audit program scope, audit program objectives, roles, authorities, and responsibilities, auditor qualification and training, and an auditor schedule are available on the EPA EMS Lotus Notes database.
April 2007 and 2008 EMS Audit Plans, Audit Findings Summary Tables and Audit Summary Reports are available for review by contacting the EMS Lead.
B. Suggestions and Non-Conformance Reports
The EPA Pacific Southwest office maintains and monitors an electronic suggestion box that can be accessed from this Web site for employees to informally submit their suggestions. The EMS Lead also keeps an electronic file of suggestions informally communicated by employees via training sessions, email, telephone conversations, etc.
If any employee wants to lodge a more formal complaint or report an observation that is contrary to our EMS, they may contact the EMS Lead and request that a non-conformance report be filed.
C. Environmental Management Programs
The EPA Pacific Southwest office Environmental Management Programs (EMPs) were created to address each of our significant aspects. EMPs describe the general program developed to achieve the EMS Objectives and Targets. The EMP pulls together and presents in one location pieces of our EMS including; the significant aspect(s), environmental impacts, objectives and targets, legal and other requirements and references operational controls for addressing specific activities and achieving EMS objectives and targets.
Below is a list of our current Environmental Management Programs:
- Air Emissions: EMP 1-12
- Energy Use: EMP 3-12
- Material Use - Paper Use: EMP 4B-12
- Waste – Purchasing Green Products: EMP 5B-12
- Waste - Zero Waste: EMP 5C-12
- Waste - Green Meetings: EMP 5D-12
- Water Use: EMP 6-12
Because these documents are updated on an ongoing basis, they are kept electronically on the internal Region 9 EMS Lotus Notes database. Please contact the EMS Lead for more information.
D. Operational Controls
Operational Controls (OCs) describe specific operations for controlling and managing the activities, processes, products, and services associated with the significant environmental aspects of the EPA Pacific Southwest office. Some of our OCs are aligned with the EMPs described above. OCs describe our activities and the technological, operational, procedural controls on these activities, how we maintain what we are doing and fix what we do if there is a failure.
Details regarding the operational controls are kept on the internal Region 9 EMS Lotus Notes database. Please contact the EMS Lead for more information.
Section 4—EMS Records
Region 9 maintains records related to the EMS, including all documentation of actions completed under the EMS. Most of our EMS records are available on the Region 9 EMS Lotus Notes Database. This includes records such as:
- Conducting the EMS audit
- EMS Team and Advisory Committee meeting minutes
- Management Review - presentation material and meeting minutes
- Records related to non-conformance(s) including completion of corrective / preventive actions
- Copies of postings, memorandums or management bulletins that cover EMS topics.
- Records of requests from public regarding the EMS policy or any external communication regarding significant environmental aspects
- EMS employee awareness training records
- Registry of legal and other requirements
For more information, please contact the EMS Lead.
Section 5—EMS Definitions
Section 5 contains definitions of terms that might be useful to individuals coming to the EMS for the first time, or other common EMS terms for which a definition would be useful.
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