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