Guide to Developing an Environmental Management System - Do
Building an Environmental Management System (EMS) might sound like an overwhelming task for a smaller organization, but it need not be. Taken in steps, it is a job that small and medium sized organizations can tackle. These pages will take you through basic steps as they are outlined in the 2001 Second Edition of Environmental Management Systems: An Implementation Guide for Small and Medium Sized Organizations. This page pulls out particular steps from the "Do" section of the Guide, and points back to specific pages in the guide to fill out worksheets and get additional materials.
Several up front EMS planning tasks (such as gaining top management commitment) were described in the "Plan" stage and should be completed prior to putting these next steps into place. This "Do" stage begins the step-by-step action plan for developing these elements of an EMS. It describes a logical sequence for planning and implementing EMS elements and explains how this sequence can be important in building an effective EMS.
The Roadmap for EMS development, page 79 of Environmental Management Systems: An Implementation Guide for Small and Medium Sized Organizations, outlines the steps in the "Do" process in a diagram. Keep in mind that this is just one way to do the job - you might find other approaches that work just as well. Each step of the suggested implementation process flow (and a rationale for its sequence) is discussed below.
A few hints to keep in mind as you build your EMS:
- You may already have some EMS elements in place, as indicated by the preliminary review that you performed earlier. Make sure to build links between elements. The effectiveness of your EMS depends as much on the strength of its links as it does on the strength of the individual elements.
- For many EMS elements, you will need to design and implement a process. In these cases, you also should consider documenting the process in the form of a procedure.
Do: Implementing, including training and operational controls
- Step 1: Identify Legal and Other Requirements
- Step 2: Identify Environmental Aspects and Related Products, Operations, and Activities
- Step 3: Define Views of Interested Parties
- Step 4: Prepare Environmental Policy
- Step 5: Define Key Roles and Responsibilities
- Step 6: Establish Objectives and Targets
- Step 7: Develop Environmental Management Programs, Identify Operational Controls, and the Identify Monitoring and Measurement Needs
- Step 8: Establish Corrective Action, Document Control, and Records Management Processes
- Step 9: Establish Operational Controls and Monitoring Processes
- Step 10: Define Job-Specific Roles and Responsibilities
- Step 11: Plan and Conduct Initial Employee Awareness
- Step 12: Establish Other System-Level Procedures
- Step 13: Prepare EMS Documentation (Manual)
- Step 14: Plan and Conduct Specific Employee Training
A first step in the EMS-building process is understanding the legal and other requirements that apply to your products, activities and services. This step is important for understanding compliance obligations and how these obligations affect the overall EMS design. For example, you might have an operation that is covered by an air quality permit, or might provide a service that results in the generation of regulated wastes. Your EMS should include processes to ensure that legal requirements are addressed.
Once you understand legal requirements, you should assess how your organization interacts with the environment. Identify environmental aspects and impacts, and determine which are significant. Some environmental aspects may be regulated, while others may not be. For example, if you identify the generation of a particular air emission as a significant environmental aspect, it would help to know which operation(s) generate such air emissions. It might also help to know whether these air emissions are monitored or otherwise measured in some manner.
Collecting this information at an early stage will help you implement subsequent EMS elements. You can use a form to capture this information (such as Figure 15 found on page 81 in Environmental Management Systems: An Implementation Guide for Small and Medium Sized Organizations). One caveat: simply because you identify an existing control and/or monitoring activity related to a particular operation or activity, do not assume that these controls are adequate for EMS purposes. The adequacy of these controls will depend on several factors, including the EMS goals and objectives.
Gather information on the views of your "stakeholders" or interested parties. Stakeholders might include your neighbors, interest groups, customers and others. Their views might address how your organization affects the environment, how well you are meeting environmental obligations, and whether your organization is a "good neighbor," among other topics. Gathering this information allows you to consider stakeholder input in the development of your environmental policy. Since you have already assessed your legal and environmental aspects, you should be in a good position to have meaningful dialogues with these stakeholders.
At this point, you should have a sound basis for developing (or amending) an environmental policy. Using the information developed in the previous three steps allows your organization to prepare a policy that is relevant to the organization and the key issues that it faces. You should understand how well you are currently managing key issues. For example, information on the views of your stakeholders might be valuable in developing an environmental policy.
Once the environmental policy has been written, you can begin to define key roles and responsibilities within the EMS. At this stage of implementation, focus on "higher-level" responsibilities, such as the roles and responsibilities of senior management, key functional leaders and environmental staff (if one exists). Once the key roles and responsibilities have been defined, obtain the input of these individuals in the next step of the process - establishing objectives and targets. EMS responsibilities for other specific jobs or functions will be identified in a later step.
These objectives should be consistent with your environmental policy and the analyses you carried out on legal requirements, environmental aspects and impacts, and the views of interested parties, etc.
You have identified the operations and activities related to environmental aspects and impacts, and key roles and responsibilities. This information will help you to determine the relevant functions within the organization for achieving objectives and targets. For example, if you set an objective to reduce hazardous waste generation by 10 percent this year, you also should know which parts of the organization must be involved in order to meet this objective.
Step 7: Develop Environmental Management Programs, Identify Operational Controls, and Identify Monitoring and Measurement Needs
This brings us to one of the most challenging (and potentially most valuable) steps in developing an EMS. You are ready to tackle several EMS elements simultaneously. These elements include the design of environmental management programs (EMPs), the initial identification of necessary operational controls, and the initial identification of monitoring and measurement needs. You should already have a head start on this step, since you identified operations and activities related to your significant environmental aspects (as well as existing control and monitoring processes) several steps ago.
One reason for combining these steps is that they can often overlap significantly. For example, your EMPs for achieving a certain objective (such as maintaining compliance with regulations) might consist of a number of existing operational controls (procedures) and monitoring activities. Achieving an objective might require a feasibility study or the implementation of certain "new" operational controls. Determining progress on achieving objectives often requires some form of monitoring or measurement.
Compile a list of your operational control and monitoring needs. As you develop your EMPs, ask yourself the following questions:
- How do we control this operation or activity now?
- Are these controls adequate to meet our objectives and to ensure compliance?
- If additional controls are needed, what types of controls make sense?
- What type of monitoring / measurement is needed to track our progress in achieving objectives and to ensure that operational controls are implemented as designed?
This process is usually repetitive. You might need to revisit your management programs, operational controls, and monitoring processes over time to ensure they are consistent and up-to-date.
At this stage of implementation, your EMS will begin to generate some documents (such as procedures and forms) and records that demonstrate that various processes are being carried out. You need an effective way to manage the records that your EMS generates. Establish procedures for corrective/preventive action, document control, and records management. These three processes are essentially "system maintenance" functions. As you develop and implement procedures, work instructions, and other EMS documents, you will need a process for controlling the generation and modification of these documents to ensure that you can correct problems when they occur, as well as manage records properly (e.g., monitoring activities).
Refer to the list of operational control and monitoring needs from Step 7. Use a template for the development of work instructions or standard operating procedures. Employees that work in relevant operations or activities can provide support here.
Roles and responsibilities should address the specific operational controls and monitoring processes discussed above. You might want to document these responsibilities in a responsibility matrix or in some other form that is easily communicated to employees.
Initial employee awareness training should be conducted to promote understanding of the organization's EMS efforts and the progress made to date. As a first step, train employees on the environmental policy and other elements of the EMS. Discuss the environmental impacts of their activities, any new or modified procedures, the organization's objectives and targets, as well as their EMS responsibilities. If you have contractors or others at your site who are not employees of your organization, consider whether these other individuals should be included in these EMS awareness training sessions.
Some system-level procedures (such as the procedures for identification of environmental aspects) were developed at earlier stages of the process. At this point, you can establish any other procedures required for the EMS. These other system-level procedures might include, for example:
- employee training and awareness,
- internal and external communication,
- emergency preparedness and response,
- EMS auditing, and
- management review.
Once you have established roles and responsibilities and defined all of your system-level procedures, preparing the EMS manual should be a relatively simple matter. The manual should summarize the results of your efforts. It should describe the processes developed, define the roles and responsibilities, as well as other EMS elements. It is important to describe the links among system elements and provide direction to other system documents. Keep the manual simple - there is no need to provide great detail on any particular system process.
Once the procedures and other system documentation have been prepared, you are ready to conduct specific employee EMS training. As a first step, identify specific training needs. Employee training should be designed to ensure understanding of (1) key system processes, (2) operational controls related to their specific jobs, and (3) any monitoring or measurement for which they are responsible. At this point, you should have sufficient EMS processes in place to begin to "Check" your EMS.