One of the challenges of managing an environmental program at a facility is the management of waste. The Resource Conservation and Recovery Act (RCRA) was passed in 1976 with the intent of protecting public health and the environment from the harmful effects of solid and hazardous wastes generated at a facility. Environmental Management Systems (EMS) should have a program to Reduce, Reuse, and Recycle products to minimize waste streams generated.
- Evaluate the products used at your facility and eliminate the use of multiple products for similar uses. For products that will generate a hazardous waste stream upon disposal, look for more environmentally friendly alternatives.
- Purchase products in appropriately sized containers, taking into account consumption rates. Expired products, that no longer have a use, may need to be disposed of as a waste product.
- Consider eliminating hardcopies of many documents and storing documents produced electronically.
- Evaluate and reuse products and chemicals where possible. Products that are reused are not classified as a waste stream.
- Evaluate the use of a filtration system for maintenance activities. A filtration system can extend the useful life of oil and other lubricants.
- Set up a recycling program for your facility. You can start simply then expand to other recyclable items as the program matures. Recyclable items may include paper, cardboard, aluminum, steel, tires, lead-acid batteries, and plastics to name a few.
- Evaluate and consider recycling petroleum and antifreeze products. A recycling program will not only reduce waste streams, but may also generate additional income for the facility.
- Evaluate the possibility of recycling totes and containers. Contact the chemical manufacturers or distributers to determine the viability of returning the totes for recycling.
The successful implementation of an Environmental Management System (EMS) requires the participation of the entire work force. The following are 5 ways to empower your employees and encourage active participation within the EMS.
- Training – Supervisors and employees should not only be trained on the legal requirements of the permits, but also on the regulations behind the permits. Education is the first step to empowering employees.
- Participation – Encourage employees to participate in environmental programs. This could include risk assessments, assessment of environmental aspects, setting of goals and objectives, development of action plans, etc. Employees should also be encouraged to participate in regulatory and other required inspections.
- Information Updates – Supervisors and employees appreciate being kept up to date on permitting and regulatory issues on a regular basis. This can take place at your regularly scheduled safety meetings or could be in the form of a regular newsletter.
- Feedback – Provide employees with feedback on actions or efforts that have taken place to maintain regulatory compliance or protect the environment. If an employee has done something extraordinary, let them know. Providing positive feedback is an essential element to empowering employees.
- Visible Leadership – Schedule time to interact with employees during the course of the week. Some employees may not offer up suggestions and ideas if they have to come to you. Visit with employees during the course of their daily activities. Regular interaction will build relationships and allow everyone to become involved in the EMS.
Empowering employees is an essential element to successfully implement an effective EMS. How do you empower your employees? Please provide comments and feedback below.
Establishing and implementing an Environmental Management System (EMS) is all about protecting the environment. The following are 10 ways to protect the environment at your facility.
- Establish and implement an Environmental Management System to manage and protect the environment. Consider implementing an ISO 14001 system.
- Compliance – Know and understand the laws and regulations that apply to your facility.
- Educate – Train and educate employees at all levels on their roles and responsibilities with respect to the environment. Protecting the environment and maintaining a culture of compliance is everyone’s responsibility.
- Accountability – Protecting the environment and maintaining a culture of compliance is everyone’s responsibility. Everyone must know and understand their role and responsibility.
- Courageous Leadership – Empower employees with the knowledge and responsibility to share ideas for reducing environmental impacts.
- Reduce, Reuse, and Recycle – Explore ideas to reduce waste, reuse resources, and recycle products to make the facility more efficient and reduce environmental impacts.
- Participation – Encourage employees to become involved in environmental inspections and initiatives. Reward employees for innovative ideas and actions.
- Report – Establish an environment where all incidents are reported and investigated promptly.
- Assess Effectiveness – Assess the effectiveness of controls put in place to protect the environment. Develop and implement new controls in high risk areas.
- Continual Improvement – Continually strive for new ways of doing things with a focus on protecting the environment.
Do you have any other tips to protect the environment? Please share your comments and ideas below.
Even the most effective and well developed Environmental Management Systems (EMS) will at times have failures resulting in environmental incidents. Successful EMS will have pre-plans to anticipate and respond to emergency situations which may occur. The following are tips to develop an environmental emergency response plan.
- Conduct a risk assessment to determine the environmental incidents which could occur at your facility. In conducting the risk assessment consider:
- Safety incidents captured within your safety and health risk register which could have an environmental aspect.
- Chemicals, fuels, and other products used at the facility. Many of these products are already captured and identified if your facility is required to maintain a Hazardous Material Permit.
- Controls that have been implemented to reduce the likelihood and severity of the incidents.
- For each of the potential incidents identified through the risk assessment, outline a course of action that would be taken to control and minimize the environmental impacts. The response plans should consider and outline:
- Roles and responsibilities during and post incident.
- How to maintain personal safety during the response.
- Isolation of the environmental incident and securing the area of the incident (i.e. isolating a spill).
- Protection of sensitive environmental areas (i.e. waterways, wildlife).
- Clean-up and mitigation procedures.
- Equipment and resources available on site to mitigate the environmental incident.
- Outside resources that are available in the case of an incident which requires resources which are beyond those located on site.
- Internal notification and reporting requirements.
- Regulatory agency notifications including reportable quantities, reporting, and contact information.
- Press releases and community notifications.
- Also develop a procedure to form a formal Incident Command Center if the incident warrants continued resources over an extended period of time.
Establishing an emergency response plan will result in a quicker and more effective response to an unplanned environmental incident. What have you found to be the most effective way to plan for an environmental incident?
Regardless of the maturity of a facility, changes will occur that may impact the environment or require additional permitting with regulatory agencies. Identifying and understanding the impacts of the changes is an essential element to an effective Environmental Management System (EMS). The following are some tips to successfully manage change.
- Define and communicate what constitutes a change. Consider that a change may be a physical change to equipment or processes or it may be something more subtle like a change in responsibilities, positions, or organizational structure. You may also choose to exclude specific activities that are either routine or are simple in-kind replacements of equipment or machinery.
- Establish a formal system to review changes. Make the system comprehensive enough to minimize the risk of non-compliance, yet making it simple enough that employees will be encouraged to use it. The system should include:
- Stakeholders who are directly or indirectly impacted by the change.
- A review of regulatory requirements and permitting required prior to implementation.
- A formal approval process that authorizes the implementation of the change.
- Documentation and justification for the proposed change, along with the projected benefits.
- A formal risk assessment process to assess the likelihood and consequences of impacts from the proposed change.
- Actions that must be implemented prior to execution of the change.
- A review of the implemented change after execution to assess the effectiveness of the controls and evaluate the benefits realized.
- Documentation or actions that will be required post implementation (i.e. as-builts or record of construction reports).
- Define who is required to follow the change management procedure. In addition to employees, this may include contractors, vendors, and consultants who may work at your facility.
- Establish a documentation procedure for the change management system such that completed changes are archived. Previous documentation should be catalogued and searchable such that employees can access them for future change reference.
- The management of change, which may impact the environment, may be incorporated into a more global change system that also assess for impacts to safety and health, production, community, or other areas of concern.
A change management system is an essential element of a successful EMS. Managing change is necessary to protect the environment and ensure regulatory compliance. What systems do you use to manage change?
Environmental Management Systems (EMS) are designed to prevent environmental incidents and ensure compliance with regulatory requirements. However, systems and controls can fail. The EMS should have a system put in place to periodically review and assess the effectiveness of the systems and controls. The following are 5 steps to test for the effectiveness of the controls.
- Establish a review period for your permit obligations. Reviewing the permit requirements on a regular basis will help to ensure that you are familiar with the requirements and that the requirements are being met.
- Review the Environmental Obligation Register on an annual basis. Ensure that action plans with reminders have been established for all of the recurring permit requirements.
- Correct any deficiencies in the action plan reminders immediately upon discovery. If there is an element of an action plan that isn’t clear as to the action to be taken, causing you to refer back to the permit, correct it immediately.
- If there is a case of an environmental incident or permit non-compliance:
- Conduct a root cause analysis to determine the source of the system failure.
- Set up action plans to correct the system or to add additional controls.
- Set a timeframe to review the effectiveness of the controls or changes to the system intended to prevent the recurrence of the system or control failure.
- If the review indicates that the changes did not result in the desired outcome, start the process over. It is likely that you have not determined the root cause.
- Review and discuss overdue action items at senior staff meetings. Follow up on overdue action plans and hold people accountable for completing the action plans and tasks.
Setting up processes to review and test for the effectiveness of the systems and controls is essential to an EMS. Following these steps and working to continually improve will result in a more effective EMS. How do you test for the effectiveness of systems and controls within your organization? Please share your comments and thoughts.
Image Credit: Root Cause via Think Reliability
Environmental Management Systems (EMS) are established to protect the environment and ensure compliance with legal and other non-regulatory requirements. I previously discussed the importance of establishing an Environmental Obligation Register (EOR). The following are nine simple steps to set up your legal and other requirements within your Environmental Obligation Register.
- Create an obligation in the EOR for each of the individual permits associated with your facility.
- For each obligation, reference the specific permit number and regulation. This will provide context for any subsequent successors to your position.
- Create individual action plans/tasks, under each obligation, for each of the individual requirements associated with the permits.
- Set up a reminder in the EOR for each of the repetitive action plans and tasks. When setting up a reminder, consider the time that will be required to complete the task.
- Set up a recurrence interval for each of the reminders.
- Assign a due date to each of the action plans and tasks.
- Assign responsibility for completing the action plans and tasks. Assign the tasks to both an individual and a position. If the responsible individual changes position or leaves the company, reassignment is simply assigning another individual to that position.
- Set up and assign positions of responsibility within the EOR.
- Provide details within the action plans and tasks for how the requirement closeout will be documented. Consider a requirement to attach or provide a link to the documentation required for closing out the action plan or task.
EORs are an essential tool to efficiently manage legal and other non-regulatory requirements associated with your facility. Do you have any unique methods to manage your EOR? Please share your comments and suggestions.