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An Overview

An Environmental Management System (EMS) is a set a management processes and procedures that allows an organization to integrate environmental concerns and issues into day-to-day decisions and practices, thereby improving both its environmental and economic performance.  In other words, no longer is maintaining compliance with environmental regulations, statutes, and laws the sole responsibility of an environmental coordinator, or in some cases, an environmental, health and safety coordinator, but the responsibility of all employees, including management. 
 
In July 1999, EPA, in a report entitled "Aiming for Excellence: Actions to Encourage Stewardship and Accelerate Environmental Progress", made a commitment to our stakeholders to encourage organizations to use EMSs that improve compliance, pollution prevention, and other measures of environmental performance. Toward that goal, EPA, in partnership with businesses, academia, and state/local government agencies, has developed several EMS guidance documents (see EMS resources).   Most of these guides are based on ISO 14001 which is the international standard for an EMS established in 1996 by the International Organization for Standardization Exit EPA disclaimer .  However, they do differ depending on what the author of the particular guidance believes is wrong with the ISO EMS model. For instance, EPA's National Enforcement Investigations Center believes that the ISO standard is weak on explicit compliance assurance language so they developed a Free PDF reader available Compliance-Focused EMS model.  By the way, since this model is used as the basis for EMS requirements in EPA settlement agreements, it is worth reading. Yet despite the differences between the various EMS guidance documents, all of them seem to agree that the following 12 key elements should be in an EMS:
 
1. Environmental Policy - All successful EMSs have top management commitment and support. Although it is possible for an organization to adopt ideas generated at the grassroots level, it is more likely that such ideas will be dismissed unless they have a champion with sufficient organizational clout to advance them. If management commitment is seen as lacking, environmental concerns will not receive the priority they deserve.  As a result, an organization must have a written environmental policy that clearly communicates top management's commitment towards a cleaner environment. This policy will serve as the foundation for the organization's EMS and provide a unifying vision of environmental concern by the entire organization. Ideally, this policy should contain the following five commitments:
  • Compliance with applicable federal, state, and local environmental requirements;
  • Continuous improvement in environmental performance, including areas not subject to regulation;
  • Provide adequate resources to make the EMS work, including skilled personnel, technology, and financial resources;
  • Pollution prevention (e.g., source reduction); and
  • Public outreach/community Involvement.
2. Structure, Responsibility, and Accountability - For an EMS to be effective, one needs to lay out the organizational structure and lines of responsibility for the environmental system. Without a clear structure showing who is in charge and who is accountable for getting things done, the system components will not mesh as well as they should and the benefits of the system will be reduced. Thus, you should, at a minimum, 
  • Develop organizational charts that identify units, management, and other individuals having environmental performance and regulatory compliance responsibilities;
  • Identify and define duties, roles, responsibilities, and authorities of key environmental program personnel in implementing and sustaining the EMS;
  • Specify the accountability and responsibilities of management, on-site service providers, and contractors for environmental protection practices, assuring compliance, required reporting to regulatory agencies, and corrective actions implemented in their area(s) of responsibility;
  • Create incentive programs to reward and recognize employees for excellent environmental performance;
  • Outline the potential consequences for departure from specified operating procedures, including liability for civil/administrative penalties imposed as a result of noncompliance;
  • Designate a management representative who will ensure that the EMS is developed, implemented, and maintained; and
  • Recognize environmental responsibilities as a primary responsibility of all employees, including management (i.e., do not confine environmental responsibilities to an environmental office).
3. Communications - The third key element of an EMS is the establishment of a system for communicating environmental issues and information internally to all employees, on-site service providers, and contractors and externally to customers, regulatory agencies, neighbors and other interested parties and a system for receiving and addressing their concerns. Please note that effective internal communications require mechanisms for information to flow top-down AND bottom up.  Since employees are on the front lines, they are often an excellent source of information, and ideas on how to improve the organization's environmental performance, such as identifying pollution prevention opportunities. However, remember to choose a method of receiving information and suggestions from employees that will protect them from negative repercussions. As for the external communications strategy, an organization needs to decide how proactive it wants to be. The strategy must include, at a minimum, protocols for responding to inquiries and requests from interested parties for release of EMS and environmental performance information and for interacting with regulatory agencies regarding environmental issues and regulatory compliance, including required reporting. However, some organizations have found that a more proactive external communications strategy can be beneficial even though it may require more resources. For example, reporting on your environmental performance may give you an edge over your competition. It may also improve your relationship with the surrounding community. In addition, external stakeholder bring useful perspectives to identifying environmental issues, often identifying issues that might otherwise have been overlooked, thereby improving the EMS.
 
4. Environmental Requirements and Voluntary Undertakings - In order for an organization to be in compliance with applicable laws and regulations and to conform with the various non-legal requirements such as industry codes or EPA Voluntary Programs to which an organization may subscribe, it must first know what those environmental requirements and "voluntary undertakings" are, and how they affect what the organization does. Thus, an EMS should provide a means to identify, interpret, and effectively communicate environmental requirements and voluntary undertakings to affected employees, on-site service providers, and contractors.  It should also include procedures to ensure that the organization meets these environmental requirements and voluntary undertakings. In addition, the EMS should specify procedures for anticipating changes to environmental requirements - including new requirements that may apply as a result of changes in operations - an incorporating those changes into the EMS.  As an aside, EPA Region 2 recently developed a Compliance Website to help organizations obtain information about applicable laws and regulations. 
 
5. Environmental Impacts - Before an organization can plan for and control its significant environmental impacts, it must first know WHAT these impacts are and WHERE these impacts come from. Therefore, an EMS should contain an ongoing process for assessing an organization's products, activities and services as well as those of its contractors and on-site service providers for the purposes of determining how these products, activities, and services interact with and impact the environment as well as determine the significance of these impacts.  This process, should, at a minimum, identify activities where there is a potential for accidents and emergencies. It should also identify operations and waste streams where equipment malfunctions and deterioration, operator errors, and discharges or emissions may be causing, or may lead to releases of hazardous waste or other pollutants to the environment, a threat to human health or the environment, and violations of environmental requirements.  Finally, the EMS should provide a mechanism to keep this impact information up-to-date and to use the information in setting objectives and targets, establishing operational controls, defining monitoring needs, and in planning and designing new processes and products. 
 
6. Operational Control - To ensure that an organization's environmental policy is followed and that it's objectives are achieved, certain activities must be controlled. Where these activities are complex and/or their potential environmental impacts are significant, these controls should take the form of documented procedures. These documented procedures will help an organization ensure regulatory compliance and consistent environmental performance. Thus, an EMS must include a process for identifying activities were documented standard operating procedures (SOPs) are needed and it should define a uniform process for developing, approving, and implementing these SOPs. 
 
7. Corrective/Preventive Action and Emergency Response - Despite an organization's best efforts, the possibility of violations, accidents, and other emergency situations still exists. Thus, establishing a corrective action process is a critical part of any EMS and merits special attention. Without an effective corrective and preventive action program, an EMS is just a collection of procedures and is not a system that will last or improve over time. Therefore, an organization needs to establish procedures for preventing, detecting, investigating, correcting, and reporting any occurrence that may cause the organization to deviate from its environmental policy.  Particular attention, of course, should be paid to incidents that may have an effect on compliance with environmental requirements as well as on environmental performance in regulated and non-regulated areas. These procedures, at a minimum, should include:
  • Routine, objective, self-inspections by department supervisors and trained staff, especially at high risk/hazard locations identified during the assessment;
  • Internal and external reporting of potential violations and release incidents;
  • Investigation and prompt and appropriate correction of potential violations (the investigation process includes a root-cause analysis of identified problems to aid in developing the corrective action);
  • A process for mitigating any adverse impacts on the environment that may be associated with accidents or emergency situations and for ensuring that similar incidents are avoided;
  • A system for development, tracking, and effectiveness verification of corrective and preventative actions; and
  • Periodic testing of emergency plans/procedures, wherever practicable.

8. Monitoring/Measurement - Some say that an EMS without an effective monitoring and measurement program is like driving at night without the headlights on - you know that you are moving, but you don't know where you are going. Monitoring and measurement enables an organization to assess how well the EMS is working and to identify steps to improve the system.  At a minimum, a monitoring and measurement program should include: 

By the way, to encourage organizations to conduct compliance audits, EPA has agreed to eliminate or substantially reduce monetary penalties for violations that are voluntary discovered and disclosed to us, provided that certain conditions are met. These conditions are outlined in our Voluntary Audit Policy and Small Business Policy and are designed to ensure that human health and the environment are not compromised. For more information, please visit our compliance incentives webpage. 

9. Training, Awareness, and Competence - Training employees about environmental management is needed for two reasons. First, every employee can have an impact on the environment. Therefore, they need to understand how their actions affect the organization's environmental performance and how to perform their work so as to proactively avoid or mitigate the occurrence of environmental incidents. Second, any employee can have good ideas about how to improve the organization's environmental management efforts. Trained personnel are better able to understand the processes for which they are responsible and therefore more likely to offer suggestions to improve those processes. As a result, an EMS should establish procedures to ensure that all personnel (including employees, on-site service providers, and contractors) whose job responsibilities affect the ability of the organization to achieve its EMS goals have been trained and are capable of carrying out these responsibilities.  Particular attention, of course, should be paid to personnel responsible for meeting and maintaining compliance with environmental requirements and/or whose tasks can cause significant environmental impacts. At a minimum, everyone in the organization should be trained on the environmental policy, the significant environmental impacts of their work, their roles and responsibilities within the EMS, the SOPs and environmental requirements that apply to their activities, and what could happen if they don't follow procedures.  Remember to document any training provided and to train employees on a continuous basis to keep them abreast of new regulations, procedures, technological developments, etc.

10. Organizational Decision-Making & Planning - In order for an organization to translate its environmental policy into action, it must set specific objectives and targets and develop action plans to achieve these objectives and targets. Thus, an EMS should:

Responsible environmental management should be one of the main pillars of the organization, not an ancillary concern or afterthought. Thus, if an organization is planning on constructing a new building, it should look at the environmental concerns associated with that construction at the same time to avoid creating new significant environmental impacts that will have to be addressed later.  

11. Records Management and Document Control - The value of records management is fairly simple - an organization needs to be able to prove that it is actually implementing its EMS as designed.  Basic records management is straightforward, an organization needs to decide:
  • what records will be kept;
  • who maintains them and where;
  • how long they are kept, taking into account record retention requirements in applicable environmental regulations;
  • how they are accessed (some records may require additional security); and
  •  how they are disposed.
The organization should also establish document control procedures so that everyone is working with the correct, and up-to-date SOPs, drawings, and other documents. These procedures should ensure that:
  • EMS documents can be located;
  • they are periodically reviewed, updated and approved for adequacy by authorized personnel;
  • obsolete documents are removed; and
  • current versions are available where needed.
12. Continuing Program Evaluation and Improvement - Just as a person should have periodic physical exams, an EMS must be audited and reviewed by management from time to time to stay "healthy".  Periodic EMS audits will establish whether or not the EMS is being carried out in the specified manner.  The frequency of these audits is up to the organization.  However, as a rule of thumb, all parts of the EMS should be audited at least annually.  The organization can audit the entire EMS at one time or break it down into discrete elements for more frequent audits.  The results of the audits should be documented and discussed with top management in order to ensure that corrective action plans are developed and implemented in a timely manner. Also, during their EMS reviews, management should assess how changing circumstances such as new facilities, changes in activities, new scientific data, new stakeholders concerns, etc. might influence the suitability, effectiveness, or adequacy of the current EMS and whether or not it needs to be changed to meet the organization's ever evolving goals and needs. 

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