Do they have an EMS?

The best way to find out if you or anyone has an EMS is to do an “environmental management audit”.  This is different from the conventional compliance audit where you ask the question: “Is anything wrong here TODAY?” That’s all you can hope for in a  compliance audit. You are trying to find out if the facility is in compliance on the day you perform the audit. It is just a snap shot of the compliance status of the facility. It tells you nothing about what the status will be the next day or next year.

When you do an “environmental management audit”, you are asking this question: “What will they do when something goes wrong tomorrow?” You look at people. You observe how they react to environmental problems. You look at the procedures that they have put in place to plan for emergencies. You ask open-ened questions. You find out how they interact with agencies. All of these questions will help you determine if they have an effective environmental management system.

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3 responses to “Do they have an EMS?

  1. How to Set Up an EMS without the trouble of Certification

    Many companies sign on to ISO 14001 because their customers won’t do business with them without it. If your organization is under no market place reasons to get certified and yet you would still like to have an effective Environmental Management System (EMS), this month’s column offers you several simple practical steps towards this goal.

    Step 1. Get Top Down Support. You need to have someone within your organization who will support the idea of implementing an EMS. This person must be a member of senior management and have access to the Management Board within your organization. Without the support of this individual, your chance of success will be greatly diminished. This person can be a vice president or even the chief financial officer of the organization. In fact, the more involvement this person has with finances the better. Any senior official within the legal department or quality control department would do well too.

    Step 2. Write Down Your Policy. Define a roadmap or vision of how your organization plans to operate within the confines of environmental compliance. Some people call it the Environmental Policy. What you end up calling it is less important than how it ends up driving the performance of your operations. This policy needs to state clearly the steps your organization will take to achieve excellence in environmental performance. Once you have articulated this policy, make sure that all of your employees are made aware of it.

    Step 3. Assign Responsibilities. Look around your organization and see if you can find people who are willing to take on the responsibilities of environmental compliance and also be accountable for the performance. One effective way is to hold plant managers accountable for environmental performance – in much the same way that they are usually held accountable for safety performance. You will find that senior management generally has a much keener awareness or keenness in safety performance – much more so than on environmental issues. This is not necessarily always a reflection of management’s human concern for their workers’ safety although one would like to think so. Very often it is because they see a cost (Workers’ Comp) directly associated with work-related injuries and are thus able to “manage” the cost by putting the necessary resources behind it. There are no comparable and concise monetary yardsticks for environmental compliance. Management often does not see the “costs” of environmental non-compliance until it is too late and therefore does not know how to manage it proactively. Remember that Corporate America manages by the quarters because Wall Street demands quarterly reports.

    Step 4. Train Your People. Make sure the people who are involved in your EMS are qualified. You need to provide them with the necessary training. At a minimal, these folks need to understand the basic requirements of environmental regulations. This is a very important issue given the high turnover rate in personnel. More and more companies are assigning new people environmental responsibilities. You need to make sue these people get the basic training. They do not all have to be environmental experts. But they need to know enough about regulations and various requirements to ask the right questions.

    Step 5. Set Broad Environmental Objectives and Targets. One of the most effective ways to sell your EMS to senior management is to demonstrate realistic objectives (or goals) that will result in real cost savings. For example, you might want to focus on reducing generation of hazardous wastes or toxic air emissions. Both of these activities carry large social and bottom line costs to your organization. Here is a classic example: If you can reduce the amount of hazardous air pollutants in your solvents by getting your supplier to reformulate the products, you can substantially reduce the amount of toxic air emission and hazardous wastes from your operation perhaps to the point of not needing a major permit such as Title V under the Clean Air Act. Many companies have done just that. If you can set this as an objective and have a realistic target date for reducing a fixed amount, you should have no problems in convincing senior management to go along.

    Step 6. Be Helpful. If you are helpful to the operation folks, you will have much better chance of success. You need to develop simple and straight forward sets of procedures in the event of environmental emergencies. For example, develop some simple steps on what the plant is supposed to do it has a chemical spill so that the operations people will know exactly what to do and whom to contact. Avoid legalese and regulatory jargons when you write these procedures. If the instructions are too complicated, people will not follow them. Don’t tell the third shift operator that if there is a spill of chemical exceeding the Reportable Quantity (RQ) in pure chemical form, he will have to report to NRC under EPCRA. All of this is Greek to him. You need to predetermine the amount of a mixture that needs to be spilled before the RQ is exceeded and just write into the procedures that if that predetermined spill amount is exceeded, the operator will need to alert someone with the organization and so on.

    Step 7. Involve People. Try to involve as many of the operational folks as possible in developing any environmental plans such as storm water pollution prevention plan or SPCC. Ownership to these plans is critical to their success. The more the plant personnel are involved, the more ownership they have for the plans and the more likely they are going to do a good job in implementing these plans. After all, do people wash their rental cars before returning them? The answer is no because they don’t own them,

    Step 8. Conduct Periodic Internal Review. Every time you walk through the plant, you are in effect performing an internal “audit” of some sort. When you see something wrong during the walk through, go seek out the person in charge and have a discussion on how to correct the situation. Support the effort by helping your plant in obtaining funding to fix the problems. Document the efforts taken by the plant.

    Step 9. Choose Your Vendors and Consultants Carefully. Be very careful when you choose your consultants and vendors. Remember that your outside consultant represents you before the regulatory agencies. How this person communicates with the regulators on both a professional and personal levels directly affect the agencies’ perception of your organization. If your consultant is antagonistic towards the regulators, you will be the one paying the price in the long run. In choosing vendors for your environmental services, you need to be aware of the long term liability associated with many environmental operations. If your hazardous waste hauler dumps your wastes in a ditch in the middle of the night because the hauler was the lowest bidder of all three quotes you got earlier, you have just incurred a much higher cost and level of liability for your organization.

    Step 10. Learn To Manage Agency Inspections. Chances are excellent that your will have a close encounter with an inspector at one time or another. You need to have a set of internal procedures on what to do before, during and after an inspection. There are many dos and don’ts when it comes to agency inspections. Read the writer’s article in the January 2002 issue of this magazine or you can contact the writer at norman@proactenv.com for a short article on this topic. It is also critical that you know how to manage the outcome of a “bad” inspection. If at all possible, fix any problems that an inspector uncovers before he or she leaves your premise. Always try to resolve any inspection issues at the lowest level within the agency. The higher you go within the regulatory chain of command, the less control you are going to have in the process.

    If you following these ten simple steps, you will have the essence of an effective Environmental Management System.

  2. Is there anyone out there who has sucessfully combined EMS and compliance audits? If so, what approach was taken?

  3. Manfred – welcome to our blog. About your qquestion – it is done all the time. Or I shoudl sya I do that all the time. The best way to do a management audit is when you are doing a complaince audit. For example, when you identify some compliance issues during a complaince audit, you bring that to the attention of the facility and you observe how they react to it. That tells you a lot about the facility’s EMS or lack thereof.

    If they become very defensive and start makign excuses for the violations, that tells you a lot. If they respond to the violations by taking steps immendiately to address them, that tells you a lot about them too. The way they respond answers the question – “Will they be able to handle an environmental issue in the future.”

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