EMS Manual

Section 9— EMS Tutorial

The following paragraphs provide a brief discussion of management system concepts. This is not a description of the USMA at West Point’s EMS, but rather an introduction of general principles and structure that apply to all formal management systems. The model discussed here is based on the international standard, ISO-14001.

9.1. Background

Formal Environmental Management Systems (EMS) emerged in the early 1990s to provide organizations with a proactive, systematic approach for managing the potential environmental consequences of their operations. Such systems have been widely adopted by industry and government and have been effective at improving regulatory compliance and environmental performance.

In April 2000, President Clinton signed Executive Order (E.O.) 13148, “Greening the Government through Leadership in Environmental Management” that established a 5-year EMS implementation goal for all Federal Facilities.

9.1.1 EMS Model

Although several recognized EMS frameworks exist, most are based on the International Organization for Standardization’s ISO-14001 EMS standard. As a result, ISO-14001 is the framework on which organizations most frequently choose to base their EMS, and this has proven to be the case with U.S. federal facilities.

Phase 1:Planning

The organization identifies how its operations might harm the environment, and develops measures to reduce this harm.

Phase 2:Doing

The organization implements the systemic measures to minimize harm across all levels and functions of its operations.

Phase 3:Checking

The organization assesses the effectiveness of the systematic measures for minimizing both the potential harm to the environment and its consequential impacts to mission.

Phase 4:Acting

Based on its assessment of the implemented systemic measures, the organization undertakes actions to make system adjustments and to promote continual improvement.

The findings of Phase 4 may indicate that adjustments to measures already in place are necessary or that entirely new approaches are needed to achieve desired environmental objectives. Output from this phase is fed back into Phase 1 Planning, to make necessary changes and additions designed to bring the EMS to the desired level of effectiveness. This system feedback propels the continual improvement of the EMS.

The EMS continually moves through this cycle, fine-tuning its management of those areas of the organization’s operations that harm the environment. This “continual improvement cycle” is a fundamental characteristic of the EMS; it allows the system to adapt to the dynamic nature of the organization’s operations and to remain relevant and viable for its intended purposes.

9.2. Structure and Key Elements of the EMS

9.2.1. EMS Scope

The organization establishes the scope of its EMS. In general, this includes all activities and operations that the organization has direct control over. At the boundaries, where control passes to other organizations or jurisdictions, the organization needs to establish cooperative agreements for coordinating responsibility for environmental protection. Where the organization has influence (but not control), there is an expectation that the organization exercise its influence to achieve the most desirable environmental outcomes.

9.2.2. Environmental Policy

The environmental policy statement is a declaration of top management’s commitment to the environment, and serves as the foundation for the EMS. Everyone in the organization is expected to be familiar with and understand the policy. The policy is considered when setting EMS objectives and targets, and it is understood that the implementation of the EMS serves to make the commitments in the policy operational. The environmental policy statement is, therefore, a vehicle for communicating the organization’s aspirations for environmental protection as well as a functional tool for establishing the operational boundaries of the EMS. The environmental policy aligns with the organization’s core mission and must include commitments to continual improvement, pollution prevention, and regulatory compliance. The environmental policy statement should reflect a management consensus on its contents and aims, and should be formalized through the signature of top management.

9.2.3. Planning

Planning the EMS involves the development and execution of procedures to identify significant environmental aspects and impacts of the organization’s activities, products and services. It also involves creating the environmental management plans designed to control and reduce, where possible, the impacts associated with these identified environmental aspects.

9.2.3.1. Environmental Aspects

The organization’s interactions with the environment are its environmental aspects. The EMS team identifies these interactions by reviewing all the activities, products and services of the organization and assessing the possibility of each 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’s mission.

9.2.3.2. Legal and Other Requirements

An EMS recognizes that certain environmental aspects are significant for an organization because they are subject to certain legal or other requirements. These may include federal and state requirements, or organizational standards. The organization 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.

9.2.3.3. Objectives and Targets

Generally, objectives and targets are established to address each of the organization’s significant environmental aspects and are integrated at all its levels and functions. 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 and implement effective management programs to achieve them.

9.2.3.4 Environmental Management Plans (Programs)

Environmental Management Plans serve to achieve the organization’s objectives and targets, and are therefore linked directly to them. They 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. Management plans tie many elements of the EMS together (e.g., significant aspects, objectives and targets, resources, responsibilities, and capabilities) and provide an integrated view of the disparate requirements of an EMS.

9.3. Implementation and Operation

9.3.1. Roles, Authorities and Responsibilities

Roles and responsibilities for activities under the EMS must be clearly defined and as stated above, many of these can be incorporated in the management plans. 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.

9.3.2 Training, Awareness, and Competence

An EMS requires two types of training: general awareness, and competence training. General awareness training for employees focuses on the importance of the environmental policy, the role of employees, and the potential consequences of failing to provide environmental protection. Competence training is prescribed for members that work in proximity to significant environmental aspects and focuses on the possible significant impacts of those aspects, the employees’ specific roles and responsibilities, the objectives and targets for those aspects, and the operational controls in place to prevent the impacts. Competence training is detailed in the management plans and in the documentation of the operational controls. The EMS Coordinator ensures that both types of training are conducted as appropriate to satisfy these requirements.

9.3.3. Communication

Clearly, effective integrated environmental management demands effective communications to coordinate staff internally and to communicate with external stakeholders. Maintaining employee awareness of EMS initiatives, motivating them, and supplying them with knowledge of their roles and responsibilities require communication. It is also true that communication is a two-way process; that vehicles exist for employees to make recommendations to management and give their constructive views to improve the system.

One EMS requirement is that views of interested parties should be considered in the EMS. This means that there is a need for effective two-way communication between external stakeholders and the organization. Interested parties should be able to communicate their views to the organization, and the organization should be able to respond to these parties.

9.3.4. 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.

9.3.5. Document Control

Due to th