Paving the Way for Wider Acceptance

• Feb 01, 2002

Introduction

Conformance to the ISO 14001 Environmental Management System (EMS) can attain unprecedented achievements if properly designed through a standardize "systems" approach. While many facilities may maintain a stellar environmental compliance record with federal and state regulators, at times, a measurable, integrated approach to improving environmental performance and business decision-making is needed. As a result, a properly designed EMS program may allocate improvements to an organizations stewardship, environmental protection, financial performance and even individual development throughout its operations.

Many EMS projects have already received distinguished visibility within the government, as well as other public and private-sector organizations. For that reason, beginning with an end in mind is what EMS is working towards to complement sustainable development, stewardship and protection of our resources.

Organizations, which have assisted in pilot projects, are still showing remarkable return on investments, such as the Suburban Maryland Processing and Distribution Center of the U.S. Postal Service. To date, the EMS has provided the framework and infrastructure necessary to build its various environmental programs around one stable structure. Of noteworthy consideration, the EMS protocols were called into play a part in the recent anthrax response at the Washington, DC (Brentwood) Processing & Distribution Center to formulate a strategy directed at emergency response, but also identifying its aspects, legal and other requirements, objectives and targets and management programs.

An EMS, if properly implemented, can be used as a marketing tool to encourage other parts of an organization to implement proactive management systems that are designed to measure environmental performance, to enhance business decision-making and to provide a foundation for continuous improvement. All too often, we implement EMS programs to comply with environmental laws and regulations instead of planning strategies to anticipate environmental issues. However, a standardized EMS will provide the tools to reduce wastes, streamline processes, while maintaining regulatory compliance, which can impact the bottom line in a positive manner.

Many organizations have the tenets of an EMS, but they may not be structured as prescribed within the ISO 14001 standard. All too often, what appears to be an EMS, at times, falls short of its intended mark. While many good intentions initially formulate a strategy, professional facilitation is extremely important during an EMS, in order to provide hands-on guidance to the facility during the EMS implementation process. Of significant importance is evaluating the bottom line, which could include an extensive activity-based costing (ABC) analysis of the EMS associated with the facility's operations. The development of a detailed aspect analysis of operational processes, creation of process flow diagrams for each EMS for each aspect and development of ABC models for each EMS can significantly complement progress. Additionally, flow charts can be used to map and develop each procedure.

Facilitators can be used to leverage oversight knowledge of EMSs when assisting a facility in undertaking the following:
1. Selection of an EMS implementation team.
2. Conducting implementation training.
3. Conducting an ISO 14001 gap analysis of the environmental management program.
4. Conducting awareness training for employees and management.
5. Documenting procedures/leverage from existing procedures.
6. Articulating environmental management programs to address the significant aspects.
7. Formulating in-house EMS audit capability to integrate existing programs.
8. Preparing senior management for an EMS management review process.
9. Providing guidance during the facility's internal EMS audit and management review.
10. Training personnel to conduct an internal audit.

The success of this approach is dependent upon the commitment of management, employees and represented unions, where applicable. By reviewing program performance through performance measurement initiatives, each employee and manager can identify the strengths and areas for improvement of the EMS, which will result in greater focus on continuous improvement of environmental and business performance.

All things considered, employees and management may not initially realize the full scope of environmental issues that they face, such as vehicle use, maintenance activities, equipment operations, energy usage, underground storage tanks, paint emissions and the disposal of wastes. Implementing an integrated EMS can allow facilities to manage these programs more consistently and efficiently. The standard asks the facility to take stock of the environmental aspects of its activities, products and services; to implement a process to keep track of regulatory developments; to prioritize by selecting significant environmental aspects; to set objectives and targets for those aspects; and to implement environmental management programs to accomplish the objectives and targets. The standard also calls for communication procedures, document control, record keeping, management system audits and management reviews by top management. What's more, management can use this structural model to address health and safety issues. ISO 14001 is a standard for change management and has very broad applicability within any organization.

Identification of significant environmental aspects requires the combined efforts of an EMS team in order to create the baseline of significant environmental aspects upon which the EMS is built, despite the fact that, ISO 14001 places much of the responsibility for environmental care in the hands of the employees and not on the environmental professionals. It does this by prescribing key requirements of the system be implemented at "each relevant function and level" of the facility. Under the traditional approach, virtually all of these would have been seen as the responsibility of the environmental professional.

Environmental aspects and impacts should be determined by analyzing all processes and activities, supply chain sanctions in terms of input, output and by-products flow. Through a detailed program assessment, an organization can identify areas where it could immediately improve upon current performance. Some of these areas include:

• Identifying steps to reduce the environmental impact of the use and maintenance of vehicles;
• Increasing the scope of recycling programs, which should result in additional savings to the organization;
• Defining operational, environmental and financial performance measures, so both management and employees can identify program successes and challenges; and
• Using activity-based costing techniques to capture the costs and benefits of implementing and managing the EMS to help promote the benefits of program implementation to other entities within an organization.

On a yearly basis, the environmental professional will repeat certain procedures to ascertain if any new significant environmental aspects have arisen from changes in mission, activities, products, processes or services. Management may increase the frequency of this updating if they deem it necessary to maintain the effectiveness of the EMS.

• Employees in all areas of operations must be asked to help identify environmental aspects.
• Employees will tell the "interviewer" about their environmental aspects, but risk (perception of risk) must be eliminated.
• Even a place that seems not to have potential aspects will likely have many.
• Be very open-minded and ask about all operations and activities.

• Employees already are personally interested in helping to protect the environment.
• Begin communicating with employees early in the process to get them involved and interested. Delays will raise suspicions or lead to sentiment that this is not their system.
• Employees feel a greater sense of ownership and enthusiasm when visual and audio materials are used for the EMS program (e.g., pocket-cards, posters, etc.).

Potential for ImprovementsMost potential for improvement is in things that do not have regulatory requirements:

• Vehicle scheduling and operation;
• Maintenance procedures (de-fueling);
• Equipment operation (hydraulic lifts); and
• Energy and water conservation.

Note: Do not only focus on regulated aspects. Employees may find impacts that are not included in applicable regulations.In-house Champion

• The EMS cannot be imposed from the top management.
• The EMS must emerge from the bottom-up with the help of a proactive champion.
• The champion will need a support team.
• A consultant can create the EMS, but not sustain it.

• Management must have an understanding up-front about the magnitude of change and impact an EMS will have on operations and employees.
• Management must be willing to be visible and to lead through personal example and a display of commitment and will.
• Implementation of an EMS cannot occur if it is seen only as the effort and interest of middle management.

• To track the magnitude of the financial effects, employees need a better understanding of the accounting approaches (e.g., collection of bills, receipts, tracking utility costs, etc.) to be of importance.
• EMS pays off in terms of 1) environmental effects (where pollution prevention and continuous improvements and environmental objectives and targets are explored); and 2) financial effects (where the EMS investment, and the market and cost structure are explored preliminarily).

Benefits to Program Effectiveness

ISO 14001 establishes a framework that relies on process management and the continual improvement of processes. Continual improvement works to ensure that processes do not stagnate - that they remain fresh, vigorous and relevant. Here, again, ISO 14001 offers a system discipline that is equally valuable to the health and safety programs as it is to the environmental ones.

When paving the way for wider acceptance, the application of an integrated EMS can shift an organizations operation from a reactive to proactive style when addressing environmental, health and safety issues designed to manage and monitor performance to enhance business decision-making and provide a foundation for continuous improvement. This voluntary self-regulation approach gives an organization flexibility to address environmental priorities as cost-effectively as possible and provides the organization a strategy to respond to various pressures by setting and monitoring their own environmental codes of practice.

International Organization for Standardization -- www.iso.ch/iso/en/150online.frontpage
U.S. Environmental Protection Agency's Policies Concerning Environmental Management Systems -- www.epa.gov/ems/

This article originally appeared in the 02/01/2002 issue of Environmental Protection.