KEY ELEMENTS OF AN EMS
1.1 EMS Scope
Every organization has its own goals that stem from the vision
and aspirations of its founders and leaders. These may
span the gamut from client service to social service to
national defense goals. The possibilities can be virtually
limitless. An EMS takes this as a fact, as a pre-existing
condition from which the awareness and desire to be environmentally
responsible emerge. That desire itself becomes an organizational
goal when it is transformed into a commitment. This commitment
must be specifically expressed in a written environmental
policy when the organization decides to implement an EMS.
1.2 Environmental Policy
The Environmental Policy verbalizes the organization’s commitment to be environmentally responsible. The content of the environmental policy describes the organization's aspirations, evoking the degree of commitment by top management and serving as a beacon to influence the behavior and actions of all members of the organization to high achievement for environmental protection.
1.3 Planning
EMS planning activities determine the environmental aspects and impacts of the work conducted at the ESC. Environmental management programs (EMPs) are designed to control and reduce, where possible, the impacts associated with the identified aspects.
1.3.1 Environmental Aspects
The organization’s interactions with the environment
are its environmental aspects. These interactions are identified
by reviewing all the activities, products and services of
the organization and assessing the possibility of each of
them to have an environmental impact. It is important to
recognize that these impacts may be positive or negative
and that the organization should set objectives to increase
positive impacts and reduce negative impacts. The organization
can then develop programs to manage the environmental aspects
they believe are significant either to the environment or
to the organization.
1.3.2 Legal and Other Requirements
An EMS recognizes that certain environmental aspects are
significant for an organization because they impinge upon
certain legal or other requirements, which can affect the
organization’s ability to carry out its mission.
These may include federal and state requirements, industry
standards, or organizational standards. The organizations
must establish a procedure to identify these requirements.
In most cases it is prudent for all environmental aspects
with legal implications to be designated as significant.
1.3.3 Objectives and Targets
Generally objectives and targets are established to address
each of the organization’s significant environmental
aspects and are integrated at all levels and functions
of the entity. Objectives and targets are set by considering,
in part, the legal and other requirements, the views of
interested parties, as well as, technological, financial
and other operational considerations. This ensures that
objectives and targets are robust, that they respond to
legitimate concerns, that they are realistic for the organization,
and that it is possible to develop strong management programs
to achieve them.
1.3.4 Environmental Management Programs (EMPs)
Environmental Management Programs serve to achieve the organization’s
objectives and targets, and are therefore linked directly
to them. EMPs contain details on the resources (e.g., financial,
human, and technological) and timeframes to accomplish the
objectives and targets. They also contain information describing
the approaches and strategies for achieving objectives and
targets, as well as the performance indicators, the operational
controls, the roles and responsibilities to accomplish tasks,
and the competency of individuals to accomplish those tasks.
The EMP ties many elements of the EMS together (e.g., significant
aspects, objectives and targets, resources, responsibilities,
and capabilities) and provides an integrated view of the
disparate requirements in the EMS.
1.4 Implementation and Operation
1.4.1 Roles, Authorities and Responsibilities
Roles and responsibilities for activities under the EMS must
be clearly defined and as stated above, many of these appear
in the EMPs. While an EMS is largely sustained by the voluntary
participation and commitment of members of the organization,
certain duties are assigned with clear roles and responsibilities
and with attendant accountability for performance and results.
For example, top management must appoint a management representative
to be responsible for leading the creation, implementation,
and maintenance of the EMS. Other roles are assigned to
members at various levels and functions throughout the
organization where significant environmental aspects are
present.
1.4.2 Training, Awareness, and Competence
An EMS requires two types of training: general awareness,
and competence training. General awareness training for all
employees focuses on the importance of the environmental
policy, the role of employees, and the potential consequences
of failing to provide environmental care. Competence training
is prescribed for members that work in proximity to significant
environmental aspects and focuses on the possible significant
impacts of those aspects, their specific roles and responsibilities,
the objectives and targets for those aspects, and the operational
controls in place to avert the actualization of the potential
impacts. Competence training is detailed in the EMPs and
in the documentation of operational controls. The EMS Coordinator
ensures that both types of training are conducted as appropriate
to satisfy these requirements.
1.4.3 Communication
Clearly, effective integrated environmental management demands
effective communications to coordinate staff internally
and to liaise with external stakeholders. Maintaining employee
awareness of EMS initiatives, motivating them, and supplying
them with knowledge of their roles and responsibilities
all require communication. It is also true that communication
is a two-way process; that employees can make recommendations
to management and give their views when necessary.
One must remember that views of interested parties should be considered in the EMS. This means that there must be effective two-way communication between external stakeholders and the facility. Interested parties should be able to communicate their views to the facility, and the facility should be able to respond to these parties.
1.4.4 EMS Documentation
It is important that the organization maintain information
that would allow someone with a legitimate interest in
the EMS to understand how it is designed and implemented.
This information is essential for employees who need to
know about an EMS issue, as well as for external parties
such as customers, regulators, registrars and other interested
parties. In many cases the EMS Manual will fulfill this
documentation requirement. However it is likely that some
documents will be maintained outside the EMS Manual in
which case they must be referenced in the Manual.
1.4.5 Document Control
Due to the wide variety of documents used in the EMS it is
essential that a formal approach be developed to control
and organize them. This document control procedure must
ensure that the documents being used are the most up-to-date
versions. This includes removing obsolete documents from
circulation.
1.4.6 Operational Control
It is important to control those actives, products or services
that might cause a deviation from the organization’s
environmental policy or result in significant impacts.
These controls are designed to support the achievement
of EMS objectives and targets. An operational control is
a specified engineering or administrative measure implemented
to reduce the risk that an impact will occur. Operational
controls are included as integral components of the EMPs.
Because of their volume, they may be physically separated
from the EMP but must be referenced in such instances with
a pointer in the EMP.
1.4.7 Emergency Preparedness and Response
The EMS provides a systematic method to manage known and
expected elements of the organization’s operations.
However, despite best efforts there is the possibility
of unpredictable accidents and emergencies. Those that
are predictable should have been addressed in the EMS through
the EMPs and the operational controls. The organization’s
emergency preparedness and response plan provides for the
unexpected. From the perspective of the EMS, it is necessary
that measures be included in this plan to address the environmental
consequences of such occurrences. It is expected that such
measures work to control and mitigate those possible environmental
consequences.
1.5 Checking and Corrective Action
1.5.1 Monitoring and Measurement
Monitoring and measurement is fundamental to the EMS, it
ensures that management plans; controls, and training are
effective. Furthermore, it enables the organization to
identify its progress toward achieving objectives and targets,
and the reasons for its level of achievement. Without effective
monitoring and measurement it is impossible to continually
improve which is the basis of the EMS. Organizations are
required to periodically monitor performance, operational
controls, and general conformance with EMS objectives and
targets.
5.5.2 Nonconformance and Corrective and Preventive Action
When an organization identifies a weakness in the EMS or an ineffective part thereof it needs to initiate and effect a correction. The EMS requires a procedure to receive, document and investigate problems, understand their root causes, and then implement corrective actions that prevent recurrence.
5.5.3 Records
While it is critical to effectively implement and carry out all the various elements of the EMS, it is also important to be able to demonstrate that you have done so. This is done through the creation and management of records of various implementation activities and other EMS results from training, audits and management reviews. These records must be managed so that that they can be easily accessed and retrieved. Importantly, they must be assigned retention dates that specify how long they need to be kept by the organization.
5.5.4 EMS Internal Audits
EMS audits test whether the system has been implemented and maintained as designed. Importantly, they are not compliance audits. The reason to look at compliance data during an EMS audit, for example, is not to test the organization’s regulatory posture, but rather to test whether the programs (EMPs) that have been implemented are actually working as they were intended to work to achieve and maintain compliance. Organizations will also use the EMS internal audits to gauge their status on regulatory compliance.
5.6 Management Review
The EMS reserves a special role for top management, as well
it should. Not only must they formulate and articulate the
environmental commitments of the organization in the environmental
policy, they must also render judgment on whether the EMS
continues to be suitable, adequate and effective. This is
accomplished through the periodic management review that
affords them the opportunity to judge the EMS and its results.
On that basis, they are then expected to make decisions relative
to the EMS so that it continues to perform and deliver as
expected.
Page Last Updated January 12, 2009