In its Compliance-Focused Environmental Management System Enforcement Agreement Guidance, EPA provides twelve elements that should be incorporated into an effective environmental management system. The 12 key elements are summarized below:
1. Environmental Policy – management must be committed to compliance and this commitment must be communicated to all employees.
2. Organization, Personnel and Oversight of EMS – define duties, roles and means of communicating environmental concerns, provide a direct means for concerned employees to reach management without fear of negative consequences.
3. Accountability and Responsibility – specify responsibilities, provide incentives to perform and describe consequences of nonperformance. Nonperformance must be subject to consequences.
4. Environmental Requirements – ensure that applicable requirements are identified and communicated and updated as regulations change.
5. Assessment, Prevention and Control – includes establishing standard operation procedures and management of change.
6. Environmental Incident and Non-compliance Investigations – standard procedures for dealing with incidents to determine causes and prevent recurrence.
7. Environmental Training, Awareness and Competence – must
include documentation of training and periodic updates.
8. Environmental Planning and Organizational Decision Making – includes integration of environmental planning on an annual basis for all corporate decisions.
9. Maintenance of Records and Documentation – should include specification of types of records to be maintained.
10. Pollution Prevention – provides procedures for minimizing waste and emissions.
11. Continuing Program Evaluation and Improvement – includes evaluation of the EMS and periodic audits of facility compliance.
12. Public Involvement/Community Outreach – includes education and environmental awareness.
Each element of an EMS is important, but two of the more important elements are the internal accountability process and the environmental auditing procedures.