ENVIRONMENTAL POLICY AND MANAGEMENT SYSTEM

ENVIRONMENTAL MANAGEMENT SYSTEM

• ENVIRONMENTAL MANAGEMENT SYSTEM
• Introduction
• Section 1: Why Your Organization Should Have an EMS
• Section 2: Key EMS Concepts
• Section 3: Step-by-Step Action Plan
• Section 4: Key Elements of an EMS
• Section 5: The Registration Process
• Section 6: Sources of Assistance
• Background on EMS Standards
• Case Studies
 Introduction

• The Guide explains how you can develop and implement an effective EMS
and how it can support your organization’s mission and goals.
• Development of an EMS is a voluntary approach to improving your
organization’s environmental performance.
• The heart of the Guide is found in Section 4, “Key Elements of an EMS.”
• For each of the recommended EMS elements, this section discusses the
importance of the element, how you can get started, and some key
suggestions for implementation.
• In addition, examples of how other organizations have addressed various
EMS elements are provided in Section 4.
• The Guide uses the ISO 14001 Standard as a model for an EMS.
• The ISO 14001 Standard is the widely accepted official international
standard for environmental management systems.
 Section 1: Why Your Organization Should Have an EMS

• This section explains why an EMS can help your organization to compete and
prosper in today’s global market.
• A systematic approach to meeting your environmental and business goals.
• Key EMS Benefits:
• improved environmental performance
• reduced liability
• competitive advantage
• improved compliance
• reduced costs
• fewer accidents
• employee involvement
• improved public image
• enhanced customer trust
• better access to capital
•“We view the establishment of an EMS as a process that forces us to better
organize our priorities and projects and to identify problems and exposures
before they occur.” K.J. Quinn & Co. (A small specialty chemical company)
• Is your organization required to comply with environmental laws and
regulations?
•Are you looking at ways to improve your overall environmental performance?
•Is the state of your organization’s environmental affairs a significant liability?
•Does a lack of time or resources prevent your organization from taking charge of
its environmental obligations?
•Does your organization know how its environmental objectives relate to its
business objectives?
•If you answered YES to one or more of the above questions, an environnemental
management system (EMS) can help your organization!
•As one of your organization’s leaders, you know that interest in environmental
protection and sustainable development is growing.
•Like many others, your organization may be increasingly challenged to
demonstrate its commitment to the environment.
•Implementing an EMS can help in a number of important ways.
•First, an effective EMS makes good business sense.
•By helping you identify the causes of environmental problems (and then
eliminate them), an EMS can help you save money. Think of it this way:
• Is it better to make a product right the first time or to perform a lot of re-work
later?
• Is it cheaper to prevent a spill in the first place or clean it up afterwards?
• Is it more cost-effective to prevent pollution or to manage it after it has been
generated?
•Second, an EMS can be an investment in long term viability of your organization.
•An EMS will help you to be more effective in achieving environmental goals.
•And, by helping businesses to keep existing customers and attract new ones, an
EMS adds value.
•Much of what you need for an EMS may already be in place!
•The management system framework contains many elements that are common
to managing other business processes, such as quality, health & safety, finance,
or human resources.
•As you review this, you may find that you already have many EMS processes in
place, but for other purposes (such as quality).
•Integrating environmental management with other key business processes can
improve the organization’s financial and environmental performance.
•The key to effective environmental management is the use of a systematic
approach to planning, controlling, measuring and improving an organization’s
environmental efforts.
•Potentially significant environmental improvements (and cost savings) can be
achieved by reviewing and improving your organization’s management processes.
•Not all environmental problems need to be solved by installing expensive
pollution control equipment.
•Of course, there is some work involved in planning and implementing an EMS.
•But many organizations have found that the development of an EMS can be a
vehicle for positive change.
•EMS far outweigh the potential costs.
•As they say in the Total Quality Management (TQM) world, “quality is free” — as
long as you are willing to make the investments that will let you reap the rewards.
•The same holds true for environmental management.
•“We found that an EMS could improve employee retention, new hire selection,
working conditions, and the perceptions of our customers, suppliers, lenders,
neighbors, and regulators.” Milan Screw Products (A 32-person manufacturer of
precision fittings)
•If your organization already has or is considering a quality management system
(such as ISO 9000), you will find some significant synergy between what you need
for quality management and for environmental management.
•One final note: Small and medium-sized organizations often have some
advantages over larger organizations in ensuring effective environmental
management.
•In smaller organizations, lines of communication are generally shorter,
organizational structures are less complex, people often perform multiple
functions, and access to management is simpler.
•All of these can be real advantages for effective environmental management.
•Are you interested in learning more about how an EMS can help your
organization?
•If so, let’s look at some key management systems concepts and how they are
applied in the environmental area.
 Section 2: Key EMS Concepts

• This section explains what a management system is — and how it can help your
company.
• The focus on quality principles
• Definition of an EMS: A continual cycle of planning, implementing, reviewing and
improving the actions that an organization takes to meet its environmental
obligations.
• Continual Improvement: Enhancing your EMS to better your overall environmental
performance.
• An effective EMS doesn’t just happen. An effective EMS needs ongoing management
support.
• You have probably heard of Total Quality Management (TQM).
• Your organization may apply TQM principles to some or all of its operations and
activities.
• An effective EMS is built on TQM concepts.
• To improve environmental management, your organization needs to focus not only
on what things happen but also on why they happen.
• Over time, this systematic
identification and correction of
system deficiencies leads to
bettermenvironmental (and
overall business) performance.
• Most EMS models (including the
recently issued ISO 14001
Standard, which will be
described later) are built on the
“Plan, Do, Check, Act” model
introduced by Shewart and
Deming.
• This model endorses the concept
of continual improvement.
•In the ISO 14001 EMS Standard, these “plan, do, check, act” steps have been
expanded into seventeen EMS elements.
•Each element is discussed in Section 4.
•Putting TQM principles into practice in the environmental area is the job of top
management.
•To build and sustain an effective EMS, management must communicate to all
employees the importance of :
• making the environment an organizational priority (thinking of effective
environmental management as fundamental to the organization’s survival)
• building environmental management in everywhere (thinking about the
environment as part of product and process development, among other activities)
• looking at problems as opportunities (identifying problems, determining root
causes and preventing their recurrence)

•Flexible + simple = adaptable +understandable

•Employee involvement is crucial
•The concept of continual improvement recognizes that problems will occur.
•But a committed organization learns from its mistakes and prevents similar
problems from occurring in the future.
•An effective EMS must be dynamic to allow your organization to adapt to a quickly
changing business environment.
•For this reason, you should keep your EMS flexible and simple.
•This also helps make your EMS understandable for the people who must implement it —
you and your organization’s employees.
•As you build and implement an EMS, some roadblocks may be encountered.
•Some people in the organization may view an EMS as bureaucracy or extra expense — an
“add-on” to what you do now.
•There may be resistance to change or fear of new responsibilities.
•To overcome these potential roadblocks, make sure that everyone understands why the
organization needs an effective EMS and how an EMS will help you control environmental
impacts in a cost-effective manner.
•Getting people involved in designing and implementing the EMS will demonstrate the
organization’s commitment to the environment and help to ensure that the EMS is realistic,
practical and adds value.
•Building or improving your EMS is a great opportunity to assess how your organization
manages environmental obligations and to find better (and more cost-effective) solutions.
•While you will probably identify some areas where your current EMS can be improved, this
does not mean that you should change things that are working well!
•By reviewing what your organization does and how well it works, you can ensure that your
EMS will be viable and effective, both now and in the future .
•Don’t get discouraged if your system has some bugs at first — this is to be
expected.
•Remember, the focus is on continual improvement !
 Section 3: Step-by-Step Action Plan

• This section explains the process of building an EMS.

• Putting the theory of EMS into practice
• Steps to Consider:
• Gain management commitment
• Choose a champion
• Prepare budget and schedule
• Build cross-functional team
• Involve employees
• Conduct preliminary review
• Modify plan
• Prepare procedures / other documents
• Plan for change
• Train employees
• Assess performance
•Milan Screw Products found that the use of across-functional group (the
environmental task group) was the key to progress in evaluating and
implementing their EMS. Participation of shop floor employees is essential in
successfully implementing an EMS.
•K.J. Quinn & Company found that it could perform an initial self-assessment of its
environmental programs in 20-25 hours.
•Building an EMS might sound like an overwhelming task for a small organization,
but it need not be.
•Time and other resources are limited in any small organization, so it is important
that your resources are used wisely.
•One way to do this is by following a simple, effective plan.
•Fortunately, you can build on the experiences of other organizations who have
already implemented an EMS.
•Examples are provided throughout this Guide.
•The importance of careful planning cannot be overemphasized.
•Taking the time to figure out what you need to do, how you will do it, and which
people must be involved will pay big dividends down the road.
•Using a team approach for building your EMS is a good way to improve
commitment and ensure that the objectives, procedures and other system
elements are realistic, achievable, and cost-effective.
•A few hints to keep in mind as you build your EMS:
• Help is available — don’t hesitate to use it. (See Section 6 for more on
resources.)
• Consultants can provide help in evaluating your EMS and suggesting approaches
used successfully elsewhere. Look for ways to hold consulting costs down. For
example, you may be able to join forces with other small businesses in your area
to hire a consultant.

Some Thoughts on the Use of Consultants:

• Assess your own in-house resources first.
• Make sure both parties understand the scope of work.
• Get references and check them. Look for consultants with experience in small
business and your specific industry.
• Use consultants to gain insights on approaches used by other companies.
• An EMS developed by consultants “in isolation” will not work. Your own people
need to be involved in the process.

•Look at your existing environmental compliance plans and programs to assess

how effective they have been and how they might be improved.
 Creating Your Own EMS: Key Steps

1. Obtain Management Commitment

• The first step in the EMS-building process is gaining top management’s
commitment to supporting the EMS.
• Management must understand the benefits of an EMS and what it will take to
put an EMS in place.
• Management commitment and vision should be clear and communicated across
the organization.
2. Choose a Champion
• Not all small or medium-size organizations have the luxury of choosing among
multiple candidates, but your choice of project champion is critical.
• The champion should have the necessary authority, an understanding of the
organization, and project management skills.
• The champion should be a “systems thinker” (some ISO 9000 experience would
be a plus, but is not necessary) and must have the time to commit to the EMS-
building process.
3. Prepare Budget and Schedule
•The project champion should prepare a preliminary budget and schedule for
developing the EMS.
•Costs will likely include staff and employee time, training, some consulting
assistance, materials, and possibly some equipment (such as a computer or word
processor).
•The schedule should consider the various tasks described below, among others.
4. Build Project Team
•A team with representation from key management functions and production or
service areas can identify and assess issues, opportunities, and existing processes.
•You may want to consider including contractors, suppliers, and other external
parties to be part of the project team where appropriate.
•This team will need to meet frequently, especially in the early stages of the
project.
•The cross-functional team can help to ensure that procedures are reasonable and
will build commitment to the EMS.
5. Involve Employees
•Employees are a great source of knowledge on environmental and health & safety
issues related to their areas as well as on the effectiveness of current processes
and procedures.
•They can help the project team in drafting procedures.
•Employee ownership of the EMS will be greatly enhanced by meaningful
employee involvement in the EMS development process.
6. Conduct Preliminary Review
•The next step is to conduct a preliminary review of your current environmental
programs and system and compare these against the criteria for your EMS (such as
ISO 14001).
•Evaluate your organization’s structure and its procedures, policies, environmental
impacts, training programs, and other factors.
•Determine which elements of your current system are in good shape and which
need additional work.
7. Modify Plan
•The project plan might need to be modified based on the results of the
preliminary review.
The modified plan should describe in detail the key actions needed, who will be
responsible, what resources are needed, and when the work will be completed.
8. Prepare Procedure & Documents
•At this point, you are ready to develop procedures and other system documents.
•In some cases, this might involve modifying existing environmental procedures or
adapting other business procedures (such as quality or health & safety
management procedures) for EMS purposes.
•In some cases, you might need to develop new procedures.
•Get help from employees and the cross-functional team, as discussed above.
9. Plan for Change
•In building your EMS, make sure that the system is sufficiently flexible.
•While you will likely need to modify your EMS over time, try to avoid making your
EMS so rigid that you must change it frequently to reflect the realities of your
operation.
10. Train Employees
•Once the procedures and other documents have been prepared, you are ready to
implement the EMS.
•As a first step, train your employees on the EMS, especially with regard to the
environmental impacts of their activities, any new / modified procedures, and any
new responsibilities.
11. Assess EMS Performance
•After the EMS is up and running, be sure to assess system performance.
•This will be accomplished through periodic EMS audits and ongoing monitoring
and measurement.
•Assessment of EMS performance provides the opportunity to improve the system
and your environmental performance over time.
 Section 4: Key Elements of an EMS

• This section provides guidance on how to build and implement an EMS.

• As mentioned earlier, your EMS should be built on the “Plan, Do, Check, Act”
model to ensure that environmental issues are systematically identified,
controlled, and monitored. Using this approach will help to ensure that
performance of your EMS improves over time.
• This section describes seventeen EMS elements included in the ISO 14001
Standard.
• While there are several good EMS models available, this Guide uses the ISO
14001 Standard as a starting point for describing EMS elements for several
reasons:
• ISO 14001 is a widely accepted international Standard for EMS;
• Companies may be asked to demonstrate conformance with ISO 14001 as a
condition of doing business in some markets; and
• The Standard is consistent with the key elements found in most EMS models.
Elements of an ISO 14001 EMS:
1. Environmental policy — Develop a statement of your organization’s
commitment to the environment. Use this policy as a framework for planning
and action.
2. Environmental aspects — Identify environmental attributes of your products,
activities and services. Determine those that could have significant impacts on
the environment.
3. Legal and other requirements — Identify and ensure access to relevant laws
and regulations (and other requirements to which your organization adheres).
4. Objectives and targets — Establish environmental goals for your organization,
in line with
5. Environmental management program — Plan actions to achieve objectives
and targets.
6. Structure and responsibility — Establish roles and responsibilities and
provide resources.
7. Training, awareness and competence — Ensure that your employees are
trained and capable of carrying out their environmental responsibilities.
8. Communication — Establish processes for internal and external
communications on environmental management issues.
9. EMS documentation — Maintain information on your EMS and related
documents.
10. Document control — Ensure effective management of procedures and other
system documents.
11. Operational control — Identify, plan and manage your operations and
activities in line with your policy, objectives and targets.
12. Emergency preparedness and response — Identify potential emergencies
and develop procedures for preventing and responding to them.
13. Monitoring and measurement — Monitor key activities and track
performance.
14. Nonconformance and corrective and preventive action — Identify and
correct problems and prevent recurrences.
15. Records — Keep adequate records of EMS performance.
16. EMS audit — Periodically verify that your EMS is operating as intended.
17. Management review — Periodically review your EMS with an eye to continual
improvement
How Does the ISO 14001 Standard Support Environmental Compliance?
•ISO 14001 requires an organization to:
•develop an environmental policy with a commitment to compliance;
•have a procedure for identifying and having access to environmental laws and
regulations;
•set objectives and targets that are in line with its environmental policy (which
includes a commitment to compliance);
•establish operational control procedures;
•establish procedures for emergency preparedness and response;
•establish a procedure for periodically evaluating compliance …

•While these requirements relate directly to an organization’s compliance

management, each of the seventeen elements of the ISO 14001 Standard can
contribute to enhanced compliance (e.g., communication, training, documentation,
records, nonconformance and corrective / preventive action, EMS audits,
management review, etc.).
•An EMS based on the ISO 14001 Standard can complement and improve your
organization’s compliance management and help your organization to meet
objectives and targets that go “beyond compliance.”
•An EMS based on the ISO 14001 Standard can also help your organization to meet
objectives and targets that address issues that are not subject to regulation.
1. Environmental Policy
•Why do we need an environmental policy?
•What is my organization’s commitment to the environment?
•Continual Improvement:“Process of enhancing the environmental management
system to achieve improvements in overall environmental performance in line with
the organization’s environmental policy” - ISO 14001
•Key Policy Commitments
- Continual improvement
- Pollution prevention
-Compliance with relevant laws and regulations

•An environmental policy is your management’s declaration of commitment to the

environment.
•The policy should serve as the foundation for your EMS and provide a unifying
vision of environmental concern by the entire organization.
•Your policy should be more than just flowery prose.
•Since it serves as the framework for setting environmental objectives and targets,
the policy should be brought to life in your plans and deeds.
•Everyone in the organization should understand the environmental policy and
what is expected of them in order to achieve the organization’s objectives and
targets.
•Your policy should contain three key commitments, including a commitment to
continual improvement.
•This doesn’t mean that you must improve in all areas at once, but that the policy
should drive your overall efforts to continually improve your organization’s
environmental management.
•Hints:
• Your organization probably has an environmental policy now, even if it’s not
written. For example, your organization is probably committed to complying with
the law and avoiding major environmental problems, at a minimum. Document
your existing commitments as a starting point.
• Your policy should be related to your products and services, as well as supporting
activities. Consider the results of your preliminary review before finalizing the
policy. Also, make sure the policy reflects the environmental aspects of your
products, services and activities.
• Keep your policy simple and understandable. Ask yourself: What are we trying to
achieve? How can I best communicate this to the rest of the organization? Will we
do what we said we would? Keep in mind that your policy should be explicit
enough to be auditable.
• The policy can be a stand-alone
document or it can be integrated
with your health & safety, quality,
or other organizational policies.
· Consider who should be involved in
developing the policy and the
best process for writing it. Input
from a range of people in your
organization should increase
commitment and ownership.
• Make sure that your employees understand the policy. Options for
communicating your policy internally include posting it around the site (e.g., in the
lunch room), paycheck stuffers, incorporating the policy into training classes and
materials, and references to the policy at staff or all-hands meetings. Test
awareness from time to time by asking employees what the policy means to them
• The policy should also be communicated externally. Options for external
communication include business cards, newspaper advertisements and annual
reports, among other options. You can choose to communicate the policy
proactively or in response to external requests.
Review: Have we ...
•developed a written policy?
•considered our key products, activities, and services?
•addressed the three key commitments?
•effectively communicated the policy?
• 2. Identifying Environmental
Aspects
• How does my organization
interface with the environment?
• Environmental Aspect: “Element of
an organization’s activities,
products, or services that can
interact with the environment.” ISO
14001
• Environmental Impact : “Any
change to the environment,
whether adverse or beneficial,
wholly or partially resulting from
an organization’s activities,
products, or services.” ISO 14001
•To plan for and control its significant environmental impacts, an organization must
first know what these impacts are.
•But knowing what the impacts are is only part of the challenge — you also should
know where these impacts come from.
•If your organization has undertaken pollution prevention projects, you are
probably familiar with this concept — you must know how a waste is generated in
order to minimize or eliminate it.
•As with pollution prevention, the identification and management of
environmental aspects can (1) have positive impacts on the bottom line and (2)
provide significant environmental improvements.
•Your EMS should include a procedure to identify the environmental aspects that
your organization:
• can control, and
• over which it can have an influence.

•The relationship between aspects and impacts is one of cause and effect.
•The term “aspects” is neutral, so keep in mind that your environmental aspects
could be either positive (such as making a product out of recycled materials) or
negative (such as discharge of toxic materials to a stream).
•Your organization is not expected to manage issues outside its sphere of influence.
•For example, while your organization probably has control over how much
electricity it uses, it likely does not control the way in which the electricity is
generated.
•Once you have identified the environmental aspects of your products, activities,
and services, you should determine which aspects could have significant impacts on
the environment.
•These environmental aspects should be considered when you set your
environmental objectives and define your operational controls.
•A multi-step process can be used to make this evaluation.
•Keep the resulting information up to-date, so that potential aspects of new
products, services, and activities are factored into your objectives and controls.
•Service Organizations Can Benefit from an EMS.
•Example: The US Postal Service examined environmental aspects related to the
vehicles it operates, the chemicals it uses to maintain equipment, the solid wastes it
generates, and the products (stamps) that it sells.

•K e y H i n t s :
• L o o k b e y o n d r e g u la tio n s a n d a t n o n - r e g u l a t e d a c t i v i t i e s
• P r io r i t i z e i n s e ttin g o b je c t i v e s
• C o n s id e r s e r v i c e s & c o n t r a c t o r s
•Example: Warner-Lambert Company developed process flow sheets to identify &
“visualize” all waste streams from operations, and to determine how much they
were costing the company.

•Factors to Consider:
• ecological effects
• human health impacts
• catastrophic effects
• resource depletion
• scale, severity & duration of impacts
• probability of occurrence
• cost of changing
• other business effects

•Hints:
• In identifying aspects and impacts, you should also look at activities not
controlled by applicable laws and regulations. But because many of your
aspects/impacts may be addressed by legal requirements, your compliance
program might yield some valuable information. Permits, audit reports, and other
such documents can serve as useful inputs. Beyond regulations, look at issues such
as land, energy, and other natural resource use.
• Once you have identified environmental aspects and related significant impacts,
use this information in setting your objectives and targets. This does not mean
that you need to address all of your impacts at once. There may be good reasons
(such as cost, availability of technology, and scientific uncertainty) for addressing
some impacts now and deferring action on others. Keep in mind that managing
environmental aspects could have positive business impacts.
• Remember to look at services as well as products. While the need to examine
your on-site operations might be obvious, you should also consider the potential
impacts of what you do off-site (such as servicing equipment at customer sites).
Similarly, the environmental aspects of the products, vendors, and contractors you
use may be less obvious, but should still be considered.
• Identifying significant environmental aspects is one of the most critical elements
of the EMS — and can be one of the most challenging. Decisions you make in this
task can affect many other system elements (such as, setting objectives and
targets, establishing operational controls, and defining monitoring needs). Careful
planning and conduct of this activity will pay dividends in later steps.
Getting Started
• To understand your environmental aspects, it helps to understand the processes
by which you generate products and services. A flow chart of your major
processes might help you understand the inputs and outputs of your processes
and how materials are used.
You may also want to consider the views of interested parties — some organizations
have found external parties to be a good resource to help you identify your
organization’s environmental aspects.
• There are many readily-available sources of information to help you perform your
assessment. For starters, look at your permits, various regulations that apply to
your operations, audit reports, EPCRA (Emergency Planning and Community Right-
to-Know Act) reports, and monitoring records. Trade associations, regulatory
agencies, your customers and suppliers also might provide useful information to
support your assessment.
• Various techniques exist for evaluating environmental impacts. Find one that can
be readily adapted for your use in identifying environmental aspects and significant
impacts. Consider techniques used for compliance with the OSHA (Occupational
Safety and Health Administration) Process Safety Management Standard,
environmental impact assessments, and life cycle analysis.
• Once you’ve found a process that works for your organization, describe the
process in a written procedure.
• You can start out with a simple process for identifying aspects and then refine the
process over time as needed. You also can address the more obvious impacts or
“low hanging fruit” first, then tackle the more complex issues later.
Review: Have we ...
•evaluated our products, activities, and services?
•determined which aspects have significant impacts?
•documented a procedure?
3. Legal and Other Requirements
•What standards affect the organization?
•Setting the legal framework for your EMS
•Legal requirements include:
• Federal requirements
• State or local requirements
• Permit conditions
•Other requirements might include ( for example):
• Company-specific codes
• Standards in locations where you sell products
• International Chamber of Commerce (ICC) Charter for Sustainable Development
• Chemical Manufacturers Association’s (CMA) Responsible Care
• American Petroleum Institute’s Strategies for Today’s Environmental Partnership
(API STEP)
• Other industry codes or programs to which your organization voluntarily
subscribes.
•Key Steps:
- Identify Requirements
- Analyze Impacts
- Communicate
-Act
•To be in compliance with the laws and regulations that apply to your organization,
you must first know what the rules are and how they affect what you do.
•As discussed earlier, compliance with legal requirements is one of the “three
pillars” upon which your environmental policy should be based.
•Costs of non-compliance (in terms of dollars, public image and possible damage to
the environment) can be very high.
•An effective EMS will include a process for:
• identifying applicable legal and other requirements, and;
• ensuring that these requirements are factored into the organization’s efforts.

•Changing legal requirements might require that you modify your environmental
objectives or other elements of your EMS.
•By anticipating new requirements and making changes to your operations, you
can avoid some future compliance obligations and their associated costs.
Getting Started
•Your EMS should include a procedure for identifying and having access to the
legal and other requirements that apply to your organization.
•These “other requirements” might include industry codes, the CERES (coalition
for environmentally responsible economies) Principles, or similar requirements to
which your organization may subscribe.
•The process of identifying applicable regulations, interpreting them, and
determining their impacts on your operations can be a time-consuming task.
•Fortunately, there are many ways in which your organization can obtain
information about applicable laws or regulations. These include:
• commercial services (offered on-line, on computer disk, and on paper);
• regulatory agencies (federal, state and local);
• trade groups / associations;
• public libraries;
• seminars and courses;
• newsletters / magazines;
• consultants and lawyers;
• the Internet; and
• customers, vendors and other companies.
Example: Commonly Applicable Federal Environmental Laws in the US
•Once the applicable legal and other requirements have been identified and
analyzed for their impacts, you should communicate these requirements (and
plans for complying with them) to the appropriate people within the organization.
Communicating the “other requirements” that apply to your organization (as well
as their impacts) is an important and often overlooked —step.
•Review: Have we ...
•identified applicable rules and other requirements and determined their
impacts?
•established and documented a process for keeping up-to-date?
•communicated to the right people?
4. Objectives and Targets
•How will objectives and targets help my organization?
•What does my organization do to achieve its policy?
•Environmental Objective: “Overall environmental goal, arising from the
environmental policy, that an organization sets itself to achieve, and which is
quantified where practicable.” - ISO 14001
•Environmental Target: “Detailed performance requirement, quantified where
practicable, applicable to the organization or parts thereof, that arises from the
environmental objectives and that needs to be set and met in order to achieve
those objectives.” - ISO 14001
•Objectives and targets help you translate purpose into action — they should be
factored into your strategic plan and can facilitate the integration of environmental
management with other business management processes.
•You determine what objectives and targets are appropriate for your organization.
•These goals can be organization-wide or applied to individual units or activities.
•In setting objectives, keep in mind your environmental policy, including its three
“pillars.”
•You should also consider your significant environmental aspects, applicable legal
and other requirements, the views of interested parties, your technological
options, and financial, operational, and other business requirements.
•There are no “standard” environmental objectives that fit all organizations.
•Your objectives and targets should reflect what your organization does and what it
wants to achieve.
•Hints:
• Objectives and targets should be set by the people in the functional area
involved — they will be best positioned to establish, plan for, and achieve these
goals.
• Involving people in the area will help to build commitment.
• Objectives should be consistent with your overall business mission and plan and
the key commitments established in your policy (pollution prevention, continual
improvement, and compliance).
• Be flexible in your objectives.
Define a desired result and let the
people responsible determine
how to achieve the result.
• Keep your objectives simple
initially, gain some early
successes, and then build on
them.
• Communicate objectives and
targets (as well as your progress
in achieving them) across the
organization. Consider a regular
report on progress at staff
meetings.
• To obtain the views of interested parties, consider holding an open house or
establishing a focus group with people in the community. These activities can have
other payoffs as well.
• Make sure your objectives and targets are realistic. Determine how you will
measure progress towards achieving them.
• Keep in mind that your suppliers (service or materials) can help you in meeting
your objectives and targets (e.g., by providing more environmentally friendly
products).
Example: POLLUTION PREVENTION
•The most significant savings from Pacific Gas & Electric’s EMS have come from
reductions in hazardous waste generation and disposal. Ten years ago the
hazardous waste generated by operations exceeded 90,000 tons per year — now
that number is below 10,000 tons per year and is still falling.
Example: POLLUTION PREVENTION
•Warner-Lambert Company used a “holistic” approach to identify its waste
streams.
•The company looked beyond emissions from its property and considered all of the
ramifications of its activities …
•By replacing chillers and redesigning the chilling system to be more efficient, the
company has realized $250,000 in energy savings. Because the company is more
energy efficient, it has reduced emissions at the local power plant!
•By redesigning and revising dust collection, the company now uses 40 hp instead
of 100 hp (without compromising the effectiveness of the dust collection system),
has lowered its operating costs (and, reduced emissions at the local power plant).
•Review: Have we …
•documented objectives and targets at relevant functions and levels within the
organization?
•ensured that our objectives and targets are consistent with the environmental
policy (including commitments to pollution prevention, continual improvement,
and compliance)?
•ensured consistency with our business plan / mission?
•established a process for tracking and reporting progress?
5. Environmental Management
Program(s)
• Why do we need an environmental
management program?
• A road map for achieving your
environmental goals
• So far, this Guide has focused on
the foundations of your EMS (the
planning elements) and on
defining what your organization
intends to achieve in the
environmental area.
• To ensure that objectives and
targets are achieved, you need an
action plan.
•The environmental management program should be linked directly to your
objectives and targets — that is, the program should describe how the organization
will translate its goals into concrete actions so that environmental objectives and
targets will be achieved.
•To ensure its effectiveness, your environmental management program should:
• designate responsibilities for achieving goals, and
• define the means and time frame for achieving those goals.

•Keep in mind that your program should be a dynamic one.

•Consider modifying the program when:
• objectives and targets are revised or added;
• progress in achieving your objectives and targets is made — or not made; or
• products, processes, or facilities change or other factors arise.

•Your action plan need not be compiled into a single document.

•A “road map” to several plans is an acceptable alternative, as long as the key
responsibilities, tactical steps and schedules are adequately defined in these other
documents.
•Keep in mind that this program should not be developed in a vacuum — it should
be coordinated or integrated with other business plans, strategies, and budgets.
•For example, if you are planning changes to a manufacturing process (say, for
quality or production purposes), then it makes sense to look at the possible
environmental issues associated with this process change at the same time.
Hints:
• Involve your employees early in establishing and carrying out the program.
• Clearly communicate the expectations and responsibilities laid out in the
program to those who need to know.
• Build on the plans and programs you have now for environmental compliance,
health & safety, and/or quality management purposes.
• Re-evaluate your action plan when you are considering significant changes to
your products, processes, facilities or materials. Make this re-evaluation part of
your change management process.
• Keep it simple (see sample tool, next page) and focus on continual improvement
of the program over time.

•Thought to Keep in Mind: There may be real opportunities here!!

•Coordinating your environmental program with your overall business plans and
strategies may position your organization to exploit some significant cost-saving
opportunities.
Environmental Management Program
-- Sample Tool
Key Hints
• Involve employees
• Communicate expectations
• Build on existing programs
• Keep program simple
• Look for opportunities
• Example: POLLUTION PREVENTION
• In an effort to reduce VOC emissions,
Aeroquip Corporation has successfully
replaced a high-solids paint with a water-
based paint.
• Solvent use has decreased significantly
because the dilution solvent for the paint
is now de-ionized water.
•Review: Have we ...
•prepared an action plan on how the organization will meet its objectives and
targets?
•included responsibilities, means and time frames?
•incorporated environmental concerns in our change management process?
communicated the plan and tracked progress internally?
6. Structure and Responsibility
•How does our organizational structure affect environmental management?
•Aligning your resources to succeed
•“Resources include human resources and specialized skills, technology, and
financial resources.” - ISO 14001
•Characteristics of a good management representative:
• Knowledgeable
• Assertive
• Independent

•More organizational advantages of small business:

• shorter lines of communication
• less complex organization
• limited delegation
• simpler access to management
•For your EMS to be effective, roles and responsibilities must be clearly defined
and communicated.
•In a small organization, the commitment of all employees is needed.
•Top management plays a key role by providing the resources needed to ensure
that the EMS is implemented effectively.
•Ensuring this capability is one of the most important jobs of top management.
•Any effective management system needs an advocate.
•Top management should appoint a management representative.
•This representative (1) ensures that the EMS is established and implemented; (2)
reports on its performance over time; and (3) works with others to modify the
EMS when necessary.
•The management representative could be the same person who serves as the
project champion (as discussed in Section 3), but this is not mandatory.
•Management can use information on EMS performance to improve the system
over time.
•(A business owner, plant or shop manager, or any number of other people might
serve as an effective management representative.)

•Small and medium-sized businesses may have an advantage over larger

businesses in structuring their organizations for environmental management.
•Because personnel and other resources are generally more limited in small
businesses, people often “wear more than one hat” and are experienced in
performing multiple functions.
•In some cases, the individual responsible for environmental management in a
small firm is also responsible for quality, health & safety, facilities, or other related
functions.
•For this reason, integrating environmental responsibilities with other functions
can be greatly simplified.
•Getting Started:
•The following questions can help you determine the right organizational structure
for environmental management:
• Look at the scope of your environmental management program: What
capabilities do we need? Who needs to be involved to make the system effective?
What training or other resources will they need?
• Look at your significant environmental impacts: What operations / activities need
to be controlled? Who needs to be involved to ensure that controls are
implemented?
• Look at the results of previous audits or other assessments: What does this
information tell us about the effectiveness of our organizational structure? How
could it be improved?
• Look at the current responsibilities for environmental management: How can we
enhance ownership of environmental management across the organization? How
can other business functions support the EMS?
• Look at your quality management and / or other existing management systems:
What roles and responsibilities exist in these management systems? Where are the
opportunities for integration?

•Consider flow charting your organization’s activities relating to environmental

management.
•This can help you understand how processes work and the final product can be a
great communication and training tool.
•Flow charts might be useful to look at processes such as chemical purchasing and
distribution, employee training, and preventive maintenance, among others.

•Getting Started
Look At:
• Program scope
• Environmental aspects
• Previous audits
• Other systems
•Consider integrating EMS with your existing:
• information systems
• purchasing controls
• quality procedures
• work instructions
• training programs
• communication efforts
• reporting systems
• recruitment, appraisal and disciplinary processes

•Hints:
• Build flexibility into your organization’s EMS. Recognize that environmental (and other)
management needs will change over time.
• Be sure to communicate to people what their roles are (as well as the roles of others). One
tool for communicating these responsibilities is a responsibility matrix.

Finding Resources
•In most cases, developing and maintaining an EMS will not require large capital outlays.
•What an EMS will require is time.
•Many small organizations have found that they can make effective use of interns or
temporary employees to perform potentially time-consuming EMS development tasks (such
as collecting data, drafting and typing procedures, etc.).
•This approach allows in-house personnel to focus on more complex EMS development tasks.
•Also, exploit the links between environmental management and other aspects of
your organization.
•Look for areas where environmental management can support other business
functions
(and vice-versa).

•Review: Have we ....

•defined roles for environmental management?
•communicated those roles internally?
•assessed resource needs?
•designated a management representative?
•integrated environmental management with other business functions wherever
possible and practical?
7. Training, Awareness and Competency
•Why is training important to the success of our EMS?
•Building internal capabilities
•Implementing an EMS involves everyone
•Reasons for Training:
• motivation
• awareness
• commitment
• skills/ capability
• compliance
• performance
•There are two excellent reasons for training employees about environmental
management and your EMS:
• Every employee can have an impact on the environment.
• Any employee can have good ideas about how to improve environmental
management efforts.

•Each person and function within your organization can play a role in
environmental management.
•For this reason, your training program should cast a wide net.
•Everyone in the organization should be trained on the environmental Policy,
signifiant environmental impacts of their work activities, key EMS roles and
responsibilities, procedures that apply to their activities, and the importance of
conformance with EMS requirements.
•All personnel should receive appropriate training.
•However, training is just one element of establishing competence, which is
typically based on a combination of education, training, and experience.
•For certain key roles (including tasks which can cause significant environmental
impacts), you should establish criteria for measuring the competence of
individuals performing those tasks.
•Getting Started:
• A critical first step in developing your training program is assessing your training
and skill needs. In assessing these needs, you should consider both general and
specific aspects (e.g., “What EMS procedures affect Joe’s daily work and what
happens if they aren’t followed?” “What environmental impacts might Joe’s work
cause?” “What broader understanding of environmental issues and our EMS does
Joe need?”)

• Look at the training you conduct already, for compliance with environmental
and health and safety regulations and other purposes. You may find that you
existing training efforts go a long way towards satisfying the requirements for the
EMS.
•Example: Milan Screw Products found that it could provide a great deal of its EMS
training during “brown bag” lunches, during which employees bring their lunches,
participate in a training session, and remain “on the clock” for the lunch period.
Training Resources:
• internal trainers / experts
• consultants
• community colleges
• vendors / suppliers
• customers
• technical / trade / business associations
• self-study or study groups
• training consortia (teaming with other local companies)
• computer-based training
Key Steps in Developing a Training Program:
Step 1: Assess training needs & requirements
Step 2: Define training objectives
Step 3: Select suitable programs and methods
Step 4: Prepare training plan (who, what, when, where, how)
Step 5: Implement training program
Step 6: Track training (and maintain records)
Step 7: Evaluate training effectiveness
Step 8: Improve training program (as needed)
Hints:
• Because of the level of effort involved in a training program, this is one EMS area
where you don’t want to start from scratch. Many employees may already be
qualified on the basis of their experience and previous training. (Keep in mind that
all training should be documented.) Since some employees may require training on
how to run a process safely, on the- job training certainly plays a role.

• Plan and schedule training opportunities carefully. While finding enough time for
training can be a challenge, there may be creative ways to make “more time”. Use
venues like safety meetings, staff meetings, and tool box meetings to provide
“training” and reinforce key messages.

• New employees can pose a significant training challenge. Consider developing an

EMS training package for new employee orientation. Even better, videotape one of
your current EMS training courses to show new employees.

• In reviewing training needs, don’t forget to consider the qualifications and

training needs of your environmental manager and your trainers. Professional
certification programs may be appropriate for certain functions.
• Factor your EMS skills requirements into your recruiting, selection, and new
employee orientation efforts (as noted above).

• Establishing competency for various tasks can be a challenge. Competency

criteria for jobs that can cause significant environmental impacts should be as
objective as possible. One informal method for assessing competency is to
question employees in critical functions as to how they perform various aspects of
their jobs (e.g., “Show me how you.......”). Use responses to determine whether
they have the requisite skills and understanding to do the job safely. This will help
you gauge whether additional training may be needed.

• Consider “job aids” to supplement training or help establish competence.

Examples of job aids include written or pictorial job procedures, decision tables or
flow charts.
When Training Might Be Needed
• New employee is hired
• Employee is transferred to new job
• Individual doesn’t follow procedure / instruction
• Procedures are changed
• New process, material, or equipment is introduced
• Company changes objectives and / or targets
• New regulation affects company activities
• Job performance is not acceptable
A Few Thoughts about Adult Learning
• Adults need the opportunity to integrate new ideas with what they already
know.
• Information that conflicts sharply with existing beliefs or has little conceptual
overlap with what is already known is acquired more slowly.
• Adults prefer self-directed learning and want to have a hand in shaping the
training program.
• Adults have expectations. It is important to clarify these up-front.
• Adults prefer active participation to straight lecture.
-Adapted from “30 Things We Know for Sure About Adults Learning” (Training
Magazine, July 1988)
Review: Have we …
•identified training needs?
•developed a training plan?
•provided the required training at all levels?
•communicated training responsibilities?
•tracked and documented training?
8. Communications
•How are communications critical to the success of our EMS?
•Opening the information lines
Consider communication strategies for:
• neighbors
• community groups
• other interest groups
• local officials
• regulatory agencies
• emergency responders

•Example: External Outreach Warner-Lambert Company has hosted local community leaders,
state agencies, and federal agencies, to share its environmental activities and programs and
to obtain feedback.
•Example: Milan Screw Products’ staff interviewed neighbors, customers, suppliers, and
employees’ family members to obtain the views of external parties.

•The importance of employee involvement in developing and implementing your EMS has
been discussed earlier.
•Effective environmental management requiers effective communications.
•Communications will help you:
• motivate the workforce;
• explain the environmental policy (both internally and externally) and how it
relates to the overall business vision / strategy;
• ensure understanding of roles and expectations;
• demonstrate management commitment;
• monitor performance; and,
• identify potential system improvements.

•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, issues and ideas.
•Communicating with external parties is also important for effective environmental
management.
•Obtaining the views of neighbors, community groups, and customers, (among
others), will help you understand how your organization is perceived by others.
•Information from external sources can be critical in setting environmental and
other business goals.
•An effective EMS should include procedures for:
• communicating internally (between levels and functions), and
• soliciting, receiving, documenting and responding to external communications.
Getting Started:
•The first step in designing a communications program is determining your
audiences. Make a list of internal and external audiences.

•Once you identify the audiences, you should then determine what you need to
communicate with them. (What do they need to know about your products or
operations? What are their concerns?)

•Next, decide how you can best reach them. Appropriate communication methods
might vary from audience to audience. Start by looking at your existing methods
for communicating, both internally and externally. These might include:
Internal Methods
• newsletters
• staff meetings
• employee meetings
• bulletin boards
• brown bag lunches

External Methods
• open houses
• focus groups
• press releases
• annual reports
• advertising
Hints:
• Determine how proactive your external communications strategy will be. Select an
approach that fits your organization’s culture and strategy. For example, will reporting on
environmental performance and progress give you an edge over the competition?
While a proactive external communications program may require more resources, some
organizations have found that a proactive strategy can be quite beneficial. Weigh the costs
and benefits for yourself, but keep in mind that there might be many interested audiences.

• In communicating with employees, it is helpful to explain not only what they need to do
but why they need to do it. For example, when describing a requirement based on a
regulation, simply saying “the regulations require it” is not sufficient explanation. Try to
explain the purpose behind the rule and why it is important. Also make a clear connection
between the requirement and how it applies to each person’s job.

• Keep the message simple — all communications should be clear, concise, and accurate.

• Managing responses to external inquiries does not have to be a burdensome task. Use a
simple method, such as stapling an inquiry to its written response and then filing them
together. The key is to be able to demonstrate that the organization has a system for
responding to external inquiries.
• Example: POLLUTION PREVENTION PP and Communication
•Rochester Midland Corporation developed a program to improve indoor
environmental quality in buildings where cleaning products are used.
•This model program uses cleaning procedures that reduce emissions, products
that are less hazardous, and engineering controls for consistent quality.
•Rochester Midland placed postcards on building tenants’ desks that informed
them of the program & solicited feedback for continual improvement of the
program.

•Review: Have we …
•established procedures for internal and external communication?
•determined who is responsible for responding to external inquiries?
•identified target audiences?
•determined the proper communications methods for each audience?
9. EMS Documentation
•Why do we need documentation of our EMS?
•Describing your EMS and how the pieces fit together
•Easier to read and understand = easier to follow
•To ensure that your EMS is well understood and operating as designed, you need
to get information to the people doing the work.
•In addition, there are external parties that might need to understand how your
EMS operates, such as customers, registrars, regulators, lending institutions, and
the public.
•A “road map” of your EMS explaining how the pieces fit together can be a very
useful tool.
•EMS documentation can be viewed as a series of explanations or statements of
how EMS criteria (such as ISO 14001) apply to your organization.
•While you don’t need to maintain a single “manual”, you should maintain EMS
information in a form that:
• describes the core elements of your EMS (and how these elements relate to each
other), and
• provides direction to related documentation.

•You can maintain this documentation either on paper or electronically.

•There may be some advantages to maintaining documents electronically, such as
easier updating, access control, and ensuring that the most up to-date version of a
document is used by all readers.
•EMS documentation is related to (but not the same as) EMS records.
• EMS documentation describes
what your system consists of (i.e.,
what you do), while EMS records
demonstrate that you are doing
what you said you would do.
• EMS records are described later
in this Guide.
• One way to think about your EMS
documentation is to use the
figure shown, which also applies
to ISO 9000 documents.
Hints:
• Keep your EMS documentation simple and choose a format that works best for
your organization. The documentation does not need to describe every detail of
your EMS or how your organization conforms to the ISO 14001 Standard (or other
EMS criteria). Instead, consider providing references to other documents or
procedures.

• Use the results of your preliminary assessment to prepare your EMS

documentation. In the course of conducting the preliminary assessment, you
should have collected or prepared useful material on how your organization
satisfies the EMS criteria.

• The usefulness of your EMS documentation can be improved by including the

organization’s mission statement, vision, guiding principles, and annual objectives
(if these exist). These will help readers understand the organizational context and
how the EMS supports overall business goals.

• An EMS manual can be a useful tool for explaining your EMS to new employees,
customers, or others.
• EMS documentation should be updated as needed, based on any system
improvements you put in place.
However, if you put too much detail in an EMS manual, you may have to update
the manual frequently (see first hint, above).

What Constitutes EMS Documentation?

Consider including the following:
• your environmental policy
• your organizational structure and key responsibilities
• descriptions of how your company meets ISO 14001 requirements (e.g., “How do
we identify environmental aspects?”. “How do we control documents?” How do
we conduct EMS audits?”)
• references to key procedures / controls
• direction to other related documents (such as emergency response plans,
training plans, etc.)
Review: Have we …
•documented the environmental policy, organization, key procedures, and other
system elements?
•described where people can find the documents listed above and related
documents?
•explained the linkages among system elements?
•10. Document Control
•How do we ensure everyone is working with the right information?
•Suggested elements of document control:
• issue / revision date
• effective date
• approval (i.e., signature)
• revision number
• document number (or other identifier)
• copy number
• cross-references

•Key Question: Is everyone working with the same set of documents?

•People in your organization probably use various documents (drawings, work

instructions and the like) as they perform their duties.
•To ensure that your personnel are consistently doing the job right, the
organization must provide them with the right tools.
•In this case, the tools needed are the correct and up-to-date procedures, drawings
and other documents.
•Without a mechanism to control EMS documents, the organization has no way of
knowing (or verifying) that people are working with the right tools.
•To ensure that everyone is working with the proper EMS documents, your
organization should have a procedure that describes how documents are
controlled.
•Implementation of this procedure should ensure that:
• EMS documents can be located,
• they are periodically reviewed,
• current versions are available where needed, and
• obsolete documents are removed.

•Your document control procedure should designate responsibility and authority

for preparing documents, making changes to them and keeping them up-to-date.
•In other words, you need to make it clear who can actually change documents
and what the change process is.
•Getting Started:
• EMS document control requirements are almost a mirror image of the ISO 9000
requirements. Organizations that have or are developing an ISO 9000 management
system can enjoy some advantages here.
• Even if your organization doesn’t have an ISO 9000 system, you might be better
off than you think. Your organization probably has document controls in place for
other business purposes (such as finance, human resources or purchasing). Assess
how well these controls work and if they can be adapted for your EMS.
Documents that should be controlled:
· policy
· manual
· procedures
· work instructions
· forms & drawings
Hints:
• Don’t make your procedure more complicated than it needs to be. While larger
organizations often have complex processes for document control, smaller
organizations can use simpler systems.

• Limiting distribution makes the job easier. Does everyone have access to one or a
few copies? Determine how many copies you really need and where they should be
located for ease of access.

• If the people that need access to documents are connected to a local area
network, consider using a paperless system. This can facilitate control and revision
of documents considerably.
• Prepare a document control index that shows all of your EMS documents and the
history of their revision. Put this index in your manual.
• Also, if multiple copies of
documents are available at the
facility, prepare a distribution list,
showing who has each copy and
where the copies are located.
• As your procedures or other
documents are revised, highlight
the changes (by underlining,
boldface, etc.). This will make it
easier for the reader to find the
changes.
Review: Have we …
•developed a procedure to control EMS documents?
•determined the number of copies of documents we need?
•Established responsibilities and authorities for document preparation, revision,
management, and disposition?
11. Operational Control
•What operations and activities must be controlled for environmental
management?
•To ensure that your environmental policy is followed and that your objectives are
achieved, certain operations and activities must be controlled.
•Where an operation or activity is complex and/or the potential environmental
impacts are significant, these controls should take the form of documented
procedures.
•Procedures can help your organization to ensure regulatory compliance and
consistent environmental performance.
•Procedures can also play a key role in employee training.
•Documented procedures should cover those situations where the absence of
procedures could lead to deviations from the environmental policy or your
objectives and targets.
•Determining which operations should be covered by documented procedures and
how those operations should be controlled is a critical aspect of developing an
effective EMS.
•In deciding which activities need to be controlled, look beyond routine production
on the shop floor.
•Activities such as maintenance, management of on-site contractors, and
relationships with suppliers or vendors could affect your organization’s
environmental performance significantly.
Getting Started:
• Start by looking at the environmental aspects and potentially significant impacts
which you identified earlier. Identify the processes from which these significant
impacts arise, and consider what types of controls might be needed to prevent or
manage these impacts. If you have flow charts of these processes, identify the
points in each process where some type of control may be appropriate.

• Prepare draft procedures and review them with the people who will need to
implement them. This will help to ensure that the procedures are accurate and
realistic.
• Examples of Activities and
Operations that Might Require
Operational Controls:
• management / disposal of wastes
• approval of new chemicals
• storage & handling of raw materials
and chemicals
• wastewater treatment
• operation of paint line
• operation of plating system
• management of contractors
• Hints:
• Look at procedures you already
have in place to comply with
environmental and health &
safety regulations. Some of these
may be adequate to control
significant impacts (or could be
modified to do so). Develop a
chart to keep track of what is
needed:
• Rules of Thumb: the more highly skilled and trained your employees are, the less
critical procedures will be. The more complex the work or the greater the potential
impact on the environment, the more important these procedures will be.

• Once you have identified operations that require control, consider what kinds of
maintenance and calibration may be appropriate. However, the need for
maintenance on equipment that could have significant environmental impacts
should be obvious, and the need to plan and control such maintenance should not
be overlooked. This does not mean that an elaborate preventive or predictive
maintenance program is needed in all cases. Assess your existing maintenance
program and its effectiveness before making significant changes.

• Some of your identified environmental aspects may be related to the chemicals,

raw materials, or other goods and services you obtain from vendors/suppliers.
Likewise, the activities of your contractors can affect your environmental
performance. Communicate your expectations (including any relevant procedures)
to these business partners.

• While the development of procedures can be time consuming, some

organizations have come up with creative ways to reduce the data collection
burden.
Consider having a college intern or temporary employee interview your employees
“on the line” to collect information on what employees do and how they do it.

• If your organization uses a “work team” concept, ask the work teams to draft
procedures for their areas (or to modify existing procedures for EMS purposes).
Hints on Writing Procedures
• Understand the existing process (start with a flow chart, if one is available). Build
on informal procedures where possible.
• Focus on steps needed for consistent implementation.
• Use a consistent format and approach.
• Review draft procedures with employees that will have to implement them.
(Better yet, enlist employees to help write them.)
• Keep procedures simple and concise. Excessive detail doesn’t provide more
control and is not needed.

•Example: POLLUTION PREVENTION

•Rochester Midland Corporation, a manufacturer of cleaning and other chemical
products, formed a partnership with a cleaning contractor that uses Rochester
Midland’s products, the owners of a building where the products are used, and
building tenants, to lessen the risks associated with cleaning products.
•The partners began by developing common goals, identifying alternative cleaning
products and processes, and identifying opportunities to reduce risks to building
occupants and cleaning staff.
•Over a two-month period, they were able to: reduce chemical exposures; improve
tenant satisfaction; improve communication, awareness, and training; achieve a
50% reduction in cleaning products; and achieve measurable cost savings.
Review: Have we …
developed procedures to control key operations / activities?
trained employees on these procedures?
covered normal operations, abnormal operations, emergencies?
12. Emergency Preparedness and Response
•How should we be prepared for accidents and emergencies?
•Minimizing the impacts of uncontrolled events
•Don’t think only about response — focus on how to prevent accidents in the first
place!
•Review prior accidents and incidents as one guide to where future incidents may
occur.
•Useful Information:
· Material safety data sheets
· Plant drawings
· Process flow diagrams
· Piping and instrumentation
· Design codes and diagrams standards
· Specifications on safety systems (alarms, sprinklers, etc.)

•Despite an organization’s best efforts, the possibility of accidents and other

emergency situations still exits.
•Effective planning and preparation can reduce injuries, protect employees and
neighbors, reduce asset losses and minimize production downtime.
•An effective emergency preparedness and response program should include
provisions for:
• assessing the potential for accidents and emergencies;
• preventing incidents and their associated environmental impacts;
• plans / procedures for responding to incidents;
• periodic testing of emergency plans / procedures; and,
• mitigating impacts associated with these incidents.

•Consistent with your organization’s focus on continual improvement, it also is a

good idea to review emergency response performance after an incident has
occurred.
•This review can help determine if more training is needed or if emergency plans /
procedures should be revised.
Getting Started:
• This is another area where you should not have to start from scratch. Several
environmental and health and safety regulatory programs require emergency plans
and/or procedures. Look at what you have in place now and assess how well it
satisfies the items discussed above.

• One area where additional work is often needed is on identifying the potential
for accidents and emergencies. A team of site personnel (from engineering,
maintenance and Environmental Health & Safety, for example) can identify most
potential emergencies by asking a series of “what if” questions related to
hazardous materials, activities, and processes employed at the site. In addition to
normal operations, the team should consider start-up and shutdown of process
equipment, and other abnormal operating conditions.

·Ask yourself: Does everyone (including new employees) know what to do in an

emergency? How would contractors or site visitors know what to do in an
emergency situation?

• Communicate with local officials (fire department, hospital, etc.) about potential
emergencies at your site and how they can support your response efforts.
Hints:
• Mock drills can be an excellent way to reinforce training and get feedback on the
effectiveness of your plans / procedures.

• Post copies of the plan (or at least critical contact names and phone numbers)
around the site and especially in areas where high hazards exist. Include phone
numbers for your on-site emergency coordinator, local fire department, local police,
hospital, rescue squad, and others as appropriate.

Checklist for Emergency Preparedness and Response Plan

Does your plan describe the following:
· potential emergency situations (such as fires, explosions, spills or releases of
hazardous materials, and natural disasters)?
· hazardous materials used on-site (and their locations)?
· key organizational responsibilities (including emergency coordinator)?
· arrangements with local emergency support providers?
· emergency response procedures, including emergency communication
procedures?
· locations and types of emergency response equipment?
· maintenance of emergency response equipment?
· training / testing of personnel, including the on-site emergency response team
(if applicable)?
· testing of alarm / public address systems?
· evacuation routes and exits (map), and assembly points?
Review: Have we …
•reviewed operations for potential emergency situations?
•developed plans / procedures for managing these situations?
•trained personnel and obtained any necessary emergency equipment?
•established a feedback loop so we can learn from our experiences?
13. Monitoring and Measurement
•How do we know how we are doing?
•Assessing how well the system is working
Attributes of an Effective Measurement Program
• simple
• flexible
• consistent
• ongoing
• results communicated
• reliable data produced

Environmental performance evaluation is an ongoing process

•Regulators may provide incentives for effective compliance management

programs, including self-reporting - “Incentives for Self- Policing: Discovery,
Disclosure, Correction and Prevention of Violations “

•Employees should have a mechanism to report regulatory violations (or other

EMS issues) without fear of retaliation by their employer.
•Leading vs. Lagging Indicators
•Number of people trained in spill prevention (Leading) vs. Number of spills that
took place (Lagging)
•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 can’t
tell where you are going! Monitoring and measurement enables you to:
• gauge your environmental performance;
• analyze root causes of problems;
• identify areas where corrective action is needed; and,
• improve performance / increase efficiency.

•In short, monitoring helps you manage your business better.

•Pollution prevention and other strategic business opportunities are identified
more readily when current and reliable data is available.
Your organization should develop procedures to:
• monitor key characteristics of operations and activities that can have significant
environmental impacts;
• track performance (including how well you meet your objectives and targets);
• calibrate and maintain monitoring equipment; and,
• through internal audits, periodically evaluate your compliance with applicable
laws and regulations.
 Getting Started:
• Monitoring and measuring can be resource-intensive. One of the most important
steps you can take is to clearly define your needs. While collecting information is
clearly important, resist the urge to collect data “for data’s sake.”

• Review the kinds of monitoring you do now for regulatory compliance and other
purposes (such as quality or health and safety management). How well does this
serve your EMS purposes? What additional monitoring or measuring might be
needed?

• You can start with a relatively simple monitoring and measurement system, then
build on it as you gain experience.
 Hints:
• Monitoring key process characteristics: Many management theorists endorse
the concept of the “vital few” — that is, that a limited number of factors can be
measured to determine the outcome of a process. The key is to figure out what
those factors are and how to measure them. Root cause analysis is one way to
identify what those factors might be.

• Most effective environmental measurement systems use a combination of

process and outcome measures. Outcome measures look at results of a process or
activity (such as the amount of waste generated or the number of spills that took
place). Process measures, on the other hand, look at “upstream” factors, such as
the amount of paint used per unit of product or the number of employees
trained. A combination of process and outcome measures may be right for your
organization.

• Equipment calibration: Identify process equipment and activities that truly affect
your environmental performance. As a starting point, look at the key process
characteristics you identified earlier. Some companies choose to put key
monitoring equipment under a special calibration and preventive maintenance
program. This can help to ensure accurate monitoring and lets employees know
which instruments are most critical for environmental monitoring purposes.
In some cases, it may be more cost-effective to subcontract calibration and
maintenance of monitoring equipment than to perform these functions internally.

• Assessing regulatory compliance: Determining your compliance status on a

regular basis is very important. You should have a process to systematically identify,
correct, and prevent violations. Performance of the compliance management
program should be considered during EMS management review. Compliance
Management Program Elements:
• Organization policies and standards that describe how employees are to meet the
regulations
• Assignment of responsibility for compliance oversight
• Processes to systematically ensure that policies and standards are carried out
(e.g., monitoring and auditing)
• Appropriate incentives and disciplinary procedures
• Prompt disclosure of findings
• Prompt and appropriate correction of problems (adapted from EPA’s final policy
statement on self-auditing; December 22, 1995)

• Evaluating environmental performance: Go back and look at your significant

environmental aspects and the objectives and targets associated with those
significant aspects.
What information will you need to determine if the company is achieving its
objectives and targets? Focus on things that you can do something about!

• Start by selecting a few performance indicators that are:

- simple and understandable
- objective
- verifiable
- relevant to what your organization does (i.e., its activities, products, and services)

• Make sure you can commit the necessary resources to track this information over
time. It is OK to start small and build over time as your company gains experience in
evaluating its performance. Keep in mind that no single measurement will tell your
organization how it is doing in the environmental area.

• People respond best to information that is meaningful to “their world.” Putting

environmental information in a form that is relevant to their function increases the
likelihood they will act on the information. Be sure to link your measurement
program with your communications program and other elements of the EMS (such
as management reviews, as discussed later).
• The distinction between audits and environmental performance evaluation can be
confusing. Both are important to your EMS.
Review: Have we …
•identified key process characteristics and how to measure / monitor them?
•set up a process to regularly evaluate (through internal audits) compliance with
laws and regulations?
•determined how to measure performance against our objectives and targets?
established procedures to maintain and calibrate key monitoring equipment?
14. Nonconformance and Corrective / Preventive Action
•What do we do when we find a problem?
•Fixing EMS problems and avoiding them in the future
•Nonconformance means......
• system does not meet the EMS criteria (such as ISO 14001) -or-
• implementation is not consistent with the EMS description

•Recurring problems are expensive !

•No EMS is perfect.

•You will probably find problems with your system, especially in the beginning
(through audits, measurement, or other activities).
•Your EMS will also need to change as your organization changes and grows.
•When system deficiencies are encountered, your organization will need a process
to ensure that:
• problems (including
nonconformities) are
investigated;
• root causes are identified;
• corrective actions are identified
and implemented; and,
• corrective actions are tracked and
documented.

• EMS nonconformities and other

system deficiencies should be
analyzed to detect patterns or
trends.
•Identifying these trends will allow you to anticipate and prevent future problems.
•Focus on correcting and preventing problems.
•Preventing problems is generally cheaper than fixing them after they occur (or
after they reoccur).
This approach is consistent with the continual improvement philosophy.
Hints:
• If your organization has an ISO 9000 management system, you should already
have a corrective / preventive action process for quality purposes. You can use this
as a model (or integrate with it) for EMS purposes.

• Small companies might find they can combine their management review and
corrective action processes, especially if the same people are involved in both. At
the very least, a strong link should exist between the two processes.

• The amount of planning and documentation needed for corrective / preventive

actions can vary with the severity of the problem (and its potential environmental
impacts). Don’t go overboard with bureaucracy — simple methods often work
best.

• Once you document a problem, the organization must be committed to

resolving it. Corrective actions should be implemented as quickly as possible.
 Be sure that your corrective /
preventive action process
specifies responsibilities and
schedules. Review your progress
regularly and follow up on any
deficiencies.

• Make sure you collect the right

data / information to make good
decisions. While many corrective
actions may be “common sense,”
you need to look below the
surface to determine why a
problem has occurred.
• Initially, most EMS problems may be identified by your auditors. However, over
the long run, most problems and good ideas may come from the people in the shop
doing the work. This should be encouraged. Find ways to get employees involved in
the system improvement process (for example, via suggestion boxes, contests and
incentive programs).

Why do EMS problems occur? Typical causes include:

• poor communication
• faulty or missing procedures
• equipment malfunction (or lack of maintenance)
• lack of training
• lack of understanding (of requirements)
• failure to enforce rules

Key Steps:
• identify the problem
• identify the cause (investigate)
• come up with solution
• implement solution
• document solution
• communicate solution
Review: Have we …
•developed procedures for investigating, correcting, and preventing system deficiencies?
•set up a process for assigning responsibilities for and tracking completion of corrective
actions?
set up a process to revise procedures or other EMS documents based on corrective /
preventive actions?
15. Records
•How do we prove that our EMS is working?
•Evidence that the EMS is working properly
•Records should be important to the operation of the EMS, including your
regulatory compliance efforts.
•Key Questions:
• what records are kept?
• who keeps them?
• where are they kept?
• how are they kept?
• how long are they kept?
• how are they accessed?
• how are they disposed?

•The value of records management is fairly simple — you should be able to prove
that your organization is actually implementing the EMS as designed.
•While records have value internally, over time you may need to provide evidence
of EMS implementation to external parties (such as customers, a registrar, or the
public).
•Records management is often viewed as bureaucratic, but it is hard to imagine a
process or system operating consistently without keeping accurate records.
•Basic records management is straightforward — you need to decide what records
you will keep, how you will keep them and for how long.
•You should also think about how you will dispose of records once you no longer
need them.
If your organization has an ISO 9000 management system, you should have a
system for managing quality records.
Hints:
• Focus on records that add value — avoid bureaucracy. If records have no value,
then don’t collect them. The records you choose to keep should be accurate and
complete.

• You may need to generate certain forms as you develop your EMS. These forms
should be simple and understandable.

• Consider combining your records management processes for environmental and

health & safety records.
• Establish a records retention policy and stick to it. Make sure that your policy
takes into account records retention requirements specified in applicable
environmental regulations.

• In designing your records management system, be sure to consider:

- who needs access?
- to what records?
- in what circumstances?

• If your organization uses computers extensively, consider using an electronic EMS

records management system. Maintaining records electronically can provide an
excellent means for rapid retrieval of records as well as controlling access to
sensitive records.

• Think about which records might require additional security. Do you need to
restrict access to certain records? Should a back-up copy of critical records be
maintained at another location?

Types of Records You Might Maintain (Examples):

• legal, regulatory and other code requirements
• results of environmental aspects identification
• reports of progress towards meeting objectives and targets
• permits, licenses and other approvals
• training records
• EMS audit and regulatory compliance audit reports
• reports of identified nonconformities, corrective action plans and corrective
action tracking data
• hazardous material spill / other incident reports
• communications with customers, suppliers, contractors and other external parties
• results of management reviews
• sampling and monitoring data
• maintenance records
• equipment calibration records
-(ISO 14001 requires that organizations have procedures for training records and
the results of audits and reviews)

Review: Have we …
•identified records to be maintained?
•determined their retention times?
•set up a good storage and retrieval system?
16. EMS Auditing
•Are we doing what we said we would do?
•Objective evidence of conformance with EMS requirements
•Audits are vital to continual improvement
•EMS Audit: “ A systematic and documented verification process of objectively obtaining and
evaluating evidence to determine whether an organization’s environmental management
system conforms to the environmental management system audit criteria set by the
organization, and for communication of the results of this process to management.” ISO
14001
•Once your organization has established its EMS, verifying the implementation of the system
will be critical.
•To identify and resolve EMS deficiencies you must actively seek them out.
•In a small organization, audits are particularly relevant since managers are often so close to
the work that they may not see problems or bad habits that have developed.
•Periodic EMS audits will establish whether or not all of the requirements of the EMS are
being carried out in the specified manner.
•For your EMS audit program to be effective, you should:
• develop audit procedures and protocols;
• establish an appropriate audit frequency;
• train your auditors; and,
• maintain audit records.

•The results of your EMS audits should be linked to the corrective action system.
•While they can be time-consuming, EMS audits are critical to EMS effectiveness.
•Systematic identification and reporting of EMS deficiencies to management provides a great
opportunity to:
• maintain management focus on the environment,
• improve the EMS, and
• ensure its cost-effectiveness.
Getting Started:
• How frequently do we need to audit? In determining the frequency of your EMS audits,
some issues to consider are:
- the nature of your operations,
- the significant environmental aspects / impacts (which you identified earlier),
- the results of your monitoring program, and
- the results of previous audits.
As a rule of thumb, all parts of the EMS should be audited at least annually. You can audit the
entire EMS at one time or break it down into discrete elements for more frequent audits.
(There may be advantages to more frequent audits, but the decision is up to you).

• Who will perform the audits? You will need trained EMS auditors. Auditor training should be
both initial and ongoing. Commercial EMS auditor training is available, but it might be more
cost-effective to link up with businesses and other organizations in your area (perhaps
through a trade association) to sponsor an auditor training course. A local community college
might also provide auditor training.
EMS auditors should be trained in auditing techniques and management system concepts.
Familiarity with environmental regulations, facility operations, and environmental
science is a big plus, and in some cases may be essential to adequately assess the
EMS. Some auditor training can be obtained on-the-job. Your organization’s first few
EMS audits can be considered part of your auditor training program (but make sure
that an experienced auditor takes part in those “training” audits).

If your company is registered under ISO 9000, consider using your internal ISO 9000
auditors as EMS auditors. Although some additional training might be needed,
many of the required skills are the same for both types of audits.

• How should management use audit results? Management can use EMS audit
results to identify trends or patterns in EMS deficiencies. The organization must also
make sure that any identified system gaps / deficiencies are corrected in a timely
fashion and that the corrective actions are documented.
Hints:
• Your EMS audits should focus on objective evidence of conformance. (If you
cannot tell whether or not a particular procedure has been followed, then you
should consider revising the procedure). During the actual audit, auditors should
resist the temptation to evaluate why a procedure was not followed — that step
comes later.
• During the course of the audit, auditors should discuss identified deficiencies
with the people who work in the area. This will help the auditors verify that their
understanding is correct. It can also serve as refresher training (on EMS
requirements) for employees.

• If possible, train at least two people as internal auditors. This allows your
auditors to work as a team. It also allows audits to take place when one auditor has
a schedule conflict (which is unavoidable in a small organization!).
Some Options for Auditing
- Barter for audit services with other small companies
- Use external auditors
- Have office personnel audit production areas (and vice versa)

• Before you start an audit, be sure to communicate the audit scope, schedule, and
other pertinent information with the people in the affected area(s). This will help
avoid confusion and will facilitate the audit process.

• Consider linking your EMS audit program to your regulatory compliance audit
process. But keep in mind that these audit programs have different purposes, and
while you might want to communicate the results of EMS audits widely within your
organization,
the results of compliance audits
might need to be communicated
in a more limited fashion (in order
to maintain attorney-client or
attorney work product privilege,
for example).

Audit procedures should describe:

• audit scope (areas and activities
covered)
• audit frequency
• audit methods
• key responsibilities
• reporting mechanisms
Traits of a good auditor:
• Independent (of the
• Objective
• Impartial activity being audited)
• Tactful
• Attentive to detail
Sources of Evidence:
• interviews
• document review
• observation of work practices

•ISO has finalized three guidance standards for environmental auditing — ISO
14010, ISO 14011, and ISO 14012.
•These guidelines may help your organization to develop its EMS auditing program.

•Results of regulatory compliance audits are often good indicators of EMS

deficiencies.
•Use compliance audit findings to guide your EMS audit efforts.

•Even if you have an effective internal audit program, consider periodic external
audits to ensure objectivity.
Review: Have we …
•developed an audit program?
•determined an appropriate audit frequency?
•selected and trained EMS auditors?
•conducted EMS audits as described in the program?
•developed a process to keep records of these audits?

17. Management Review

•How do we ensure that our EMS will remain viable?
•Closing the continual improvement loop
•Management reviews can be used to demonstrate top management’s ongoing support for
the environment
•Hold management reviews “after hours” so that production will not be affected.
•Just as a person should have periodic physical exams, your EMS must be reviewed by
management from time to time to stay “healthy.”
•Management reviews are the key to continual improvement and to ensuring that the EMS
will continue to meet your organization’s needs over time.
•Management reviews also offer a great opportunity to keep your EMS efficient and cost
effective.
•For example, some organizations have found that certain procedures and processes initially
put in place were not needed to achieve their environmental objectives or control key
processes.
•If EMS procedures and other activities don’t add value, eliminate them.
•The key question that a management review seeks to answer is: “Is the system working?”
( i.e., is the EMS suitable, adequate and effective, given our needs?)
Hints:
• There are two kinds of people who should be involved in the management review process:
- people who have the right information / knowledge
- people who can make decisions

• Determine the frequency for management reviews that will work best for your
organization. Some organizations combine these reviews with other meetings (such as
director meetings) while other organizations hold “stand-alone” reviews. For ISO 9000
purposes, management reviews are typically held once or twice per year.

• Regardless of what approach your organization takes, make sure that someone takes notes
on what issues were discussed, what decisions were arrived at, and what action items were
selected. Management reviews should be documented.

• The management review should assess how changing circumstances might influence the
suitability, effectiveness or adequacy of your EMS. Changing circumstances may be internal
to your organization (i.e., new facilities, new materials, changes in products or services, new
customers, etc.) or may be external factors (such as new laws, new scientific information, or
changes in adjacent land use).
• Once you have documented the action items arising from your management review, be
sure that someone follows-up. Progress on these items should be tracked.
• As you evaluate potential changes to your EMS, be sure to consider your other
organizational plans and goals. Environmental decision-making should be
integrated into your overall management and strategy.

Questions to Ponder During Management Reviews

• Did we achieve our objectives and targets? (if not, why not?) Should we modify
our objectives?
• Is our environmental policy still relevant to what we do?
• Are roles and responsibilities clear and do they make sense?
• Are we applying resources appropriately?
• Are the procedures clear and adequate? Do we need others? Should we
eliminate some?
• Are we monitoring our EMS (e.g., via system audits)? What do the results of
those audits tell us?
• What effects have changes in materials, products, or services had on our EMS
and its effectiveness?
• Do changes in laws or regulations require us to change some of our approaches?
• What stakeholder concerns have been raised since our last review?
• Is there a better way? What else can we do to improve?
Information sources to consider:
• audit results
• internal suggestions
• external communications
• progress on objectives and targets
• other environmental performance measures
• reports of emergencies, spills, other incidents
• new or modified legislation and regulations
• new scientific/ technical data on materials and processes used by the
organization

•The Internet is a good way to stay on top of changing laws, regulations,

technologies, and other environmental information.
•“Many of the benefits of an EMS cannot be anticipated beforehand. You will have
to discover them as pleasant surprises at some point after implementation. They
will be there.” - Milan Screw Products
•Review: Have we …
•established a process for periodic reviews of our EMS?
•documented the results of such reviews?
followed-up on action items to ensure closure?
YOU NOW HAVE ALL OF THE ELEMENTS OF AN EFFECTIVE EMS !!
 Section 5 : The Registration Process

• This section describes the registration process, and will help you to decide if your
organization should pursue registration.
• 1st Party Audit- Internal Audit
• 2nd Party Audit- Customer audit of a supplier
• 3rd Party Audit -Audit by another party independent of a supplier and its
customer
Registration vs. Certification
• Both terms can be used to describe the third-party process.
• In the U.S., the term registration is generally used for management systems,
while the term certification is generally used for products.
• Environmental management system registration is the process whereby a non
biased third-party attests that an organization’s EMS conforms with the
requirements of an EMS standard, such as ISO 14001.
• The third-party organization that performs the registration services is called a
registrar,” and is selected by the organization that desires registration services.
•The type of registration services that will be offered for ISO 14001 will be similar to
those offered for the ISO 9000 series of quality management system standards.
•In North America, over 13,000 companies have been registered to ISO 9000.
•A registrar can be accredited by a third-party accreditation body that is
independent of the registrar.
•Accreditation is the process in which a registrar’s competence is evaluated by a
third-party accreditation body with national or governmental recognition.
•Accreditation greatly enhances a registrar’s credibility.
•ISO 14001 does not require that an organization implement the Standard at the
corporate level.
•For example, one organization may choose to implement the Standard throughout
the entire organization, while another may implement the Standard in one
particular facility.
•An organization can elect to register the entire organization, a division(s), selected
facilities, a particular facility, or selected operations within a facility.
•The key factor in choosing the organizational unit for registration purposes is that it
has its own functions and administration.
•Registrars may have different registration processes and may offer different types
of services.
•The following is a description of a fairly typical registration program which is
provided for illustrative purposes:
The Registration Process
Overview of the Typical EMS Registration Process:
1. Application
2. EMS Documentation Review - Desk Audit
3. On-site EMS Readiness Review
4. Registration Audit
5. Registration Determination
6. Surveillance
Step 1: Application for Registration
•The organization seeking EMS registration submits an application indicating the
activities and facilities of the organization or site to be registered.
Step 2: Review of EMS Documentation / Desk Audit
•The organization submits documentation of its EMS, which includes its
environmental policy and documentation indicating how it meets each clause in the
ISO 14001 Standard.
•The documentation is reviewed by a designated lead auditor.
•The auditor generates a written report which indicates conformance or
nonconformance of the documented EMS to each clause of the Standard.
Step 3: On-site EMS Readiness Review
•The lead auditor conducts an on-site visit in order to resolve any EMS
documentation nonconformities and to verify that the facility is prepared for a full
registration audit.
•The onsite visit is also used to assess the resources and logistics necessary for the
full registration audit.
Step 4: Registration Audit
•An audit team conducts an on-site audit to evaluate and verify through objective
evidence (interviews, procedures, records, etc.) that the EMS conforms to the
requirements in the ISO 14001 Standard, is effectively implemented, and has
sufficient provisions to be maintained.
Step 5: Registration Determination
•A final report containing the results of the registration audit is submitted to the
organization.
•To receive a Certificate of Registration, an organization must successfully meet the
requirements of the ISO 14001 Standard, as well as the registration policies of the
registrar.
•Step 6: Surveillance
•Surveillance audits are typically performed semi-annually to verify continued
conformance with the ISO 14001 Standard.
•During the surveillance audits, the audit team may only audit certain elements of
the EMS.
•Over a three year period, however, all of the elements of the EMS must be
reviewed to ensure continued conformance to the requirements of the ISO 14001
Standard.

•The ISO 14001 Standard does not require third party registration, but market
forces and regulatory incentives may provide strong encouragement for
registration.
Possible Registration Audit Results
•There are three possible results from a registration or surveillance audit.
•The registrar can determine that the applicant is:
•Recommended for registration
•There are no major nonconformities.
-or –
•Recommended for registration following verification of corrective action
•There are one or more major nonconformities which can be corrected and verified without a
full re-audit.
- or -
•Recommended for an on-site reassessment
•There are several major nonconformities which indicate a breakdown of the EMS.
Another full on-site audit is required.
Classification of Audit Findings:
Major Nonconformity- Absence or complete breakdown of an EMS element.
•A large number of minor nonconformities for one element may be considered a
major nonconformity.
•Minor Nonconformity- A single observed nonconformity.
Should Your Organization Pursue Registration?
•There are numerous benefits associated with implementing an EMS; some of those
benefits can be the result of external recognition.
•An organization that voluntarily implements an EMS standard, such as ISO 14001,
may be able to demonstrate externally that it has made a commitment to
environmental protection.
•The ISO 14001 Standard does not require registration.
•An organization can demonstrate its commitment to proactive environmental
management to its stakeholders and other interested parties in two ways:
•An organization can have its EMS audited and registered by an independent 3 rd
party, i.e. registrar; — or —
•An organization can make a self-determination and self-declaration of
conformance to an EMS standard.

•An organization should carefully consider several factors in order to determine

which approach is best.
•An organization’s reputation and relationship with its stakeholders and other
interested parties may play a significant role in helping it to determine which
option is most desirable.
•An organization that is weighing the pros and cons of self-declaration vs.
registration should also consider the following factors:
•Strategic goals;
•Maintenance of current market position;
•Opportunities for a competitive advantage;
•Investor criteria for access to capital;
•Possible regulatory incentives; and
•The credibility of self-declaration.

•Example: “We concluded that eventually Quinn would have to be ISO 14001
certified to compete internationally.” — K.J. Quinn
•Example: Hach Company will “wait and see” if market forces and potential
regulatory incentives provide sufficient benefits to offset the costs of registration.
— Hach Company
•“ … as is the case with ISO 9000, some early indications are that ISO 14001
registration will be a prerequisite for doing business internationally, especially in
Europe.” — Globe Metallurgical Inc.
•In certain cases, EMS registration may be required by customers or may be necessary to
fulfill a contract requirement.
•Organizations that sell their goods or services internationally may find that EMS registration
is a strong selling point in the global marketplace and may enable them to obtain preferred
supplier status.
•For certain organizations, registration to the ISO 9000 series of quality management system
standards has become a prerequisite for doing business domestically and internationally.
•EMS registration may be pursued by a wide variety of organizations, including those that
have obtained quality management system registration.
•EMS registration may result in a competitive advantage for organizations that have achieved
it.

•An organization may pursue registration as a means to demonstrate to its shareholders that
its EMS conforms to the requirements in an international EMS standard.
•Organizations that are striving for good community relations may use registration as a
vehicle to improve or maintain their public image.
•Some lenders and insurers have indicated that organizations that have obtained EMS
registration may be given preferential treatment because they are perceived to be a lower
risk.

•Regulators, both at the state and federal level, have indicated that they may provide
incentives, in the future, for organizations that successfully implement an effective EMS.
•Regulatory agencies are currently evaluating the effectiveness of EMS
implementation but have not committed to what types of regulatory incentives
may be available.
•Examples of regulatory incentives could include streamlined permitting processes
and reduced fines.
•Organizations that provide goods or services to government agencies may be
granted preferred supplier status if they implement an effective EMS.
•Should Your Organization Pursue EMS Registration ? Consider:
•Strategic goals
•Customers
•Competitors
•Shareholders
•Local community
•Lenders/Insurers
•Regulatory agencies

•An organization evaluating whether or not registration is an appropriate goal

should consider the following questions:
The Organization
1) What is your organization’s motivation for implementing ISO 14001?
2) Is your organization’s senior management committed to ISO 14001 implementation?
3) How does environmental management fit into your organization s operating and strategic
goals?
Customers
4) Have your customers indicated that they will require ISO 14001 registration?
5) Do your customers give preferential treatment to environmentally responsible suppliers?
6) Does your organization sell its products or services internationally (particularly in Europe
or Japan)?
7) Are your competitors pursuing ISO 14001 registration?
Shareholders
8) Are your shareholders concerned about your environmental management practices?
9) Have your shareholders considered using your proactive environmental practices as a
marketing tool?
Local Community
10) Has your local community raised concerns about your environmental practices?
11) Has your organization been looking for a means to demonstrate your proactive
environmental management practices to your local community?
Lenders/Insurers
12) Will your lenders or insurers offer your organization better rates if it has a registered
EMS?
Regulatory Agencies
13) Are your organization s activities highly regulated? (Would any potential regulatory relief
provide motivation for registration?)

•The benefits of EMS registration may vary significantly among organizations.

•In addition, the costs associated with the registration process will vary significantly among
organizations, depending on the size of the organization and the number of
facilities/divisions they choose to register.
•A cost-benefit analysis may help your organization to weigh the costs associated with EMS
registration with the benefits your organization can expect to achieve.
•Your organization should determine if registration will add value to your business.
Choosing a Registrar
•If your organization chooses to pursue EMS registration, you may want to consider the
following factors when choosing a registrar:
1) Are they accredited? Major accreditation bodies include: the American National Standards
Institute (ANSI); the Registrar Accreditation Board (RAB); and the Raad voor Accreditatie
(RvA) (the Dutch Council for Accreditation).
2) How many years have they been in business?
3) Do they provide registration services for quality management systems (ISO 9000)? (May be
helpful if your organization is pursuing registration to both ISO 9000 and ISO 14001.)
4) What is the experience base of the auditors? Do they have experience in quality
management systems and environmental management? Do they have experience in your
particular industry?
5) How many clients do they have? Can they provide you with a list of customers/references?
6) Are they accredited in your Standard Industrial Classification (SIC) Code?
7) Do they have experience working with small and medium-sized organizations?
8) Are they geographically convenient to your operations?
Can they provide you with a lead auditor who is located close to your organization?
(Geographic proximity can reduce travel expenses.)
9) Is registration continuous or does it expire? (Is a full registration audit required again after
a period of time?)
10) What are their costs over a four-year period?
 Section 6: Sources of Assistance

• This section describes where your organization can find additional help.
• There are many free or inexpensive resources available to help your
organization develop and implement an EMS. The following is a description of
some of these resources.
• Federal Government Agencies
• Example: The U.S. Environmental Protection Agency (USEPA) provides
information on a number of topics that can be useful in the development and
implementation of an EMS.
• Some of these resources include: assistance with interpretation of
environmental laws and regulations; information on pollution prevention
technologies; case studies; fact sheets; and hotlines to answer questions about
environmental issues.
• The USEPA’s Office of Compliance has established telecommunications-based
national Compliance Assistance Centers for four specific industry sectors (and is
currently working on two new centers).
•The existing centers include: the National Metal Finishing Resource Center
(NMFRC); Printer’s National Compliance Assistance Center (PNEAC); GreenLink –
the Automotive Compliance Information Assistance Center; and the National
Agriculture Compliance Assistance Center.
•Office of Compliance staff is planning to develop a Chemical Manufacturers’ Center
and Printed Wiring Board Center.
•Example: The Small Business Administration (SBA) provides assistance to small and
medium sized organizations in U.S.
•The SBA can provide information and assistance related to: operation and
management of a business; sources of financial assistance; international trade; as
well as laws and regulations.
State Agencies
•Your state environmental regulatory agency can provide assistance with the
development of an EMS.
•Contact your state environmental agency and inquire about education and
outreach programs for businesses that are developing an EMS. Many state
environmental agencies can also provide publications, pamphlets, and on-line help
related to environmental laws, innovative pollution prevention technologies, waste
reduction, and permitting.
Associations
•Industry trade associations can provide assistance with the development of an
EMS.
•These organizations can provide information on a number of industry-specific
environmental management issues, and can be instrumental in placing you in
contact with other organizations that can share their experience and expertise in
EMS implementation.
•Your local or state chamber of commerce can be helpful in providing information
about legislative and regulatory issues that affect environmental management for
small and medium sized organizations.
•Other services that are commonly offered include handbooks, workshops,
conferences and seminars.
Non-Profit Organizations
•Example: Another resource to consider is the Manufacturing Extension Partnership
(MEP), which is a growing nationwide system of services that provide technical
support to businesses interested in assessing and improving their current
manufacturing processes in U.S.
•The MEP is a partnership of local manufacturing extension centers which typically
involve federal, state, and local governments, educational institutions, and other
sources of information and funding support.
•The MEP can also often provide assistance with quality management,
development of training programs and business systems.
•Example: The Industrial Technology Institute (ITI) is a non-profit organization
dedicated to expanding technology access and technology management among
U.S. manufacturers.
•ITI provides technical assistance to small and medium-sized organizations through
the Michigan Manufacturing Technology Center.
•ITI also has experience with the development of business performance tools and
provides services for energy, environment, and manufacturing assessments; as well
as, QS 9000 and ISO 14000 training and implementation.
Other Companies
•Another recommended source of information and expertise is the companies with
which you do business.
•It is likely that your suppliers and customers have experience with many of the
aspects of an EMS, and are willing to share their experiences and provide advice to
your organization.
On-line Resources
•There is a wealth of information related to EMS implementation available
electronically via the Internet.
•Many state, federal, and local agencies have home pages on the Internet
containing information that can be useful to your organization.
•Numerous non-governmental organizations have home pages that contain
information on topics such as ISO 14000, pollution prevention, recycling and waste
minimization, environmental laws and regulations, innovative manufacturing
technologies, and materials substitution. If your organization does not have
Internet access, contact your local library to see if it provides Internet access to its
users.
 Background on EMS Standards

The Development of ISO 14000

• The International Organization for Standardization (ISO) is responsible
for the development of the ISO 14000 series of international
environmental management standards.
• ISO was founded in 1946 and its headquarters is located in Geneva,
Switzerland.
• ISO has developed international voluntary consensus standards for
manufacturing, communication, trade, and management systems.
• Its mission is to promote international trade by harmonizing standards.
• Over 100 countries have national standards bodies that are members of
ISO.
• The American National Standards Institute (ANSI) is the U.S.
representative to ISO.
•In June 1991, ISO created the Strategic Advisory Group on the Environment
(SAGE).
•SAGE assessed the need for international environmental management standards
and recommended that ISO move forward with their development.
•In January 1993, ISO created Technical Committee 207 (TC 207) which is charged
with the development of the ISO 14000 series of standards.
•TC 207 is comprised of various subcommittees and working groups.
•Representatives from the ISO member countries contribute their input to TC 207
through national delegations.

•In the United States, the U.S. Technical Advisory Group (U.S. TAG) develops the U.S.
position on the various ISO 14000 standards.
•The U.S. TAG is comprised of approximately 500 members representing industry,
government, not-for-profit organizations, standards organizations, environmental
groups, and other interested stakeholders.
•The U.S. TAG has the largest number of members of any ISO member delegation.
•There are several organizations involved in the administration of the U.S. TAG s
input to TC 207, including: ANSI; the American Society for Testing and Materials
(ASTM); the American Society for Quality Control (ASQC); and NSF International.
•TC 207 is developing the ISO 14001 Standard which specifies requirements for an
environmental management system (the ISO 14001 Standard is the standard to
which an organization’s EMS would be registered).
•In addition to ISO 14001, several guidance documents are also being developed by
TC 207.
•The documents being produced are in various stages of development. ISO 14001,
ISO 14004 (an EMS guidance document), and three environmental auditing
guidelines (ISO 14010, ISO 14011, and ISO 14012), were finalized and published in
September 1996.
•Published ISO standards must be reviewed and revised every five years.
The Emergence of EMS Standards
•Numerous factors have contributed to the emergence of EMS standards.
•The following is a brief overview of some of the major contributing factors.
ISO 9000
•The ISO 9000 series of international quality management standards was published
in 1987.
•The standards were created to promote consistent quality practices and to
facilitate international trade.
•The ISO 9000 series of standards has been adopted by more than 80 countries and
is used as a benchmark for quality management by industry and government bodies
worldwide.
•In some cases, ISO 9000 registration has become a prerequisite for doing business
domestically and internationally.
•In North America, over 13,000 companies are registered to ISO 9000.
•The quality management system framework can serve as a foundation for
environmental management systems.
•In essence, an EMS is the application of quality management system principles to
the management of environmental affairs.
•While the ISO 9000 and ISO 14001 standards have different focuses, they share
similar requirements.
•The three specification documents for ISO 9000 series are ISO 9001, ISO 9002, and
ISO 9003.
•The key difference between ISO 9000 and ISO 14001 is that ISO 14001 requires
planning steps to identify environmental aspects and significant environmental
impacts which become the basis of continual improvement, whereas ISO 9000
focuses on consistency of process.
Sustainable Development
•In 1987, the World Commission on Environment and Development (Brundtland
Commission) coined the term sustainable development in its report entitled Our
Common Future.
•This report emphasized the need to balance environmental protection and
economic growth.
•In 1991, the International Chamber of Commerce (ICC) created the Business
Charter for Sustainable Development.
•The ICC Charter is comprised of sixteen Principles for environmental management
that foster sustainable development.
•The Principles in this document include some of the basic elements of
environmental management systems.
•In 1992, the United Nations Conference on Environment and Development
(UNCED) was held in Rio de Janeiro.
•The conference, also called the Earth Summit (or Rio Summit), resulted in two
noteworthy documents Agenda 21 and the Rio Declaration.
•Agenda 21 is a comprehensive guidance document for sustainable development,
while the Rio Declaration is a set of 27 principles for achieving sustainable
development.
•The international initiatives on sustainable development marked the dawning of a
new age in environmental protection.
•The business community worldwide was asked to consider its impact on the
environment and to take steps to mitigate that impact.
Private Sector Programs & Public Concern for the Environment
•Private sector programs, such as the Chemical Manufacturers Association’s
Responsible Care program, the Global Environmental Management Initiative
(GEMI), and the Coalition for Environmentally Responsible Economies (CERES)
Principles (formerly the Valdez Principles), resulted in model codes of conduct that
encourage environmental stewardship.
•In addition, public concern for the environment has provided strong motivation for the
development of EMS standards.
•National EMS Standards & Regional EMS Legislation
•In 1992, the British Standards Institute published BS 7750, the first national standard for
environmental management systems.
•The British Standards Institute had previously published BS 5750 (a national quality
management system standard) which was a significant contribution to the development of
ISO 9000.
•ISO 14001 was largely based on BS 7750, and the two standards share many similar
requirements.
•The BS 7750 Standard, however, is viewed by many to be more stringent than ISO 14001.
•For example, BS 7750 requires that an organization compile a register of its significant
environmental effects, and a register of all legislative, regulatory, and other policy
requirements.
•In addition, BS 7750 requires an organization to make its environmental objectives publicly
available.
•Following the publication of the United Kingdom s BS 7750, a proliferation of national EMS
standards emerged, including standards from Ireland, France, South Africa, and Spain.
•The various EMS standards did not all share the same requirements, and in some cases the
requirements were contradictory.
•It became clear that in order to facilitate international trade, there would have to be one
international EMS standard that would be accepted around the globe.
•In addition to the national EMS standards, regional EMS legislation was developed.
•The Eco- Management and Audit Scheme (EMAS) was adopted by the European
Union (EU) in 1993.
•EMAS is a regulation that enables industries to voluntarily implement formal
environmental management systems in order to improve their environmental
performance.
•While ISO 14001 and BS 7750 apply to organizations (or parts thereof), EMAS is
restricted to site-specific industrial activities.
•EMAS participants must prepare an environmental statement specific to each site
concerned, and provide information to the public about their environmental
aspects.
•Third-party verification of the EMS is an essential component of EMAS.
•Participating organizations are included on the EU list of participating sites.
 Case Studies

1. MILAN SCREW PRODUCTS

Background
• Milan Screw Products is a small manufacturing firm located in southeastern Michigan
that employs 32 individuals.
• Milan Screw Products manufactures precision fittings for the fluid power, automotive,
and refrigeration industries, and is registered to the ISO 9002 quality management
system Standard.
• There are approximately 1,500 companies in the United States in the screw-machine
products industry.
• Most of these companies are family-owned and family-managed, and typically have
approximately 50 employees.
• While there are generally few hazardous materials used in the screw-machine industry,
there are environmental issues associated with the containment of coolants and cutting
oils, the substitution of chlorinated solvents, and the disposal of waste oils.
• The most persistent environmental challenge is the containment of cutting oil within
production machines.
•Many screw-machine shops have production equipment that was manufactured
in the 1950s, which may have leaky gearbox covers and inadequate oil splash
guards.
•The cutting oils also create cleaning and disposal issues (e.g., stained carpets;
waste bins filled with saturated oil absorbents swept from the shop floor; and
liquid wastes from the solvents and soaps used in cleaning).
•While many shops have simply accepted the oily film that soon coats everything
from the light fixtures to the floors, Milan Screw Products decided that it was going
to improve the management of its environmental issues.
•Top management recognized that a clear environmental policy, objectives and
targets, written procedures, training, and corrective action (elements similar to its
quality management system), would help them to proactively manage their
environmental practices.
•The motivation to implement an EMS was derived from the company’s desire to
improve its environmental performance, and in light of the company’s quality
management system experience, the EMS approach seemed to be the best way to
achieve it.
•Milan Screw Products was soon committed to implementing an environmental
management system.
EMS Implementation
•One of the first steps in the implementation of the EMS at Milan Screw Products
was the establishment of a cross-functional environmental task group.
•Top management appointed five representatives from production, support, and
management.
•The environmental task group is responsible for assuring continued regulatory
compliance (including the submission of all permits/forms to federal, state, and
county environmental agencies), and improving the company’s environmental
performance.
•Milan Screw Products found that participation of shop-floor employees is essential
to the successful implementation of an EMS because it encourages their ownership
of the process.
•Top management was pleased with the heightened environmental awareness
among task group members and their growing understanding of the company’s
environmental responsibilities.
•In addition, environmental compliance activities were soon effectively managed by
the environmental task group and would only require top management review.
•While progress had been made, the organization was lacking a structure for its
EMS program and had no means to measure progress.
•In March 1995, Milan Screw Products joined the EPA-sponsored EMS
Demonstration Project at NSF International.
•One of the first steps in the project was the self-assessment process.
•Milan Screw Products completed NSF’s EMS Self- Assessment Tool, which is a
checklist that enables an organization to determine how its EMS measures up
against an EMS standard, such as ISO 14001.
•Milan Screw Products’ score was very low because they did not have a formal EMS
in place.
•The score did not discourage Milan Screw Products and the company set a goal for
itself — complete EMS implementation by June 1996.
•Policy
•Milan Screw Products developed an environmental policy that includes a
commitment to regulatory compliance, continual improvement, and the prevention
of pollution.
•The environmental policy was modeled after the organization’s quality policy,
which was developed with the help of a consultant.
•Planning
•In order to determine the company’s environmental aspects, the environmental
task group members set up an easel and participated in a brainstorming session.
•The task group listed all of the company’s inputs (e.g. energy, water), outputs (e.g.
oil mist, noise), and conversions (e.g. steel bars to chips, and cutting oils to mist).
•The task group examined the company’s purchases, processes, and waste streams.
•The task group also identified the company’s stakeholders.
•Some of the stakeholders were interviewed so that the company could gain a
better understanding of their environmental concerns.
•These stakeholder concerns were added to the list of environmental aspects.
•A neighbor reported that their only concern was that oil from the shop could
damage their lawn.
•A supplier’s sales representative reported that the oil on his shoes was a nuisance.
•Customers were pleased to learn that the company was implementing an EMS
because they want to be assured of continued production (fines imposed on a small
company could result in a shut down).
•The task group also interviewed employees and some of their family members.
•All in all, the environmental task group had done an excellent job at identifying
their environmental aspects.
•The task group then rated the probability of an environmental impact occurring
against the severity of the impact.
•They then grouped the environmental aspects/impacts in general categories (e.g.
oil-related problems).
•It soon became clear that the company’s primary objective was oil recovery.
•The top management at Milan Screw Products had been contemplating the need
for a new facility.
•The identification of the company’s environmental aspects/impacts provided
additional motivation for the development of a new facility.
•The environmental aspects/impacts that were identified and the company’s EMS
have played a role in determining how the new facility will be built.
•The company will continue to perform oil recovery practices, but will not set
numerical targets until the new facility is complete.
•Milan Screw Products started its first EMS cycle with reasonable objectives that
focus on its manufacturing practices.
•Over time, the company will continually improve its EMS, and hopes to include
objectives such as the recycling of office paper.
•The environmental task group will continue to be responsible for keeping Milan
Screw Products fully in compliance.
•The company has found that its trade association has been a tremendous help in
keeping them abreast of environmental compliance issues.
•Milan Screw Products intends to develop its environmental management program
at its current facility and will improve the EMS at the new facility.
•The new facility will help the company to achieve its environmental objectives and
targets.
Implementation and Operation
•Milan Screw Products has found that the structure and responsibility requirements
of the ISO 14001 Standard are easier to manage in a small company.
•Milan Screw Products has developed six teams (each composed of individuals with
similar job descriptions) for the quality management system;
the teams have been given more decision-making authority and have been an
effective element of the quality management system.
•These teams will help with environmental issues over time.
•The environmental task group will continue to spearhead the EMS program — the
owner, plant manager, quality manager, safety manager, plant
supervisor/environmental coordinator, and a representative from production staff
are actively involved.
•The key to success in a small company appears to be the team approach, since
there is often no one that can be solely dedicated to managing environmental
affairs.
•Since finding the time to do employee training can be a challenging aspect of
running a small business, Milan Screw Products has scheduled training sessions a
half hour before or after the employees’ normal shift.
•Their best success has been with “brown bag” sessions where the employees bring
their lunches, listen to the training presentation, and remain “on-the-clock” for
their lunch/training period.
•Milan Screw Products has also found that videotaping training sessions can be
helpful for new-hire training.
•The environmental task group has helped with training by gathering training
materials.
•The team approach that has been developed at Milan Screw Products has been an
effective means of fostering good internal communication procedures.
•In addition, Milan Screw Products has gone beyond the requirements of the ISO
14001 Standard by soliciting the opinions of external interested parties.
•The company has found that a good external communication program has
resulted in a lot of benefits because it builds trust.
•The company has been straightforward with its community about potential oil
problems, and the community has been very supportive of their efforts and of
their plans for a new facility.
•The external communication program helped them identify some of their
environmental aspects, and has helped them to communicate with their
customers.
•Milan Screw Products’ customers appreciate that it is an environmentally
responsible company that is a leader in its industry.
•Since Milan Screw Products has a registered quality management system, they
have a sound document control program in place. As mentioned previously, a
quality management system consultant helped the company with their ISO 9002
implementation, and the document control procedures for quality will be adapted
where applicable for the EMS.
•Milan Screw Products is still in the process of establishing its EMS documentation.
•As part of their brainstorming session, the environmental task group also listed
potential emergencies.
•The company used this information when it reviewed its emergency preparedness
and response procedures.
•The EMS implementation process helped the company to consider possible areas
of liability that it had previously overlooked (e.g. a delivery truck leak).
Checking and Corrective Action
•Milan Screw Products has made some preliminary calculations of some of its
environmental aspects.
•The new facility will facilitate the quantification of its environmental aspects and
impacts.
•The company intends to build on its quality management system corrective and
preventive action procedures to help them develop their EMS.
•In addition, the company intends to utilize some of the lessons it has learned
about data collection and monitoring and measurement through its quality
operating system and will apply these lessons to the EMS over time.
•Milan Screw Products has gained experience with management system audits
through its quality management system implementation.
•Top management has performed quality management system audits with the help
of an auditor training guide that their quality management system consultant
developed for their organization.
•The company has done in-house auditor training with the help of the guide and
has used the auditor training guide for its EMS audits where applicable.
•Top management and the plant supervisor/environmental coordinator have
performed an EMS audit, even though they have not yet fully implemented the ISO
14001 Standard.
Management Review
•Milan Screw Products Management Review Board meets monthly.
•The company also performs an annual review of its operations.
•A third-party (consultant) is used to verify the results of the company’s annual in
house review.
•The EMS is being incorporated in the management review process of the company.
•The Milan Screw Products’ Experience
•While Milan Screw Products has not completely implemented its EMS, it has made
significant progress over 1 ½ years.
•Due to the groundbreaking for the new facility in June 1996, the organization had
to shift its priorities to new construction (it is now hoping to completely implement
its EMS by April 1997).
•Top management at Milan Screw Products stated that organizations that choose to
implement an EMS should not get discouraged if the EMS implementation needs to
be set aside occasionally.
•You can start, stop, and resume your efforts as needed — your aspects won’t
change unless you change your processes or products — and any progress that you
have made will still be there.
•Milan Screw Products’ top management believes that there are numerous
potential benefits associated with a successful EMS.
•Specifically, the company determined that an EMS could improve employee
retention, new hire selection, working conditions, and the perceptions of its
suppliers, lenders, customers, neighbors, and regulators.
•The EMS will also ease management concerns that an environmental problem
could arise from simple ignorance or lack of training.
•The company’s top management has stated that it may be difficult to perform a
cost/benefit analysis on the value of EMS implementation because several of the
potential benefits are intangible and cannot be given a monetary value.
•Milan Screw Products’ proactive environmental program has improved its stature
and fostered communication with regulatory agencies.
•Top management also believes that the company will benefit from being one of
the first in their industry to successfully implement an EMS — it may encourage
their customers to perceive the company as being more innovative, more
responsible, and more desirable than their competitors.
•Top management has reported that it is impossible to tally citations that are not
written, fines that are not levied, nor lawsuits that are not filed.
•Milan Screw Products’ top management has also stated that many of the benefits
of an EMS cannot be anticipated beforehand, and that an organization will discover
them as pleasant surprises at some point after implementation.
•To date, the biggest challenge that Milan Screw Products has encountered while
implementing an EMS has been allocating the human resources to the EMS project
while production demands are high.
•The company has also had to overcome old practices by explaining the rationale
behind its desire to successfully implement an EMS.
•Milan Screw Products has not calculated the costs of EMS implementation to date.
•Top management reports that it is difficult to attribute costs/benefits at this stage
of EMS implementation, particularly since the company is in a transition phase due
to the new construction.
•While it is too early to quantify costs and benefits, top management is confident
that the benefits will outweigh the costs — early projections of their oil recovery
savings at the new facility are estimated to be $20,000 per year.
•Milan Screw Products will integrate its ISO 9002 quality management system with
its ISO 14001 EMS.
•The company is developing one manual that will incorporate both quality and
environmental management system elements. For example, the organization has a
quality policy on white paper and its environmental policy on blue paper on facing
pages.
•The documents also refer to one another where appropriate.
•The document control programs for both systems will be fully integrated as well.
•In addition, the audit function will be integrated once auditor training for the EMS
is complete.
•Top management at Milan Screw Products has not determined if the company will
pursue EMS registration in the future.
•Top management has stated that it will depend on factors such as costs and
customer demand.
•The company intends to completely implement its EMS and will evaluate the need
for registration next year.
•Top management has stated that obtaining EMS registration would be a great
satisfaction and it may improve their customers’ perception of the company, but it
has not determined whether or not it can justify the costs.
•Milan Screw Products encourages other small companies to implement an EMS
because it believes that small companies may not have sufficient resources to
mitigate environmental problems.
•An EMS can help a small or medium-sized organization prevent environmental
problems which may keep a small company in business.
•Top management at Milan Screw Products has stated that an EMS enables an
organization to look at its business from another perspective.
•Organizations have considered quality, safety, etc., as integral parts of their business and
should look at their business from the environmental perspective as well.
•All of the various perspectives result in greater opportunities for improving the organization
as a whole.
2. HACH COMPANY
Background
•Hach Company is an international manufacturer and distributor of instruments and
reagents for colorimetric testing, with annual sales over $100 million.
•Hach Company manufactures spectrophotometers, colorimeters, turbid meters,
and portable testing equipment for the water and wastewater markets.
•The company manufactures instruments at its headquarters in Loveland, Colorado,
and has a chemical manufacturing and distribution plant in Ames, Iowa.
•The Hach Company is registered to ISO 9001 and is a member of the Chemical
Manufacturers Association’s Responsible Care® program.

•Hach Company participated in the EPA-sponsored EMS Demonstration Project at

NSF International, and decided to pilot EMS implementation at its Ames facility.
•The Ames facility has approximately 300 employees and faces environmental
management challenges due to its many chemical production processes.
•The Ames facility is the only Hach facility that is currently participating in the
CMA’s Responsible Care® program.
•Hach Company decided to implement an EMS at its Ames facility for several
reasons.
•The company felt that a sound EMS would:
1) provide assurance to the officers, board of directors, and company stockholders
that the company will continue to meet regulatory compliance requirements and is
prepared to handle other environmental issues; 2) provide a framework to maintain
support and resources from senior management to meet environmental objectives
and targets; 3) help create market opportunities for the organization; 4) be a
mechanism to gauge environmental performance; and 5) help the company identify
its responsibilities beyond compliance in order to meet the needs of stockholders,
employees, neighbors, customers, vendors, and suppliers.
EMS Implementation
•In order to examine the Ames facility’s environmental strengths and weaknesses,
the facility’s Quality Director performed an initial self-assessment of the EMS.
•The Quality Director reviewed the EMS standard and interviewed the
environmental safety and health staff at length.
•The Quality Director determined that the facility’s EMS complied with
approximately 30 percent of the EMS standard, which was consistent with the
expectations of the Environmental, Safety and Health (ESH) staff at this early stage
of EMS implementation.
•This process provided the ESH staff with a benchmark from which they could
measure progress as they continued to improve the facility’s EMS.
Policy
•Hach Company had previously developed an environmental policy but added
additional policies to completely fulfill the CMA’s Responsible Care® Program’s
objectives, and the policy requirements of the EMS. Hach Company has issued its
Corporate Environmental and Safety Policies which address continuous
improvement, periodic assessments, product stewardship, regulatory compliance,
operations, facilities, and employee health and safety.
•In addition, the President of Hach Company has issued The President’s
Commitment, which expresses top management’s commitment to environmental
stewardship and safety for employees and customers.
Planning
•In order to determine the Ames facility’s environmental aspects, the environmental
safety and health department reviewed the table of contents of their new ESH
manual.
•The table of contents helped them to develop an informal environmental effects
register and a safety register.
•The group then examined how environmental regulations affect their company; they
examined federal requirements (e.g. Clean Water Act, Safe Drinking Water Act, Clean
Air Act, etc.), in addition to state and local environmental regulations.
•The ESH staff proceeded to explore the facility’s environmental aspects and resulting
impacts beyond those addressed by environmental regulations.
•They always strive to do the right thing — even if it is not required by law.
•The group developed a three to four page document that focused on the facility’s
operations and processes and less on aspects such as energy use.
•The group developed their environmental effects register to help them set
objectives and targets.
•The ESH staff is taking a systematic approach to setting objectives and targets.
•While the EMS is still being developed, the objectives are focused at maintaining
compliance and tackling issues that had previously been unresolved, such as waste
disposal costs.
•One particularly important environmental issue for the company is determining
the impact that the company’s chemical products have on its international
customers (35% of the company’s products are sold internationally).
•These impacts will also be considered when setting objectives and targets.
•The ESH staff have access to copies of federal and state regulations, manuals,
journals, online resources, and software packages that help them to keep abreast of
all pertinent environmental regulations and statutory requirements.
•While the company is very good at maintaining regulatory compliance, the
procedures that they have developed for their legal and other requirements have
helped to make their compliance activities more focused and efficient.
•The procedures that they follow to ensure compliance are properly documented
and will protect the company in the event of employee turnover.
•The ESH staff at the Ames facility is developing extensive written procedures to
address their compliance activities that are above and beyond those required by
the ISO 14001 Standard.
•Hach Company has staff members that are dedicated to managing the company’s
environmental, health, and safety issues; hence, the company rarely uses outside
consultants.
•The environmental management program at the Ames facility is well positioned to
meet its environmental objectives and targets.
Implementation and Operation
•The ESH staff at the Ames facility believes that the structure and responsibility
requirements of an EMS are easier to achieve in a medium-sized organization than
in a large one.
•The staff at the Ames facility has been given the autonomy to implement an EMS
at their facility without extensive corporate supervision.
•This has made the process easier because the lines of communication are shorter
and the EMS can be focused on the operations of one facility.
•The Ames facility has an excellent training program due in part to the commitment
of resources in this area (the facility has a full-time ESH training coordinator).
•Implementing the EMS has helped with the facility’s ESH training by helping to
define training objectives.
•The ESH staff is also developing procedures for all ESH training curricula.
•The documented procedures will describe the goals and objectives of training and
establish a curriculum for applicable programs.

•Internal communication within the Ames facility has improved due to EMS
implementation.
•The ESH staff are working with members of the operations, design, and purchasing
departments so that the groups can work together to set reasonable objectives and
targets that complement the goals set by other departments within the
organization.
•Environmental issues are becoming an integral part of the business.
•The Ames facility is still in the process of completing its EMS documentation.
•The ESH staff started to develop an ESH manual in September 1995.
•The group was hoping to have the manual completed in one year; they now expect
to complete it by May 1997.
•The ESH manual that is being developed by the Ames facility staff is somewhat
unique in that it must be able to accommodate the extreme diversity of their
operations — the manual must address over 6,500 chemicals (the Chemical
Hygiene Program alone is described in approximately 90 pages).
•The ESH staff at the facility includes two college students that are working at the
facility as temporary employees to develop some of the documentation (i.e.
procedures) necessary for a successful EMS.
•The students have been very helpful — they ask a lot of questions and explain the
procedures clearly and without jargon.
•The ESH staff has also run some mock-drills or table-top exercises of its
procedures.
•Because Hach Company is registered to ISO 9001, the ESH staff has been able to
learn valuable lessons from the quality management system staff, including
information about document control practices.
•As the ESH staff began implementing their EMS, they discovered that they were
not as good at document control as they had previously believed.
•The ESH staff has indicated that a sound document control system is crucial to a
successful EMS — without it, sooner or later someone will be working from an old
version of a procedure.
•The ESH staff has not used any software packages to revise their document control
system; the system is managed electronically by a top ESH staff member.
Checking and Corrective Action
•As mentioned previously, the ESH staff at the Ames facility are developing
extensive written procedures to address their compliance activities including those
that pertain to monitoring and measuring activities.
•These procedures will be included in the ESH manual.
•The ESH staff has the opportunity to build upon the facility’s quality management
system corrective and preventive action procedures to help them develop and
successfully implement their EMS.
•After the initial self-assessment audit which was performed by the Quality Director,
the ESH staff performed an informal interim audit.
•The Quality Director performed a second formal audit of the EMS after one year of
implementation.
•The ESH staff was pleased with the audit process because the quality management
system staff had extensive experience with auditing management systems.
•The Quality Department acted as an independent party and performed a very
thorough audit.
•The Quality Department has stressed that the ESH staff must document how they
do things.
•There were times when the EMS element was in place but needed to be
documented.
Management Review
•The management review requirements in the ISO 14001 Standard have not been
implemented at the Ames facility.
•The ESH staff members at the facility do not intend to fulfill the requirements of
the management review section of the standard unless they decide to pursue EMS
registration.
•They do not believe that the management review process adds value to the EMS
until registration is sought. Hach Company believes that all other elements of an
EMS can be implemented without management review.
The Hach Company Experience
•The initial assessment of the Ames facility’s EMS showed that the EMS complied
with approximately 30 percent of the EMS Standard.
•After six months of fairly dedicated implementation efforts, the ESH staff
successfully implemented approximately 58 percent of the Standard, and after one
year of implementation they have successfully implemented approximately 71
percent of the ISO 14001 Standard.
•During this time, the ESH staff’s primary goal was to continue to ensure regulatory
compliance.
•EMS implementation efforts were carried out whenever time permitted.
•Hach Company believes that there are numerous potential benefits associated
with the successful implementation of an EMS (e.g. assurances to stakeholders; a
framework to maintain support and resources from senior management; market
opportunities; a mechanism to gauge environmental performance and to identify
responsibilities beyond compliance).
•During the EMS implementation process, the Ames facility started to observe
improvements in its environmental performance.
•Waste disposal costs dropped 70 percent in one year.
•The EMS was a contributing factor to the cost reduction, along with the company’s
quality focus and continuous improvement efforts.
•Since the EMS has not been completely implemented and the system is relatively
new, the benefits have been hard to quantify, but they are there.
•The EMS program helped to spearhead a major renovation program within the
facility for safety and environmental improvements.
•Employees have started to ask questions and are carefully following procedures.
•In addition, the ESH Department is getting additional respect from other business
units.
•The ESH staff will continue to ensure compliance and they are working closely with
plant managers to minimize the impact of compliance activities on production.
•The ESH staff is now in the position to discuss why they want to go beyond
compliance and what the business reasons are for doing so.
•One of the challenges that the ESH staff at the Ames facility experienced as they
implemented the EMS, was the difficulty they had driving the EMS down through
the organization and up through the management.
•The ESH function is often viewed as a separate entity in many organizations and
not an integral part of the business.
•This perception was initially a barrier to EMS implementation. ESH is now viewed
as a more integral part of the operation.
•The implementation of the EMS and its associated costs can be difficult to quantify.
•The ESH staff does not intend to complete a comprehensive analysis of EMS
implementation costs unless the organization chooses to further explore EMS
registration.
•To date, the most significant costs are due to personnel expenditures and office
supplies.
•The ESH staff at the Ames facility has estimated that if the facility had to start from
scratch, EMS implementation over a two-year period would cost approximately
$20,000 - $30,000 per year.
•Hach Company estimates that a company must be willing to commit at least one
person-year to implementation of an EMS.
•The ESH staff cautioned that some of the costs of implementation can be hidden,
but must be accounted for (e.g., indirect labor, training, etc.).
•The Ames facility spent approximately $5,000 on supplies and printing costs for
EMS implementation.
•The ESH staff reported that initially the costs of EMS implementation can outweigh
the benefits, but an EMS can help prevent an environmental problem and
strengthen an organization’s commitment to be a good corporate citizen.
•Currently, there are no plans to integrate the ISO 14001-based EMS and ISO 9001
programs at the Ames facility.
•The quality management system staff has suggested that operating parallel
systems is the best approach for both the ESH and quality departments at this time.
•The quality management system was adapted from existing procedures and could
possibly be more efficient; the EMS has the opportunity to start from scratch and
may be able to develop elements that are more effective and more appropriate for
ESH issues.
•In addition, the quality management system staff are hesitant about fully
integrating an “immature” EMS into their quality management system in the event
that it might jeopardize the company’s ISO 9001 registration status.
•In the event that the company chooses to pursue EMS registration, the issue of
integration will be revisited, because integration could result in synergy and cost
savings for both programs.
•Hach Company has not determined if it will pursue EMS registration.
•The company will “wait and see” if market forces, particularly demands from their
international customers, and potential regulatory incentives will provide sufficient
benefits to offset the costs of registration.
•The ESH staff may not attempt to comply with the remaining 20 - 25 percent of the
ISO 14001 Standard unless the company decides to pursue EMS registration.
•In the event that the company decides to pursue EMS registration, the ESH staff is
confident that it will be easy to put the remaining elements in place, given sufficient
notice, time, and planning.
•While questions remain about the value of EMS registration, Hach Company has
been able to make some conclusions about EMS implementation at its Ames facility.
•There were concerns initially about the EMS fitting within the company’s culture,
but the ESH staff is pleased to report that the EMS has helped to bring about a
positive culture change within the organization.
•The EMS approach agrees with the company’s audit policies and procedures,
because it fosters a systematic approach that lends itself to reevaluation.
•In addition, the process of evaluating the strengths and weaknesses of the facility’s
EMS has identified opportunities for improvement.
•Hach Company believes that it has benefited from assessing and improving the
EMS at its Ames facility.