Creating and implementing an Environmental Management System (EMS) is more than just identifying the laws and regulations that apply to your facility and complying with the regulatory requirements contained in your permits. An effective EMS will identify the environmental aspects (causes) of each of the processes occurring at your facility and analyze what impacts (effects) they have on the environment. These aspects and impacts can then be linked to the regulatory requirements, identifying areas to improve performance and compliance.
In order to identify and analyze your aspects and impacts:
- Organize your facility into groups. For a small mine, these might include administration, mining, processing, and exploration.
- Within each of the groups, identify the main processes. For mining, processes may include dewatering, drilling, blasting, loading, hauling, dumping, fueling, maintenance, reclamation, and others.
- Next, break down each of the processes into specific activities. Blasting, for example, may be broken down into offloading ammonium nitrate, loading and transporting explosives, loading the blast holes, tying the blast pattern, detonation of the blast, and post blast activities.
- Create a range of set answers for each of the questions used to analyze the aspects.
- Identify each of the environmental aspects associated with these activities by asking the following questions:
- Does the activity have positive or negative impacts to the environment? For example, does it produce air emissions, impact surface or ground water, impact the land, or deplete natural resources? Does it impact vegetation or wildlife?
- While analyzing the impacts, consider the potential impacts during normal operations, upset conditions, and emergency conditions. When are the potential impacts likely to occur?
- Are there any regulatory or other requirements associated with the identified aspect/impact?
- What is the likelihood of the impacts occurring?
- What are the severity of the impacts? Would they result in limited reversible impacts or do they have potential to result in long-term environmental impacts? Are there regulatory reporting requirements? Would the impact result in a breach of regulations with the potential for regulatory actions or fines?
- What are the costs of mitigating the impacts?
- How would you gauge the level of interest from regulators, community members and other stakeholders?
Identifying and analyzing the aspects and impacts associated with your facility will assist you in determining the areas of greatest concern and where your focus should be. Understanding the aspects and impacts will allow you to better comply with the regulatory requirements and will help to create value-adding targets and goals for your environmental program.
Managing documents is one aspect of your EMS that is crucial to your ability to demonstrate compliance with the laws and regulations that govern your facility. Whether it is an auditor looking for a demonstration of compliance, or a regulator inquiring about a required report, compliance records need to be managed consistently every time.
Create an environmental document control procedure for your organization. The procedure should create a document flow so that every piece of correspondence is handled consistently, and will go through the necessary steps. As the process becomes routine, the efficiency of the organization will improve. After you have defined the workflow for outgoing and incoming documentation, summarize it in a flowchart. A graphical flowchart will provide a quick reference for those managing your permits.
For incoming correspondence, the procedure should identify:
- The person/role receiving communication
- Routing for review of correspondence
- Procedure if correspondence requires follow-up
- Incorporation into obligation register (if applicable)
- Scanning/filing procedure
- Electronic file naming convention
Similarly, for outgoing correspondence, the procedure should identify:
- Person/role writing correspondence
- Electronic file naming convention
- Review/approval/signature process
- Scanning/filing procedure
- Mailing procedure – (consider certified mail with return receipts for better tracking)
- System for tracking correspondence
Creating a systematic procedure for managing correspondence will result in a more efficient flow of documents through your organization. Documents will be properly reviewed and approved, and will be easily retrieved when needed. The system should be simple and concise so that it can be summarized on a one-page flow diagram.
What other ideas have made document management simpler at your organization? As always, I welcome comments and feedback on all of my blogs.
Managing an environmental program for a facility requires good organizational skills. As I discussed in EMS – Creating an Obligation Register, even a small mine may have over a hundred individual permits to maintain and hundreds of individual requirements associated with those permits. All that boils down to a lot of paperwork to keep track of and a lot of information to keep organized. If you have been procrastinating, thinking that you will get organized when you have some spare time, don’t wait. That spare time will never arrive and, the longer you put it off, the more documents you have piling up.
I’m a big fan of electronic files for everything. Electronic files can be searched whether they are located on a file server or in a document database. Having the ability to access all the files while you are traveling is essential in today’s world. If a question comes up while you are meeting with regulators, electronic files will allow you to access the needed information quickly and efficiently. Your ability to locate and access information, whenever it is needed, will make more efficient use of your time and make your job more manageable. During a regulatory inspection, the ability to readily produce required documentation will build credibility with the regulators and make inspections easier.
Take a look at your obligation register and use it to draft up a file structure. I like to organize my files by permit and year, breaking out the files into outgoing and incoming correspondence. If any folder in the file structure has more than ten files in it, I would consider breaking out the file structure into another level. This will keep the files organized and easy to find.
Come up with a naming convention for your correspondence which will include each of the key word searches for the document. In addition to the specific document name, consider adding each of the following into your naming convention:
- Regulatory agency abbreviation – standardize to make it easy to find.
- Permit type or media – air, water, waste, etc.
- Permit number
- Specific document name
A document with a properly formatted naming convention will make file searches a breeze. No more rifling through folders looking for that document you can’t seem to locate. Once the naming convention is established, add your new document, copy the properly formatted name from previous correspondence, and paste it in to your new document file name. Then all you have to do is correct the specific document name portion and the date.
A well-organized document control system will pay dividends almost immediately. As with all of my blogs, I welcome your comments and suggestions. What have you found to be the most effective and efficient way to manage documents?
Before you can begin to build an effective Environmental Management System (EMS), you need to define the scope and purpose of the EMS. A project charter is a great place to start, which will identify a project sponsor, a project manager, and outline what the ultimate goal of the system should be.
The next step is to create a detailed scope. As a young engineer, I was tasked with managing the construction of a large truck wash facility for mine equipment. The project was already underway with a tight completion schedule when I became involved. The final designs of the project were still under development as construction began. After the building structure was erected and the overhead doors were installed, it was noted that there were no man-doors to enter the building. There were numerous other issues with the facility that had to be addressed prior to being able to commission the facility. How did this happen? The project had never been properly scoped and, as a result, suffered from several design and construction issues that should have never occurred. The project was completed; however, it was completed behind schedule and over budget.
Just like a construction project, you must have a clearly defined scope to develop a successful EMS. The following questions will help to develop a scope for the EMS.
- What is the purpose of the EMS and what will the end product look like?
- What operations and facilities will be included in the scope and are there any operations that will be specifically excluded?
- What resources will be needed, both in terms of manpower and budget, to develop the end product?
- Who will need to provide input to the system for it to accomplish its purpose and to make the system effective?
- How will the system be implemented and what resources will be required?
- What resources will be required to maintain the EMS once it is implemented?
- What is the targeted date for completion?
- What training will be required?
As you work through the development of the EMS, refer back to the scope frequently. This will help to keep the focus on the value adding activities and help to identify the items which are out of scope for the project. This will work to keep the project on track and within the budget and time constraints.
Please feel free to comment on this or any of my other blogs.
Over the last couple of decades, the rules and regulations governing mining and other industries has become increasingly complicated. It is not unusual for a company to have over a hundred separate permits and programs to manage for a particular operation. Each of these permits may have many obligations and requirements associated with them. Keeping track of all the legal obligations associated with these permits and programs can seem overwhelming at times and requires some good organizational skills to manage them effectively. I once had a boss who said that the three most important things to maintain your license to operate are: Compliance, Compliance, and Compliance! A complete and detailed obligation register is essential to consistently achieve compliance.
So how do you best manage and track all of these obligations? The most effective way that I have found is to develop and maintain a detailed obligation register. An obligation register can take many forms. It may be as simple as a table created with a spreadsheet that you post to your office wall, or a more intricate database with integrated reminders to keep you informed of upcoming commitments. The key is to carefully go through your permits, understand what the requirements and obligations are, and compile a comprehensive list of actions needed to maintain compliance.
There are several popular out-of-the-box software packages that will help you manage your legal and other requirements. These software packages are somewhat versatile and can track not only your environmental commitments, but also your safety and health and community related obligations. My first experience utilizing one of these software packages was with a product called Intelex. BSI Entropy Software makes a similar database product that also tracks legal and other obligations. Either of these solutions will help to organize your obligations and make managing your environmental commitments much simpler. While both of these products have the same objective, the interfaces and functionality is quite different.
Before investing the time and money required to implement one of these software packages, explore what others in your industry are using. Find out what they like and what they don’t. Make sure the solution meets your needs and will be simple to use. If it isn’t simple and straight-forward, employees won’t use it, and your efforts will be for naught.
How do you manage and track the environmental obligations at your organization? Please feel free to comment and provide feedback, as with all of my blogs.
In developing an Environmental Management System (EMS), it is critical to know the laws and regulations that apply to your company. There are a number of subscriber services that can keep you abreast of changing regulations and proposed rule changes. A couple of services that I have used, or am currently using, include: the Environmental Compliance Alert and IHS CyberRegs. These services are inexpensive and work quite well.
Another excellent source of information is your local trade group or organization. Here in Nevada, the Nevada Mining Association (NMA) is an organization that meets regularly to discuss current topics and issues as well as discuss proposed rule changes and regulations relevant to the mining industry. The NMA meetings provide a venue to meet business leaders and network with technical experts in your industry.
Regulatory permits are another excellent resource to research and understand the applicable laws and regulations. State permits will often contain regulatory citations which can be researched and reviewed online. The Nevada Revised Statutes (NRS) and Nevada Administrative Code (NAC) provide the basis for all of the State administered programs, while the Code of Federal Regulations provides the basis for the federal programs.
Finally, regulators themselves can provide an excellent resource of information. Develop relationships with the regulators and schedule regular meetings with them. This provides an opportunity to showcase your property’s areas of excellence, as well as establish lines of communication for future issues and developments. At the time of permit renewal, ask the regulators if you can review the draft permit before it is issued. While not all regulators will accommodate this request, it can be an effective strategy to make points of compliance and permit requirements more manageable. A review of the draft permit will also help to clarify ambiguous statements and provide a clear vision of what compliance will look like.
I welcome comments and feedback to all of my blogs. What has proven successful for you in staying informed of changing environmental regulations?
Today, it is more important than ever to establish and implement a strong environmental management program regardless of the industry you are in. Mining, and the development of mineral resources, is an important part of many economies throughout the world and contributes to the sustainable development of the communities in which we operate. Mineral development, like many industries involved in the natural resource sector, impacts the environment and can leave both temporary and long-lasting impacts to the environment. Regulatory laws and requirements have been put in place to protect the environment and the communities in which we operate. Creating a strong environmental management system (EMS) goes beyond managing our legal requirements; it is our social obligation and one of the key elements in maintaining a social license to operate. It’s about doing the “right thing” and protecting the places where we live, work, and play.
Before creating and implementing an EMS, develop a robust environmental policy statement. What is it that you are trying to accomplish? The environmental policy should state your goals and objectives; provide a commitment to prevent pollution; provide a commitment to comply with all laws, regulatory requirements, and other environmental obligations; and establish a commitment to continually strive for improvement. The policy statement should reflect your values and provide a commitment by senior management to provide the necessary resources and support to implement the EMS. A strong policy statement provides the foundation for a successful EMS.
In the upcoming blog postings, I will share my successes, as well as the lessons I’ve learned while implementing a successful EMS. Managing environmental impacts and navigating the regulatory environment in which we operate can prove difficult challenging at times; however, a well-developed EMS can make the challenge manageable and rewarding.
As with all of my blogs, I welcome comments and feedback. Please share your own experiences and triumphs. What lessons have you learned?