Department of Commerce

I. What is an Environmental Management System?

An Environmental Management System (EMS) is a framework that allows an organization to consistently address the effects that its operations or processes may have on the environment and to continually improve how its business practices interact with the environment. It is a continual cycle of planning, implementing, reviewing, and improving the processes and actions that an organization undertakes to meet its organizational and environmental goals.

A typical EMS is built on the “Plan, Do, Check, Act” model. This model leads to continual improvement based upon:

Plan - Planning, including identifying environmental aspects and impacts and establishing goals to address those impacts;

Do - Implementing, including training and operational controls to meet established goals;

Check - Checking, including monitoring and corrective action to determine success of implementation; and

Act - Reviewing, including progress reviews and actions to make needed changes to the EMS and return to planning phase.

An EMS is flexible and does not require organizations to necessarily “retool” their existing activities; in fact, it is best to start with what you have in place. Many facilities have active and effective pollution prevention programs and waste minimization activities already underway. These could be incorporated into an overall EMS.

B. Why implement an EMS?

On April 21, 2000, Executive Order 13148, Greening the Government Through Leadership in Environmental Management was signed. Part 4 of this Executive Order, Promoting Environmental Management and Leadership, states, “By December 31, 2005, each agency shall implement an environmental management system at all appropriate agency facilities based on facility size, complexity, and the environmental aspects of facility operations. The facility environmental management system shall include measurable environmental goals, objectives, and targets that are reviewed and updated annually.”

On April 1, 2002, James L. Connaughton, Chairman of the Council on Environmental Quality (CEQ), and Mitchell E. Daniels, Jr., former Director of the Office of Management and Budget (OMB), sent a letter to the heads of all federal agencies emphasizing the importance of developing an EMS as a key tool for meeting the President’s management and stewardship agendas.

According to the Office of the Federal Environmental Executive (OFEE), “The Administration is working to significantly increase the federal government's use of environmental management systems as a planning and implementation tool to help federal agencies better carry out their mission and be better environmental stewards. EMSs will help to better equip agencies with the information, resources, strategy, and feedback they need to ensure they are continuously improving their performance and reducing their environmental impact.”

On April 22, 2003, the Secretary of Commerce issued a memorandum to the Secretarial Officers and Heads of Operating Units outlining the Department’s dedication to the President’s commitment to implement EMSs. In this memorandum the Secretary stated, “The success of our mission requires a commitment to continual improvement in our environmental management performance. The environmental management system is the tool to assist us in meeting this commitment.”

Lastly, the Office of the OFEE, working closely with CEQ, OMB, and the Environmental Protection Agency (EPA), developed several federal EMS scorecards designed to track agency EMS implementation status. Using the information from each agency’s Annual Executive Order 13148 Reports, the OFEE tallies the scorecards for presentation to the members of the President’s Management Council and Agency Environmental Executives.

C. Definitions

Appropriate Facility for Implementing an EMS - In the Department of Commerce, an appropriate facility for implementing an EMS is any property, organization, or operation that conducts activities which can have a significant impact on the environment. An office function, such as the Minority Business Development Agency, located in a building controlled by another organization, would most likely not be an appropriate facility. The following facilities qualify as appropriate facilities:

NOAA - National Marine Fisheries Service, Northwest Science Center, Montlake Lab

NOAA - National Ocean Service, Beaufort Lab

NOAA - Marine and Aviation Operations, Atlantic Marine Operations Center Norfolk

NIST - Gaithersburg Campus

NIST - Boulder Laboratory

Continual Improvement - Continual improvement is a process of enhancing an organization’s environmental performance through a recurring cycle of planning, implementing, reviewing and improving.

Environmental Aspect - An environmental aspect is an element of an organization’s activities, products, and services that can interact with the environment.

Environmental Impact - An environmental impact is any change (complete or partial) to the environment, whether adverse or beneficial, resulting from an organization’s or facility’s functional mission or activities.

Environmental Management System - An environmental management system (EMS) is a component of any organization’s overall management system that takes into account organizational structure, planning, activities, procedures, processes, and resources for developing, implementing, achieving, reviewing, and maintaining environmental programs and policies. It serves as a tool for improving overall performance, both environmental and agency mission. An EMS integrates responsibilities and practices into an overall management system to increase efficiency and reduce environmental impacts. It provides a systematic way of managing an organization’s environmental affairs by:

Identifying and addressing the immediate, cumulative and long-term impacts of missions, services and processes on the environment;

Providing order and consistency to address environmental concerns through the allocation of resources, assignment of responsibility and ongoing evaluation of practices, procedures and processes; and

Relying on the concept of continual improvement for success.

Facility Compliance Audit - A facility compliance audit is a systematic, documented, periodic, and objective review, by regulated entities, of facility operations and practices related to meeting environmental requirements.

ISO 14001 - ISO 14001 is one series of a set of standards established by an international,

non-federation body called the International Organization for Standardization (ISO). ISO 14001 provides a standard for an environmental management system, not legal environmental standards. The standards define the management processes to be followed to control the impact an organization will have on the environment.

D. Discussion about EMS

Top Management Commitment

Applying quality management principles to the environmental area and providing adequate support and resources are the responsibilities of top management. To initiate and sustain the EMS effort, top management must communicate to all employees the importance of:

Making the environment an organizational priority;

Integrating environmental management throughout the organization; and

Identifying problems, determining root causes and preventing problems from recurring.

Focus on Continual Improvement

An effective management system adapts to successes and mistakes. Continual improvement through periodic review and course correction can, with time, minimize environmental impacts and enhance overall performance.

Flexibility

An effective EMS must be dynamic to allow an organization to adapt to quickly changing situations. For this reason, an EMS should be flexible and simple. This also helps make the EMS understandable for the people who must implement it - an organization's managers and employees.

Employee Awareness and Involvement

During the design and implementation of an EMS, an organization will encounter roadblocks. The EMS may be viewed as another bureaucracy or added expense. There also may be resistance to change or fear of new responsibilities. To overcome potential setbacks, it is important to ensure that everyone understands why the organization needs an effective EMS, their role in the EMS, and how the EMS will help control environmental impacts in a cost-effective manner, while providing benefits to the organization’s overall mission. Involving employees in the development of the EMS ensures that the EMS is realistic, practical and adds value.

An EMS provides an opportunity to assess how an organization manages environmental obligations and to find better (and more cost-effective) solutions. By reviewing what the organization does and how well it works, one can ensure that the EMS will be viable and effective, both now and in the future. Analyzing how an organization’s activities and functions interact with the environment will give a clear, concise picture of how each shop, daily activity, or industrial process can have the potential for creating negative environmental aspects and impacts, and how these negative aspects and impacts can be lessened or completely eliminated.

E. Benefits of an EMS

An EMS can provide organizational and environmental benefits. For example, an EMS may help:

Reduce environmental impacts and prevent pollution;

Improve overall environmental performance and enhance compliance;

Increase efficiency and reduce the cost of materials, waste disposal overhead, use of energy, and conserve valuable natural resources;

Improve employee awareness of environmental issues and responsibilities;

Set an example for other organizations/facilities to be environmentally responsible for their actions;

Promote predictability and consistency in managing environmental obligations;

Enable effective targeting of scarce environmental management resources;

Avoid costs associated with cleanups, fines, and violations;

Present a “good neighbor” image to the public, surrounding community, and other

stakeholders; and

Reduce/mitigate risks of environmental incidents through better risk management.

II. EMS Implementation

A. 18-Step Program

An EMS can be informal with minimal documentation. This is a common approach in some small organizations. It can also be formal and fully documented, an approach often taken by large organizations which may have many high-risk issues. Whatever the type of EMS, it should accomplish the core goals of pollution prevention and environmental compliance.

Simply having all 18 elements does not ensure an effective EMS. The way the elements work together systematically and their integration with the non-environmental components of the organization determine the effectiveness of the EMS.

Step 1 - Environmental Policy Statement

Develop a statement of your organization’s/facility’s commitment to environmental excellence. The environmental policy statement should reflect the nature and scale of the organization's activities, and embody the organization's commitment to compliance with laws and applicable requirements, prevention of pollution, and continuous improvement. Use this policy as a framework for planning and action. Where possible, tie EMS goals to the organization’s overall mission and priorities. Obtaining the organization/facility management endorsement on this policy is essential for developing a successful EMS.

Step 2 - Environmental Aspects and Impacts

Identify environmental aspects and impacts of the products, activities, and services. It is useful to review existing planning and budget documents since they reflect an organization's mission, location, activities, and history. Use existing system elements, terminology, and concepts, wherever possible, to save time and resources and allow the EMS to fit more naturally into the organization's culture. Consider the following questions:

Aspects:

How do the organization’s activities interact with the environment?

Do the activities produce waste?

Are hazardous materials involved?

Are operations located in ecologically sensitive areas?

How much water and energy is used?

Impacts:

How are the significant impacts of the organization’s environmental activities currently identified?

What effect would an accident have on the environment?

Can a risk assessment strategy be used to identify the most significant impacts?

Step 3 - Gap Analysis

If needed, conduct a gap analysis to compare an organization’s current program to an accepted EMS framework and determine where gaps exist.

Step 4 - Legal and other requirements

Identify and ensure access to relevant laws and regulations, as well as other requirements to which the organization adheres. Research applicable regulatory requirements to define compliance. Consider the following questions:

How does the organization track laws and regulations relating to its activities?

Is there a list of applicable requirements?

Is a specific person in charge of updating that list?

How are new regulations communicated?

Step 5 - Goals

Establish environmental goals for the organization in line with the policy, environmental impacts, gap analysis, interested parties and other applicable factors. Where possible, align goals with the organization’s mission and priorities.

Step 6 - Environmental Management Program

Plan actions necessary to achieve the goals.

Step 7 - Structure and Responsibility

Establish environmental management roles and responsibilities for personnel in all organizations and facilities and provide appropriate resources.

Step 8 - Training, Awareness and Competence

Ensure employees are trained and capable of carrying out their environmental responsibilities.

Step 9 - Communication

Establish processes for internal and external communications on environmental issues.

Step 10 - EMS Documentation

Develop and maintain information and documents relevant to the organization’s EMS.

Step 11 - Document Control

Ensure effective management and control of the EMS procedures, manuals, and EMS documents.

Step 12 - Operational Control

Identify, plan and manage the EMS operations and activities in line with the organization’s policies and goals.

Step 13 - Emergency Preparedness and Response

Identify potential emergencies and develop procedures for prevention and response.

Step 14 - Monitoring and Measurement

Monitor key activities and track performance. Conduct periodic assessments of compliance with legal requirements.

Step 15 - Nonconformance and Corrective and Preventive Action

Identify and correct problems and prevent their recurrence.

Step 16 - Records

Maintain and manage records of EMS performance.

Step 17 - EMS Audit

Periodically verify that the EMS is operating as intended.

Step 18 - Management Review

Ensure management periodically reviews the EMS, ensuring continual improvement of the system, environmental performance, and the ability to support the organization’s overall mission and priorities.

B. Recommended EMS Criteria

While there are several good EMS models and criteria available in the market place, the Department of Commerce recommends following the criteria of the EPA’s Code of Environmental Management Principles, ISO 14001, or a combination of both to ensure consistency throughout the Department. This Guide generally draws upon the ISO 14001 Standards for describing EMS elements as it is a widely-accepted international standard for an EMS that focuses on continual improvement.

III. Summary

An EMS is a tool and a framework that allows an organization to consistently control the effects its operations or processes may have on the environment and to continually improve its business practices.

An EMS is not just a paper exercise. It demands the commitment of an entire organization. If the environment benefits and performance is enhanced, then stakeholders realize the rewards.

The EMS is centered on and driven by environmental impacts.

The EMS promotes integration of environmental management with organizational functions.

An EMS aids employee awareness of what is required to achieve the organization's environmental goals.

Controlling risks, realizing financial benefits from improved environmental performance and providing visible support is challenging. It requires total commitment from senior management. It requires the active participation of every employee in the organization. Each person must have a clear understanding of the actions he or she must undertake in order to avoid environmental incidents that could have disastrous effects on the organization's finances and reputation.

An EMS effectively focuses attention on the issues of real practical concern to the organization.

IV. Additional References

Other useful guides and information for developing and implementing an EMS: