Planning an EMS

Contents

Selecting an Environmental Task Group
Establishing Objectives and Targets
Prioritizing Projects

Creating an Action Plan and an Action Team
Creating a Prevention and Emergency Plan

Selecting an Environmental Task Group

The responsibilities of the environmental task group include identifying ways for the company to improve its environmental performance, setting objectives and targets and monitoring and evaluating implementation.

The company’s top management is responsible for selecting the environmental task group, which will implement the EMS.It is crucial to obtain the full commitment of top management before starting the process. It is also important to obtain employee support and share environmental values that will transform the EMS from paperwork into an effective process.

The company should explore its in-house expertise in forming the task group, as the following chart suggests.

Position	Function/Task
Top Management	Communicate importance of EMS throughout organization Provide necessary resources Review EMS performance
Middle Management	Support training for new employees
Human Resources	Define competency requirements and job descriptions for various EMS roles Integrate environmental management into reward, discipline and appraisal systems Organize environmental training with environmental task group
Maintenance	Implement preventive maintenance program for equipment
Marketing	Assess market/customer response and demands
Finance	Track data on environmental management costs Prepare budget for environmental management program Evaluate economic feasibility of projects
Engineering	Consider environmental impact of new or modified products and processes/manufacturing/equipment Identify pollution prevention opportunities, excessive use of raw material
Purchasing	Monitor material purchases Acquisition of hazardous material and disposal of waste

The number of people involved will depend on the size of the company and resources available. It is worthwhile involving staff from different departments in the planning and implementation process/task group, since a multidisciplinary approach often proves most successful.

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Establishing Objectives and Targets

One of the most challenging steps in planning an EMS is determining the environmental impacts. The environmental task group will examine the company’s inputs, such as energy and water; its outputs, like solid waste, wastewater, oil mist and noise; and its manufacturing processes such as plating metal. The environmental task group will also examine purchases, processes, and waste streams in order to identify and classify future environmental projects.

The environmental task group’s first duties are to appraise the organization’s operations, services and activities, and to select objectives and targets. This will also help the company to measure the effectiveness of its environmental efforts and improve the performance of the environmental management system.

One environmental goal, may be to minimize the use of a certain chemical. A target is a detailed, quantified requirement that arises from specified objectives. For example, a target might be to reduce the use of chemical X by 25 percent by a specified date.

Considerations in Setting Objectives and Targets

Reducing the company’s impact on the environment.
Comparing current practice with best practice.
Reducing financial costs and liabilities.
Improving the company’s efficiency.
Setting clear, specific objectives and targets.

For help with establishing environmental objectives, use the Questionnaire for Establishing Priorities for Objectives and Targets in Chapter 8 to identify areas for improvement and to set priorities.

Tip Sheet: Determining Environmental Impacts

Identify areas with the greatest effect on the environment and classify them according to their extent of impact.
Involve as many people as possible in the process of identifying environmental impacts. Include top management, production line employees, and staff from different departments, such as environmental, health and safety, product design, engineering, line management, maintenance, procurement, shipping / receiving, or other departments as appropriate.
Consider accessing information from other interested external parties, which can add value to the search. Expand the analysis to include outside activities, such as services at customers’ site. Off-site operations can also have potential environmental impacts.
Consider both normal and abnormal conditions when looking at environmental impacts.
While identifying environmental issues, consider ancillary activities too. Some of the worst pollution comes from support facilities, such as tank farms and wastewater treatment sites.
Remember that the easiest and most cost effective phase to eliminate environmental problems is during early stages of the product and process design. It is also during these stages that products can be modified to reduce waste.
In selecting priorities, consider issues such as cost vs. benefits, availability of appropriate technology and future legislative requirements.
Areas will differ in priority. For example, atmospheric emissions may be more important than land use.
Scheduling brainstorming sessions may be rewarding to gain staff input from different areas.

Tip Sheet: Walk-through Assessment

The assessment team may wish to do a walk-through of the site to observe potential environmental impacts.

Does the facility show signs of poor housekeeping, such as cluttered walkways, unswept floors or uncovered material drums?
Are there noticeable spills, leaking containers, or water dripping or running?
Is there discoloration or corrosion on walks, work surfaces, ceiling and walls, or pipes? This may indicate system leaks or poorly maintained equipment.
Is there smoke, dirt or fumes indicating material losses and air pollution?
Are there odors, or eye, nose or throat irritation upon entering the workplace? These symptoms might indicate system leaks or other problems.
Are there open containers, stacked drums, insufficient shelving for inventory, or other indicators of poor storage procedures?
Are all containers properly labeled as to their contents and hazards?
Is emergency equipment such as fire extinguishers available and visible to ensure rapid response to a fire, spill or other incident?
Is waste such as dripping water, steam or evaporation noticeably being generated from processes in the facility?
Does the inventory include any outdated stock, and are materials that are no longer in use still in storage?
Do employees have any comments about the sources of waste in the facility?
Is there a documented history of spills, leaks, accidents or fires in the facility? If so, which processes were involved?

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Prioritizing Projects

After collecting the pertinent information and establishing environmental management objectives and targets, the company must then prioritize its environmental projects. Frequently, more projects are identified than can be realistically handled at once, due to a lack of personnel or finances. Prioritizing projects will determine what gets done first. This stage requires time and dedication of the environmental task group, and is crucial to the implementation of the EMS.

The following two tables will help prioritize projects. The first table classifies the degree of impact and the period of occurrence, which will help determine priorities for different areas and selecting an appropriate action team. It will also support the assessment review by suggesting a sequence of activities to be monitored. The second table offers a more in-depth analysis that is useful in classifying project priorities.

TABLE 1 - DEGREE OF IMPACT AND PERIOD OF OCCURRENCE

No Risk = N

Low Risk = L

Moderate Risk = M

High Risk = H

	Pre-Production	During Manufacture	Production/ Distribution	Auxiliary Services	Use/ Services	Waste Mgmt.
Energy
Waste
Water
Product Design
Raw Material
Packaging
Water Use/Discharge
Energy Sources/Use
Storage On Site
Emissions/ Discharge
Waste Disposal
Transport and Distribution
Solid and Hazardous Waste Management
Pulp and Paper
Insurance
Site/Building
Law & Regulations

The second table provides a more detailed status of a project in various categories. The objective of both these tables is to assist the environmental task group in identifying problem areas, setting priorities and finding feasible solutions. All relevant environmental impacts should be specified under each category.

TABLE 2 - SIGNIFICANCE OF IMPACTS

No Risk = N

Low Risk = L

Moderate Risk = M

High Risk = H

	Severity of impact	Risk probability of occurrence	Potential legal exposure and legislative requirements	Cost of reducing the impact	Cost benefit $	Effect on the public image
Energy
Waste
Water
Product Design
Raw Material
Packaging
Water Use/Discharge
Energy Sources/Use
Storage On Site
Emissions/Discharge
Waste Disposal
Transport and Distribution
Solid and Hazardous Waste Management
Pulp and Paper
Insurance
Site/Building
Law & Regulations

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Creating an Action Plan and an Action Team

An action team should be assigned for each project. Action teams are staff with the technical and management skills to determine the best ways to make the changes identified in the action plan. Human resources should be allocated according to skills and availability. The company may also consider hiring temporary employees or consultants to develop some of the documentation and to gather information necessary for a successful EMS.

The team approach and employee awareness are key to the successful implementation of an EMS. Since there may not be one employee who can be solely dedicated to managing environmental affairs, the team approach also provides both motivation and joint expertise.

The environmental task group should work closely with each action team, providing information, exchanging ideas and assisting in the implementation of changes. The environmental task group should reduce the need for outside consultants and keep the company moving ahead with its action plan. Additional training for action team members is likely to be required.

The environmental task group will develop an action plan for each project. The purpose of the action plan is to allocate human resources, to establish benchmarks, costs and schedules, outline clearly-defined steps to meet the targets, and monitor progress.

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Creating an Action Plan
An action plan is the foundation of an EMS. It may be thought of as a continuous loop of analyzing and improving, as the following diagram shows:

Once environmental impacts have been identified and management has decided which projects to address first, an action plan for each project should be written. The best results in formulating an action plan are obtained when the environmental task group and the technical specialists jointly find solutions.

It is not necessary to address all impacts at one time. Initial actions on more important areas should be undertaken first, addressing lesser issues at a later date. The action plan should also be flexible enough to accommodate modifications in line with changing priorities and external and internal circumstances.

The following action plan model will help to address critical areas in analyzing projects and creating an effective action plan.

Model Action Plan
Environmental Impact and Issue to be Addressed.
Category:
Subject:

Specific Objectives and Targets. For example, consider using a chart such as the one below:

Objective	Target
Reduce emissions of volatile organic compounds	Reduce emissions by 10 percent in 2000
Reduce energy use	Reduce electricity use by 15 percent in 2000 Reduce natural gas use by 20 percent in 2000
Recycle cardboard waste	Recycle 50 percent of cardboard waste in 2001
Improve compliance with wastewater discharge permit limits	Zero permit limit violations by the end of 2001
Promote environmental activities	Promote environmental activities through letters attached to payment slips
Reduce energy used in manufacturing operations	Achieve 10 percent reduction of energy consumption from to the previous year
Recycle plastic bottles	Recycle plastic, 50 percent of bottles in 2000 and 100 percent of bottles in 2001

Action team and team leader. The team may include representatives from the environmental task group, health and safety, product design, engineering, line management, maintenance, or other functions as appropriate. Create work teams according to the expertise and availability of action team members.
Environmental impacts throughout the project’s life cycle. Consider the project’s stages in the life cycle of the organization’s products, service and activities. Evaluate the environmental impacts throughout the product’s life cycle, beginning with the initial product design, acquisition of raw materials and continuing through all stages of processing, storage, manufacturing, distribution, transportation, and final disposal. A flowchart of the company’s operational process can provide a clear view of how its activities have been conducted and may help locate flows and weaknesses.
Steps to eliminate or minimize negative environmental impacts. There are many ways to reduce adverse environmental impacts. For a list of techniques to consider, see Tip Sheet: Techniques for Addressing Environmental Problems below.
Information and resources needed to carry out the task and people to assist the action team. Assign personnel to collect information to support the action team in determining the procedures for minimizing or eliminating negative environmental impacts. Look for information not currently classified as "environmental," such as operational data, management reports, audit reports, water and energy regulations and permits. There are also useful sources of information outside the company and on the Internet. For more information on resources, see Chapter 11.
Schedule of activities, dates and deadlines.
Measurement Performance. Essentially this comprises the ‘project plan’ against which various phases of the action plan are monitored. Create a performance indicator. Measuring performance is critical in any important endeavor. What gets measured gets managed. For more information on formulating a measurement system, see Chapter 6.
Expected benefits. Some benefits from environmental improvements are intangible and cannot be directly measured. However, it is important to recognize them.
Investment costs. A budget for all the various phases of EMS implementation needs to be formulated. It is difficult to put a price on implementation, but designate funds for each project to uphold its development. For small and medium-sized enterprises, implementing an EMS may be more dependent on human resources than financial resources.
Date for first and subsequent assessment. Regular review of progress needs to be made. This also assists in identifying factors which may need to be overcome or to which special attention needs to be paid to ensure success.

Tip Sheet: Techniques for Addressing Environmental Problems

Redesign. Change the design of either the product or process to eliminate or reduce any negative environmental impacts.
Substitute. Try to eliminate or reduce negative environmental impacts by replacing a source of waste with another material less likely to adversely affect the environmen. A packaging example: Styrofoam peanuts could be substituted for peanuts made from corn by-products, which are more likely to disintegrate naturally.
Reduce. Reduce the amount of waste products by reducing the use of components or materials that create or significantly add to waste streams.
Recycle. Usually entails breaking down a product (or its parts) or a process (or its components) into its base components and refabricating them.
Rebuild. Restore a product or process to its original condition or similar condition. Rebuilding recovers some parts or components, while others must be replaced. The greater the number of parts/components recovered, the more efficient the rebuild.
Re-manufacture. Restore a product or process to original or better-than-original condition without any parts being reduced to raw materials.
Reuse. Return material to the same application in its same form.
Internal Consumption. Use waste internally when possible. For example, wooden pallets can be used to make electricity when used as a part of a co-generation facility.
Prolong Use. Increase the overall life of the product through extended use. An effective preventative maintenance program is key to prolonging use. For example, car engines or cooling units may be re-designed to extend the time periods between overhauls. While still maintaining acceptable levels of safety and reliability.
Spread risks. Transfer responsibility to a third party who is better able to deal with the product or process. This option is often used when management feels it cannot reduce the level of environmental problems associated with a product or process. By calling in an expert, management attempts to spread the risk e.g. a company using a disposal service to break up and haul away an old assembly line.
Create a market for waste products. Seek customers for the company’s waste and help to create a market for it. For example, a furniture manufacturer converted its remnants into rear interior shelves for use in cars. A third party was brought in to pick up the remnants and those from other furniture makers in the area. The result was the creation of a viable market for these remnants.
Separate waste. Waste streams should be separated into different types before recycling, reuse or internal consumption. Waste separation is an intermediate action to facilitate reuse or recycling.

Tip Sheet: Screening and Identifying improvements in Working Practices Applications

How has it worked in similar applications?
Is this option within the budget, considering both capital and ongoing costs?
Does this option have an acceptable payback period (under one year is considered exceptional, under three years good?)
Does this option reduce the company’s raw material costs, energy consumption and/or pollutants?
Will this option reduce the company’s waste disposal costs and/or material and waste storage costs?
Will this option reduce the company’s costs associated with worker injuries or illnesses?
Will this option reduce the company’s insurance premiums?
Does this option have a proven track record?
Will this option maintain or improve product quality?
Will this option adversely affect or increase productivity?
Is space available if necessary?
Are the necessary utilities available or must they be installed?
Is the new equipment, materials, or procedures compatible with production operating procedures, workflow and production rates?
Is special expertise required to operate or maintain the new system? Is additional labor required?
Is it certain that this option will create less waste?
Is it certain that this option will not move waste problems from one form to another site or part of the overall operation (e.g. from solid waste to air emissions)?
Is the plant layout and design capable of incorporating this option?
Has it been determined that this option will improve or maintain worker safety and health?
Are materials and parts readily available?
Does the vendor provide an acceptable and reliable service?
Are other businesses using this option?
Does this option promote recycling?

Tip Sheet: Ways to Reduce Waste

Change plant operations and/or procedures by improving housekeeping and training employees about ways to reduce waste.
Substitute non-toxic materials in the production process.
Reclaim (recycle) materials during the production process.
Modify equipment to improve efficiency.
Re-design the final product to eliminate processes that create wastes.
Standardize materials or use the minimum number of types of materials in processing. This increases the potential for recycling and reduces the amount of waste requiring disposal.
Provide adequate aisle space for container transfer and easy access for inspections.
Properly label containers with material identification and health and safety hazards.
Stack containers according to manufacturers’ instructions to avoid damaging containers by uneven or excessive weight distribution.
Separate different hazardous substances to prevent cross-contamination and mixing of incompatible materials, and to facilitate inventory control.
Store containers on pallets or similar device to prevent corrosion of the containers, which can result when containers come in contact with moisture on the floor.
Regularly check and repair all leaking tanks, pumps, valves, taps, etc.
Inspect tank and tank liners regularly to prevent failures.
Install high-level alarms on all plating and rinse tanks to avoid accidental bath overflows.
Minimize the volume of water used during cleanup operations.
Educate staff are informed about the importance of preventing spills and minimizing bath contamination and waste generation.

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Creating a Prevention and Emergency Plan

Prevention and Emergency Preparedness Plans
A prevention plan assesses the potential for accidents and creates procedures to prevent or mitigate their impacts. An emergency plan identifies procedures in case an accident occurs. These plans are needed to prevent possible accidents and address all environmental impacts or abnormal situations that may occur.

A prevention plan is a proactive measure intended to prevent problems before they occur or are aggravated. It may be built on an existing emergency preparedness plan and focuses on reducing injuries, protecting employees and the community, reducing asset losses and minimizing production downtime or any other potentially significant negative trends.

Preventive maintenance improves the efficiency and longevity of equipment, reduces slowdowns or shutdowns from equipment failures and reduces the likelihood of producing rejected, off-specification products. Preventive maintenance should consist of regular inspections, equipment cleaning, lubrication, testing, measuring and replacing worn or broken parts.

Developing Prevention and Emergency Plans

Many companies have emergency procedures which can serve as the basis for new prevention and emergency plans.
The environmental task group should look at normal and abnormal situations and decide how to manage them.
Make sure all employees know what to do in case of an emergency.
Emergency procedures should be tested periodically.
Communicate the procedures among all the staff.
Inform staff of emergency and/or spillage procedures. Include emergency contacts and provision of clean-up equipment, personal protective equipment and first aid measures.
Identify agencies and authorities that are aware of these emergency procedures and facility operations.

Tip Sheet: Ways to Prevent Spills and Leaks

Spill and leak prevention includes operational procedures and precautionary modifications to equipment and containment areas. Conducting leak detection properly and consistently is perhaps the single-most important pollution prevention maintenance activity. Early detection of a release saves money from lost revenues and cleanup costs.
Install and regularly test overflow alarms on storage, process and treatment tanks. Document/log checks should be made.
Use tanks and containers according to manufacturer instructions and for their intended purpose.
Maintain the integrity of tanks and containers.
Implement controlled and supervised loading, unloading and transfer of all hazardous substances.
Construct secondary containment structures around all tanks or storage areas containing hazardous substances.

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