X, Ems For Die Cast Industry

ENVIRONMENTAL MANAGEMENT SYSTEM (EMS)
TEMPLATE FOR THE

DIE CASTING INDUSTRY
September 2003
ENVIRONMENTAL MANAGEMENT SYSTEM (EMS)

TEMPLATE FOR THE METALCASTING INDUSTRY
Introduction
An Environmental Management System (EMS) is an organizational tool composed of planning,
implementation, checking, and management review elements that a facility uses to ensure that it
meets its environmental performance goals. It does so while taking into consideration its legal
and other requirements, its significant environmental aspects, its technological options and its
financial, operational, and business requirements, and the views of interested parties.
This EMS template for the Die Casting Industry has been assembled from the best and most
recent guidance, examples, tools, and forms included in several U.S. Environmental Protection
Agency (EPA)-sponsored EMS source documents (see annotated list below). It also reflects an
EMS that is consistent with the emphasis of EPA's National Environmental Performance Track
Program on sustained compliance, preventing pollution, continuous improvement in
environmental performance, and sharing information with the community.1
Using information collected from Die Casting publications, facility site visits, and telephone
interviews, the template has been customized to address industry conditions. It is meant to assist
Die Casting facilities in those areas that will have the most immediate impact on improving
environmental performance and associated economic performance. It is largely the case that Die
Casting facilities have many components of an EMS already in place. In using this EMS
template, the theme throughout should be to identify those already existing components and
build on them rather than to adopt an overwhelming impression that much is missing.
Though there are other types of EMS's that one could adopt, and EPA does not specifically
endorse any individual EMS standard, the ISO 14001 EMS is the one most widely recognized
across the world and the one that companies are beginning to require their suppliers to adopt.
Therefore, moving in the direction of implementation and maintenance of an EMS based on the
ISO 14001 Standard may be a wise business decision. The choice to build an EMS that, if
desired, could be certified in the future, seems to make sense from an efficiency and costeffectiveness point of view. Facilities implementing the requirements of an effective EMS that
meets the requirements of the ISO 14001 Standard can either seek third-party registration or selfdeclare conformance.
To facilitate your implementation process, the template groups its modules, each corresponding
to an EMS element, into the four activities that correspond generally to the plan-do-check-act
model that most management systems follow:
x
Laying the groundwork and obtaining top management commitment
Developing policy and planning elements
Developing implementation elements
Developing corrective and preventive action, management review, and continuous

improvement elements
There is logical sequence in working through the modules in their numbered order for the first
two activities. Once an initial round of EMS planning is complete the various implementation
1
More information on the Performance Track program is provided in Appendix A.
Introduction - i
modules can be approached in a somewhat parallel fashion. Similarly for checking and review,
the material in the modules can be created and implemented somewhat concurrently. Example
1-1 in Module 1 demonstrates one organization's schedule for addressing the modules.
There are four different types of material provide in the EMS template. Definitions of each are
provided below:
x
Guidance. Guidance refers to information that describes what an EMS element represents
and what you will need to develop and maintain to fully satisfy EPAs definition of a
complete EMS
Tools. Tools refer to worksheets or questionnaires that assist you in thinking through how
to efficiently and comprehensively create a particular EMS element. Tools are important
to the process of defining what in your systems will later be documented, recorded,
monitored, measured, audited, reviewed by top management, etc. Sample procedures that
you can adopt for your own system are also considered tools.
Forms. Forms are different from tools in that they actually do become part of your
documented system, for instance serving as records, or information that might be
measured, monitored, audited, reviewed by top management, etc.
Examples. These are examples of how one might use a tool or complete a form. Many of
the examples were developed during a pilot program with the die casting industry, which
tested this template.
Brief descriptions of the EPA-sponsored EMS source documents used to develop the template
are provided below:
x
Integrated Environmental Management Systems Implementation Guide, US EPA, Office

of Pollution Prevention and Toxics, EPA 744-R-00-011, October 2000. This document
represents efforts by EPA to show how Design for the Environment (DfE) technical work
can be used to support the development of an EMS. It unites the EMS plan-do-check-act
model with DfE approaches such as the EPA Cleaner Technologies Substitutes
Assessment Methodology. It contains useful EMS guidance, tools, forms, and examples
and has material especially relevant to chemical use-intensive facilities.
Integrated Environmental Management Systems, A Company Manual Template for Small
Business, US EPA, Office of Pollution Prevention and Toxics, EPA 744-R-00-012,
December 2000. This document represents an EMS manual template, including cover
page, table of contents, and complete documentation, for a fictional corporation. It
contains procedures and associated forms for an EMS that is designed according to the
principles of the implementation guide described above.
Environmental Management Systems: An Implementation Guide for Small and MediumSized Organizations, NSF International, Second Edition, January, 2001. This document
was designed to explain EMS concepts, using the ISO 14001 standard guidance, tools,
forms and examples that are broadly applicable to many different types of businesses.
Implementation Guide For The Code of Environmental Management Principles for
Federal Agencies (CEMP), US EPA, Office of Enforcement and Compliance Assurance,
EPA 315-B-97-001, March 1997. This document was developed by EPA to help federal
agencies move toward responsible and proactive environmental management. It describes
five broad principles that are meant to foster environmental performance objectives that
are proactive, flexible, cost-effective, integrated, and sustainable.
Introduction - ii
Environmental Management Review (EMR) National Report: Lessons Learned in

Conducting EMRs at Federal Facilities, US EPA, Office of Enforcement and Compliance
Assurance, EPA 315-R-99-003, November 1999. Supplementary EMR Checklists are
also included. These documents present lessons learned by EPA from their review of
individual facility environmental protection programs and management systems. The
programs are intended to ensure compliance and progress towards environmental
excellence.
The US EPA Environmental Management System Pilot Program for Local Government
Entities, Prepared by Global Environment & Technology Foundation, Assistance
Agreement No. X 825557-01-0, January 28, 2000. This document represents a final
report to EPA on a multi-year pilot program to implement EMS for local government
entities. It presents EMS lessons learned and examples that can be useful to businesses
and other organizations.
Improving Environmental Performance and Compliance, 10 Elements of Effective

Environmental Management Systems, Guidance Document, Enforcement Cooperation
Program of the Commission for Environmental Cooperation, June 2000. This document
sets out what the three North American governments have agreed is important to address
in implementing EMSs. It is intended to assist EMS users make responsible decisions and
take actions to achieve better environmental performance through maintaining
compliance with environmental laws and moving beyond compliance. It provides a list of
ten elements to help ensure that what needs to be done is being done to meet
environmental goals. It is intended as guidance for those organizations in the public and
private sectors that seek to apply EMS in a way that will work effectively and build better
relationships with customers, suppliers, lenders, investors, the local community, and the
government.
Introduction - iii
Die Casting- EMS Template

September 2003
Table of Contents
Introductory Material
Introduction.......................................................................................................................... i
Table of Contents............................................................................................................... iv
Index of Exhibits and Examples ..........................................................................................v
Definitions ......................................................................................................................... ix
Laying the Groundwork
Module 1: Laying the Groundwork for EMS
EMS Policy and Planning
Module 2: Environmental Policy
Module 3: Environmental Aspects
Module 4: Legal and Other Requirements
Module 5: Objectives and Targets
Module 6: Environmental Management Programs
EMS Implementation
Module 7: Structure and Responsibility
Module 8: Training, Awareness, and Competence
Module 9: Communication
Module 10: EMS Documentation & Document Control
Module 11: Operational Control
Module 12: Emergency Preparedness and Response
EMS Corrective and Preventive Action, Management Review, and Continuous
Improvement
Module 13: Monitoring and Measurement
Module 14: Nonconformance and Corrective and Preventive Action
Module 15: Records
Module 16: EMS Audits
Module 17: Management Review
Appendices
A: EPA's Performance Track
B: Quality Management Systems Integration
C: Health and Safety Integration
Introduction - iv

September 2003
Index of Exhibits and Examples

Exhibit 1-1:
Exhibit 1-2:
Exhibit 1-3:
Exhibit 1-4:
Example 1-1:
Sample Worksheet for EMS Development: Participants,

Resources, and Schedule.......................................................................... 1-4
Sample Worksheet for Persons Responsible for EMS
Development ............................................................................................ 1-6
Documents/Information to Have Available for ISO 14001
Gap Analysis............................................................................................ 1-7
Gap Analysis Tool/Self Assessment Checklist...................................... 1-10
Example Schedule for EMS Implementation ........................................ 1-16

Exhibit 2-1:
Generalized Environmental Policy Template .......................................... 2-4
Example 2-1 through Example 2-4: Example Die Caster Environmental Policies .............. 2-5
Exhibit 3-1:
Exhibit 3-2:
Example 3-1:
Example 3-2:
Example 3-3:
Example 3-4:
Example 3-5:
Sample Procedure for Identification of Environmental Aspects and

Determination of Significant Aspects...................................................... 3-6
Sample Form for Identification and Significance Determination of
Environmental Aspects ............................................................................ 3-9
The Link Between Aspects and Impacts................................................ 3-12
Flow Diagrams of Typical Die Casting Processes................................. 3-13
Identification of Environmental Aspects ............................................... 3-16
A Numerical Scoring System Approach................................................ 3-18
A Second Numerical Scoring System Approach ................................... 3-25

Exhibit 4-1:
Exhibit 4-2:
Exhibit 4-3:
Exhibit 4-4:
Exhibit 4-5:
Example 4-1:
Legal and Other Requirements Worksheet .............................................. 4-4

Information Resources for Legal Requirements ...................................... 4-5
Sample Procedure for Identification of Legal and Other Requirements.. 4-6
Sample Form for Environmental and other Legal Requirements ............ 4-7
Sample Worksheet for Identifying Legal Requirements ......................... 4-8
Regulatory Checklist for a Die Casting Facility ...................................... 4-9
Introduction - v

September 2003

Exhibit 5-1:
Exhibit 5-2:
Example 5-1:
Objectives and Targets Worksheet .......................................................... 5-5

Sample Procedure for Identification of Objectives and Targets.............. 5-6
Possible Objectives and Targets Organized by Category ........................ 5-7

Exhibit 6-1:
Exhibit 6-2:
Exhibit 6-3:
Exhibit 6-4:
Example 6-1:
Example 6-2:
Environmental Management Program Worksheet................................... 6-4

Sample Form for Environmental Management Programs ....................... 6-5
Sample Procedure for Environmental Review for New Purchases,
Processes, and Products ........................................................................... 6-6
Sample New Purchase Approval Form for Environmental Review of
New Processes, Products, and Activities ................................................. 6-7
Environmental Management Program for Non-Abated Emissions
of VOCs and HAPs.................................................................................. 6-8
Environmental Management Program for Solid Waste from the
Unmasking Process................................................................................ 6-10

Exhibit 7-1:
Exhibit 7-2:
Exhibit 7-3:
Exhibit 7-4:
Example 7-1:
Structure & Responsibility Worksheet .................................................... 7-3

Sample EMS Responsibilities Descriptions ............................................ 7-4
Sample EMS Responsibilities Form ........................................................ 7-5
Functions to Include in Your EMS Team and Possible Roles................. 7-6
Responsibility Matrix .............................................................................. 7-8

Exhibit 8-1:
Exhibit 8-2:
Example 8-1:
Training, Awareness & Competence Worksheet..................................... 8-5

Sample Training Needs Analysis Form ................................................... 8-6
Training Needs Analysis Form ................................................................ 8-7
Exhibit 9-1:
Exhibit 9-2:
Exhibit 9-3:
Exhibit 9-4:
Communications Worksheet.................................................................... 9-6

Sample Procedure for Communication with Stakeholders ...................... 9-7
Sample Form for Stakeholders and Environmental Issues ...................... 9-8
Sample Form for Stakeholder Communication Record........................... 9-9
Introduction - vi

September 2003
Module 10: EMS Documentation and Document Control

Exhibit 10-1:
Exhibit 10-2:
Exhibit 10-3:
Exhibit 10-4:
Exhibit 10-5:
Exhibit 10-6:
Exhibit 10-7:
Exhibit 10-8:
EMS Documentation Worksheet ........................................................... 10-6

Sample Worksheet for Development of EMS Documentation.............. 10-7
Sample Outline for EMS Manual and Other EMS Documents ............. 10-8
Sample Procedure for Documentation ................................................... 10-9
Document Control Worksheet ............................................................. 10-10
Sample Procedure for Document Control............................................ 10-11
Sample Document Control Form ......................................................... 10-12
Sample Document Index Form ............................................................ 10-13

Exhibit 11-1:
Exhibit 11-2:
Exhibit 11-3:
Exhibit 11-4:
Example 11-1:
Operational Controls Worksheet............................................................ 11-6

Sample Worksheet for Determining Which Operations
Require Operational Controls ................................................................ 11-7
Sample Worksheet for Training Plan for Operational Controls ............ 11-8
Sample Form for EMS Operational Control Procedures ....................... 11-9
Operational Control for New Material Purchasing.............................. 11-10

Exhibit 12-1:
Exhibit 12-2:
Emergency Preparedness and Response Worksheet.............................. 12-4

Emergency Preparedness and Response Requirements Matrix ............. 12-5

Exhibit 13-1:
Exhibit 13-2:
Exhibit 13-3:
Exhibit 13-4:
Example 13-1:
Example 13-2:
Monitoring and Measurement Worksheet ............................................. 13-5

Sample Procedure for a Compliance Assessment.................................. 13-6
Sample Form for Compliance Tracking ................................................ 13-7
Calibration Log ...................................................................................... 13-8
Example of Links Between Aspects, Objectives and Targets,
Operational Controls, and Monitoring and Measurement ..................... 13-9
Linking Monitoring Processes to Operational Controls ...................... 13-10
Module 14: Nonconformance and Corrective and Preventive Action

Exhibit 14-1:
Exhibit 14-2:
Exhibit 14-3:
Exhibit 14-4:
Corrective & Preventive Action Worksheet .......................................... 14-5

Sample Procedure for Corrective and Preventive Action ...................... 14-6
Sample Corrective and Preventive Action Notice ................................. 14-8
Sample Corrective and Preventive Action Tracking Log ...................... 14-9
Introduction - vii

September 2003
Module 15: Records

Exhibit 15-1:
Exhibit 15-2:
Example 15-1:
Example 15-2:
Records Management Worksheet .......................................................... 15-4

Sample Checklist for Records of Supporting Documentation............... 15-5
Sample of Environmental Records File Organization ........................... 15-6
Sample EMS Records Management Table ............................................ 15-7

Exhibit 16-1:
Exhibit 16-2:
Exhibit 16-3:
Exhibit 16-4:
Exhibit 16-5:
Exhibit 16-6:
Exhibit 16-7:
Example 16-1:
Example 16-2:
EMS Auditing Worksheet...................................................................... 16-6

Sample Procedure for EMS Audits........................................................ 16-7
Sample Audit Plan Form...................................................................... 16-10
Sample Form for Communications to Audit Team.............................. 16-11
Sample Form for Internal Assessment Checklist................................. 16-12
Sample EMS Audit Summary Form .................................................... 16-13
Sample Form for EMS Audit Findings................................................ 16-14
Sample Questionnaire for EMS Audits ............................................... 16-15
Sample Checklist for Top Management EMS Audits.......................... 16-24

Exhibit 17-1:
Exhibit 17-2:
Exhibit 17-3:
Management Review Worksheet ........................................................... 17-5

Sample Procedure for Management Review.......................................... 17-6
Sample Management Review Record.................................................... 17-7
Introduction - viii

September 2003
Definitions
Environmental aspect (EA): An element of a companys activities, products, or services that can or does
interact with the environment (create an environmental impact)
Environmental impact: Any change to the environment, whether adverse or beneficial, resulting from a
companys activities, products, or services
Significant environmental aspect (SEA): An environmental aspect deemed by a company as having, or
potentially having, a significant impact on the environment
Alternatives evaluation: Process by which alternative methods for completing a particular function are
evaluated using business and environmental criteria
Non-conformity: Discrepancy between a companys actual EMS activities and the procedures laid out in
their EMS manual and associated documentation (that is, where the actual activities do not follow the
procedures)
Indicator: A measurable parameter or predictor of performance (in this case, of environmental
performance).
Root cause analysis: Systematic process to uncover underlying causes of a particular issue or problem.
If a drum is not labeled, you would ask what happened that resulted in the unlabeled drum (for example,
a new employee did not know the procedure, which would indicate that entry training might be a root
cause of the issue).
Introduction - ix
Die Casting Industry - EMS Template

September 2003

Guidance ..................................................................................................................................... 1-2
Tools ............................................................................................................................................ 1-4
Exhibit 1-1: Sample Worksheet for EMS Development: Participants,
Resources, and Schedule.......................................................................... 1-4
Exhibit 1-2: Sample Worksheet for Persons Responsible for EMS
Development ............................................................................................ 1-6
Exhibit 1-3: Documents/Information to Have Available for ISO 14001
Gap Analysis............................................................................................ 1-7
Exhibit 1-4: Gap Analysis Tool/Self Assessment Checklist...................................... 1-10
Examples................................................................................................................................... 1-16
Example 1-1: Example Schedule for EMS Implementation....................................... 1-16
Laying the Groundwork for EMS
Module 1 - 1

September 2003
GUIDANCE
EMS Planning Getting Started
Section 4.4.1 of the ISO 14001 Standard outlines requirements for Structure and Responsibility
within an Environmental Management System. Identifying primary roles and responsibilities is
covered more thoroughly in Module 7 of this manual. However, in order to begin building an
Environmental Management System, a few key individuals must be identified, so this section
provides a few tips on getting started.
A primary role is the EMS Management Representative who will be responsible for managing
the day-to-day EMS tasks at the facility. This assignment should be documented in a position
description that defines the responsibilities and duties associated with the role and on relevant
organization charts.
Next facilities typically identify a team of individuals (Cross Functional Team) that will help
implement the EMS. There are no requirements for how many people should be on the team or
what types of people should be assigned to the Team. The following are some general guidelines
for successful team building:
x
The Management Representative typically chairs the team meetings. Appoint someone to
record meeting minutes.
Team members should be selected from different areas, functions and levels within the
plant (Quality, Operations (including different casting areas, if applicable),
Shipping/Receiving, Engineering, Maintenance, Finance, Human Resources, etc.). One
of the most valuable components of building the EMS is providing the time for these
individuals to discuss environmental issues together.
Assign only those who are interested and can spend the time (at least 40 hours) during
implementation.
Document designation of Cross Functional Team members either with a memo from the
Facility Manager or on an Organizational Chart. Post these on bulletin boards to raise
general awareness.
x Try to limit Cross Functional Team meetings to 4 hours or less. Weekly meetings for
shorter periods tend to be more successful than longer meetings held only once a month.
Exhibits 1-1 and 1-2 will assist you in organizing and structuring your team.
Module 1 - 2

September 2003
EMS Planning - Gap Analysis

The facility should conduct an initial review or "gap analysis" to understand what is already
being done and to evaluate ways to improve and build on existing programs and activities. This
is an important part of laying the groundwork for your EMS.
A gap analysis is designed to answer the following questions:
x
How well are the organization and its environmental programs performing?
What standards of environmental performance does the organization hope to achieve?
What parts of the ISO 14001 EMS do we already have in place, even partially?
Where are there gaps between objectives and performance?
What existing programs and activities can serve as the best foundation for improved
environmental performance?
Through this process, many organizations will probably find ways to address some of the EMS
components at little or no cost.
Prior to beginning the gap analysis, it is helpful to pull together materials you will be
referencing. Exhibit 1-3 is a list of materials which can be useful in conducting a gap analysis.
Not all of these will be applicable to your specific facility and not all of them are necessary to
conduct a gap analysis. The list is, however, a good reference to consult as you prepare for your
gap analysis.
Exhibit 1-4 is a gap analysis tool/self-assessment checklist that can be used to assess current
programs and specific needs of a facility. Example 1-1 shows a typical EMS implementation
schedule. Plan to spend 9-12 months, on average, developing your system.
Module 1 - 3

September 2003
TOOLS
Exhibit 1-1: Sample Worksheet for EMS Development: Participants, Resources,
and Schedule
EMS Element
Participants
Resources
Schedule
Making the Commitment: Creating a Policy

Statement and Determining the Scope
Intermediate steps: (As appropriate)
Conduct Gap Analysis/Self-Assessment
Planning the Process: Decision Points,

Leadership & Participants, Schedule & Plan
Determining Significant Aspects:

Prioritizing Concerns and Setting
Objectives
Developing Operational Controls
Module 1 - 4

September 2003
EMS Element
Participants
Resources
Schedule
Making Improvements: Evaluating

Alternatives and Setting Targets
Implementation: Building Organizational

Support for Your EMS
Setting Up Environmental Management

Programs; Measuring and Achieving
Success
Establishing Continuing Improvement
Contact Person:
Date Completed:
Module 1 - 5

September 2003
Exhibit 1-2: Sample Worksheet for Persons Responsible for EMS Development
Roles
Individual(s)
Responsible
% of Time
Designated
Budget
Environmental Management Representative (EMR)

having responsibility for implementing the EMS (in small
businesses, this could be the owner).
EMS Coordinator
EMS Team Participants
Conducting Gap Analysis
Identifying and determining significance of environmental
aspects.
Identifying and determining applicability of legal and other
requirements.
Competency-based training.
Operational controls.
Emergency preparedness and response.
Monitoring and measurement of key characteristics of
operations and activities that can have significant
environmental impacts (i.e., the significant environmental
aspects.).
Periodic evaluations of environmental compliance.
Handling and investigating non-conformance with the EMS.
Records management.
Internal EMS audits.
Contact Person:
Date Completed:
Note:
Most of these blocks will be filled in as development of the EMS progresses. This worksheet will help track progress and
serve to remind the team and management of necessary assignments.
Module 1 - 6

September 2003
Exhibit 1-3: Documents/Information to Have Available for ISO 14001 Gap Analysis
1.
2.
3.
4.
5.
6.
7.
General
1.1.
ISO 9000 or QS 9000 program manual and procedures
1.2.
General facility policies and procedures
1.3.
Facility process flow diagrams
1.4.
Current facility corrective actions plans
1.4.1. From audits
1.4.2. From inspections
1.4.3. From risk assessments
1.5. Facility audit results
1.6.
Facility regulatory inspection results
Environmental Policy
2.1.
Draft or final Environmental Policy or Health, Safety and Environmental Policy
Environmental Aspects
3.1.
Lists of prioritized environmental issues/activities
3.2.
Procedures for developing lists of prioritized activities
3.3.
HAZOP Studies
3.4.
Incident Investigations
Legal & Other Requirements
4.1. Environmental compliance files
4.2.
Written guide to compliance files
4.3.
Title V Air Operating Permit (usually identifies applicable regulatory requirements)
4.4.
Mechanism for tracking permits/rules
4.4.1. Subscriptions to regulatory services
4.4.2. Contracts for regulatory updates
4.4.3. Procedures for periodic rule checking
Objectives & Targets
5.1.
Plant-wide environmental goals or objectives
5.2.
Major Capital Projects
5.3.
Procedure for establishing goals and objectives
Environmental Management Programs
6.1.
Management of Change Procedure
Structure & Responsibility
7.1.
Organizational chart
7.2. Job descriptions related to environmental activities
7.3. Mechanisms for making job/task assignments
7.4.
List of regular environmental meetings
7.4.1. Within Environmental Department
7.4.2. With top management
Module 1 - 7

September 2003
8.
9.
10.
11.
12.
13.
14.
Training, Awareness & Competence

8.1.
Descriptions of existing environmental training at the facility
8.2.
Training Matrix
8.3.
Training tracking records
8.4.
Craft Progression Process or Competency Requirements
8.5. Contractor Management/Training Programs
Communication
9.1.
Existing mechanisms for communicating with employees
9.1.1. Bulletin boards
9.1.2. Newsletters
9.1.3. Staff meetings (safety meetings, tool-box meetings, all staff meetings,
etc.)
9.2.
Procedures for updating/posting information
9.3.
Procedures for responding to outside communications (calls, letters, inquiries, etc.)
9.4.
Training for top management on media handling
EMS Documentation
10.1. Examples of other maintained documents (written plans, web-site, procedures)
10.2. Environmental procedures/policy manual or file
Document Control
11.1. Document control policy and procedures
11.2. Scope of current document control program
11.3. Record retention policy/procedures
11.4. Procedure format
Operational Control
12.1. Preventive maintenance schedules and procedures
12.2. Waste minimization/pollution prevention plans
12.3. Process Safety Management Procedures
12.4. Contractor Management/Training Program
12.5. Standard Operating Procedures
Emergency Preparedness & Response
13.1. Copies of emergency plans
13.1.1. SPCC Plan
13.1.2. Storm Water Pollution Prevention Plan
13.1.3. Incident Response Plan
13.1.4. Evacuation Plan
13.1.5. Other emergency plans
13.2. Schedule and procedures for drills (fire, evacuation, spill, etc.)
Monitoring & Measurement
14.1. Examples of current process and environmental measurements
14.2. Calibration procedures and records for monitoring equipment (Preventive
Maintenance Program)
14.3. Facility internal inspection/audit procedures and schedules
Module 1 - 8

September 2003
15. Non-conformance & Preventive Action

15.1. Reports on non-conformances from ISO or QS 90000 audits
15.2. Facility corrective action tracking program
15.3. Incident Investigation Procedure
16. EMS Audits
16.1. Description of ISO or QS 9000 audit program
16.2. Example ISO or QS 9000 audit report and corrective action list
16.3. ISO or QS 9000 audit team membership
17. Management Review
17.1. Management directives on environmental activities
17.1.1. Policies
17.1.2. Mandates
17.1.3. Goals
17.2. List of regular management meetings
Module 1 - 9

September 2003
Exhibit 1-4: Gap Analysis Tool/Self-Assessment Checklist

Facility Name:
EMS Requirement
Date:
Yes
No
Assessor(s):
N/A
Findings/Remarks
Closed

Does your facility have an environmental
policy?
Policy is specific to facility and signed by top
management.
Policy is appropriate to the nature and scale
and environmental impacts of its activities,
products or services.
Policy includes a commitment to continuous
improvement in environmental performance
and prevention of pollution.
Policy includes a commitment to sharing
information on EMS performance with the
community.
Policy includes a commitment to comply with
relevant environmental laws, regulations and
other requirements applicable to the facility.
Policy provides a framework for setting and
reviewing environmental objectives and
targets.
Policy is documented, implemented and
maintained.
Policy is communicated to all employees.
Policy is made available to the public through
display in reception area or by other means.
Facility has a procedure to identify the
activities, products or services that can interact
with the environment (i.e., environmental
aspects) that it can control in order to
determine those which have or can have
significant impacts.
Facility has considered on-site contractor
activities in its significant aspect determination.
Aspects associated with significant
environmental impacts are considered when
setting facilitys environmental objectives.
Module 4: Legal & Other Requirements
Facility has a procedure to identify and have
access to legal and other requirements.
Module 1 - 10

September 2003
EMS Requirement
Yes
No
N/A
Findings/Remarks
Closed
Facility maintains access to all current federal,

state, and local regulations and ordinances
through the computer or by some other means.
Facility has identified environmental objectives
and targets.
Facility has considered technological options,
financial, operational and business requirements
in establishing its objectives and targets.
Facility has considered legal and other
requirements in establishing objectives and
targets.
Facility has considered the views of interested
parties in establishing objectives and targets.
Facility objectives and targets are consistent
with environmental policy.
Module 6: Environmental Management
Programs
Facility has established and maintained
programs for achieving objectives and targets.
New activities, products or services are
reviewed for potential environmental programs
plans and controls.
Facility has identified the means and timeframe for achieving objectives and targets.
Facility has defined roles and responsibilities
for achieving objectives and targets at each
relevant function and level within organization.
Module 7: Structure & Responsibility
Facility has defined the roles, responsibilities
and authorities to facilitate implementation of
the EMS.
Facility management has appointed a
management representative with defined roles
to implement the EMS.
Facility environmental management
representative reports on the performance of
the EMS to top management for review and
continuous improvement.
Module 8: Training, Awareness &
Competence
The organization has performed an
environmental training needs analysis.
Module 1 - 11

September 2003
EMS Requirement
Yes
No
N/A
Findings/Remarks
Closed
Personnel whose work may create a significant

impact or is associated with a significant aspect
have received appropriate training, education
and/or experience to ensure job competence.
Facility has a procedure to make its employees
aware of the importance of conformance with
policy and procedures and the requirements of
the EMS.
aware of the significant impacts associated
with their work, and their roles and
responsibilities as they pertain to conformance
with the environmental policy and the EMS.
aware of the potential consequences of
departure from operating procedures.
Facility has a procedure for internal
communication between the various levels and
functions.
Facility has a procedure for receiving,
documenting and responding to relevant
communication from external parties.
Facility has considered a process for external
communication relative to significant aspects
and recorded decision on how to proceed.
Module 10: EMS Documentation and
Document Control
Facility has information in paper or electronic
form to describe the core elements of the
management system and their interactions.
Facility has information in paper or electronic
form to provide directions on how to find
appropriate documents.
Facility has a procedure for controlling all
documents required by the EMS.
Documents and forms are reviewed for
adequacy by authorized personnel prior to use
or release.
Relevant documents are accessible for the areas
to which they apply.
Obsolete documents are promptly removed
from all points of use or otherwise assured
against unintended use.
Obsolete documents retained for legal or
preservation purposes are properly identified.
Module 1 - 12

September 2003
EMS Requirement
Yes
No
N/A
Findings/Remarks
Closed
Facility has a procedure for defining

responsibility concerning the creation and
modification of documents.
Documentation is legible, dated and readily
identifiable, maintained in an orderly manner
and retained for a specified period.
Facility has identified operations associated
with significant environmental aspects.
Facility has planned maintenance in order to
ensure that they are carried out under specified
conditions.
Operations associated with significant aspects
have documented procedures to cover
situations where their absence could lead to
deviations from the policy, objectives and/or
targets.
Procedures stipulate operating conditions.
Facility has a procedure to identify significant
aspect of goods and services used by the
organization and to communicate relevant
procedures and requirements to the suppliers
and contractors.
Facility has a procedure for prevention of
pollution and waste minimization to
accomplish goal of environmental policy.
Module 12: Emergency Preparedness &
Response
Methods for preventing, mitigating, and
responding to releases that require emergency
response have been established and maintained
at the facility and involve the appropriate
response personnel.
Roles and responsibilities for communications
within the facility and for obtaining outside
support services (e.g., police, fire) have been
established and maintained at the facility.
The emergency preparedness and response
procedures are reviewed and revised as needed,
in particular after an incident occurs.
Facility has documented procedures for
monitoring and measuring key characteristics
of operations associated with significant
aspects.
Module 1 - 13

September 2003
EMS Requirement
Yes
No
N/A
Findings/Remarks
Closed
Facility has established metrics to track

performance, relevant operational controls, and
conformance with objectives and targets.
Monitoring and measuring equipment is
calibrated and maintained as evidenced by
appropriate records.
Facility has documented procedures for
periodically evaluating compliance with
relevant environmental laws and regulations.
Facility has a process for planning, scheduling,
and implementing internal environmental
regulatory compliance assessments, including
the identification of necessary resources.
Managers and/or supervisors are designated to
ensure that control and improvement plans are
established, implemented and monitored.
Module 14: Nonconformance and
Corrective and Preventive Action
Facility has a procedure for defining
responsibility and authority for handling and
investigating nonconformance.
Facility has a procedure for taking action to
mitigate environmental impacts and for
initiating corrective and preventative action.
Each corrective or preventive action is
appropriate in scale to the magnitude of
problems and to the environmental impact.
Facility records and makes changes in
documented procedures resulting from
corrective and preventive actions.
Module 15: Records
Facility has a procedure to identify, maintain,
and dispose of environmental records.
Each activity responsible for maintaining a
record has the responsibility for establishing
the method for filing and indexing the records
for accessibility.
Facility record procedure is consistent with
corporate record retention procedures.
Facility has a program and procedure for
planning, scheduling and implementing
periodic internal EMS audits.
Module 1 - 14

September 2003
EMS Requirement
An audit schedule exists for each activity to be
audited. Audit frequency is based on priority
basis that accounts for previous audit results,
the relative importance of the activity, and is
not be less than once per year for each activity.
A facility audit team has established a checklist
of questions relating to the EMS, which are
reviewed and amended as necessary based on
audit findings and other factors.
The facility has a process for audit results to be
provided to management for review.
Yes
No
N/A
Findings/Remarks
Closed

Management reviews of the EMS are
conducted at set intervals.
The management review addresses the possible
need for changes to policy, objectives, process
and/or other elements of the EMS.
Module 1 - 15

September 2003
EXAMPLES
Example 1-1: Example Schedule for EMS Implementation
ID
1
2nd Quarter 3rd Quarter

4th Quarter
1st Quarter
2nd Quarter
3rd Quarter
4th Quarter
Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
Task Name
Making the Commitment: Creating a Policy
Stament and Determining the Scope
Cross Functional/Implementation Team
Form the team
ISO 14001 Implementation Training
Conduct GAP Analysis / Self Assessme
Develop schedule
Define Role and Responsibilities
Aspects & Significant Aspects
Identify Aspects
10
Legal & Other Requirements
11
Determine Significant Aspects
12
Objectives & Targets
13
Develop Objectives & Targets
14
Submit Aspects, O&T, and Policy for Mg

Review
15
16
17
EMPs
Identify EMP tasks, responsibilities, &
completion dates
Submit EMPs for management review
18
Develop operational controls
19
Develop monitoring & measurement proc
20
Determine roles, responsibilities & autho
21
Training Programs
22
Develop training needs
23
Revise training needs & program proced
24
Internal Auditing
25
Develop procedure, checklist, & schedu
26
Internal Audit Training
27
Conduct audits
28
Corrective & preventive actions
Module 1 - 16

September 2003

Guidance ..................................................................................................................................... 2-2
Tools ............................................................................................................................................ 2-4
Exhibit 2-1: Generalized Environmental Policy Template ............................................ 2-4
Examples..................................................................................................................................... 2-5
Example 2-1 through Example 2-4: Example Die Caster Environmental Policies ..... 2-5
Module 2 - 1

September 2003
GUIDANCE
Your EMS should be based upon a documented and clearly communicated environmental policy.
This policy serves as the foundation for your EMS, and provides a unifying vision of
environmental principles that will guide the actions of employees and management. This policy
statement serves as the framework for setting environmental objectives and targets, and will be
brought to life in your plans and business activities. Note that the scope of your environmental
policy statement also will influence the scope of your EMS.
In order to meet the requirements of ISO 14001, your policy must include the following
elements:
x
x
x
Commitment to continued improvement and pollution prevention;

Commitment to comply with environmental laws and regulations and other requirements
to which your organization subscribes;
Framework for setting and reviewing environmental objectives and targets.
In addition, your environmental policy must be:

x
x
x
Appropriate in nature, scale, and environmental impacts of your facilitys activities,

products, or services;
Documented, maintained, and communicated to all employees; and
Available to the public.
Hints:
x
Apply existing company policies, written or implied. If your current policy is implied,
such as a dedication to meet environmental laws, document the concepts in writing.
Keep your policy simple and understandable, yet explicit. Be direct the wording in
your policy should avoid general statements such as We are committed to excellence
and leadership in protecting the environment unless you can demonstrate how such a
commitment is being met.
The environmental policy can be a stand-alone document or it can be integrated with

your health & safety, quality, or other organizational policies.
Consider involving a wide range of people from your organization to develop your
policy. This approach should increase commitment and ownership.
Module 2 - 2

September 2003
Make sure that your employees understand the policy. Options for communicating your
policy internally include posting it in the shop floor communication center, breakrooms
and bathrooms; using paycheck stuffers; incorporating the policy into training classes and
materials; and referring to the policy at staff or all-hands meetings. Test awareness and
understanding before your audits by asking employees what the policy means to them
and how it affects their work.
The policy also should be communicated externally. You can meet this requirement by
posting a copy of your policy in the reception area of your plant. More aggressive
strategies include placing the policy on business cards, in newspaper advertisements, and
in annual reports. How you communicate your policy should be factored into your overall
strategy for external communication (see later discussion under Communications).
Consider how you would demonstrate that you are living by the commitments laid out in
the policy.
Exhibit 2-1 is a generic example of an environmental policy. In addition, Examples 2-1

through 2-4 are examples of actual die casters policies in use.
REMEMBER: Top management must commit to the environmental policy statement, with the
company president or casting division manager signing and dating it.
Module 2 - 3

September 2003
TOOLS
Exhibit 2-1: Generalized Environmental Policy Template be sure to adapt to your facility.
[YOUR FACILITYS NAME] ENVIRONMENTAL POLICY
[Facility Name] is committed to managing environmental matters as an integral part of our
business planning and decisions. Manufacturing and environmental protection must continue to
be compatible goals. To obtain these goals, we will adhere to the following principles:
COMPLIANCE
We will comply with applicable laws and regulations and will implement programs and
procedures to ensure compliance. [Facility Name] shall promote a workplace in which all
employees are properly trained to comply with environmental requirements and procedures, to
meet environmental program goals, and to take personal responsibility for implementation of the
program.
POLLUTION PREVENTION AND RESOURCE MANAGEMENT
We are committed to pollution prevention and the continual improvement of our environmental
performance.
We will employ management systems and procedures designed to prevent activities and/or
conditions that pose a threat to human health, safety, or the environment, and we will work to
minimize our impact on the environment.
COMMUNICATION
We will communicate our commitment to environmental quality and to our companys
environmental performance to our employees, vendors, customers, and external stakeholders.
CONTINUOUS IMPROVEMENT
We will measure our progress as best we can and report on our efforts on an annual basis. We
will continuously seek opportunities to improve our adherence to these principles and to improve
our environmental performance.
Management at all levels of [Your Facilitys Name] are responsible for ensuring that this policy
is communicated and adhered to by all employees and subcontractors, and that it is made
available to interested members of the public.
{Signature}
President
Date
Module 2 - 4

September 2003
EXAMPLES
Example 2-1: Example Die Caster Environmental Policy
YELLOW DIE CASTING COMPANY

ENVIRONMENTAL MANAGEMENT POLICY
Yellow Die Casting Company intends to meet its customers needs in a manner protective of
Gods creation. It will achieve this in the following ways:
1.
Develop annual safety and environmental goals and plans.
2.
Assess business decisions impacts on the environment.
3.
Conserve energy and reduce waste by recycling or reusing the product.
4.
Ensure the entire plant meets or exceeds the standards of current local, state and federal
laws, environmental regulations and other requirements.
5.
Actively pursue ways to continually improve the manner in which it protects the
environment and prevents pollution.
6.
Continually train employees to carry out this policy.
7.
Measure and report performance to shareholders, employees and the public.
President
Module 2 - 5

September 2003
Blue Diecast Corporation

Environmental Management System Policy
Blue Diecast Corporation believes the health and safety of its employees and the protection of
the natural environment are critical concerns in the operation of its business.
Therefore, it is the policy of Blue Diecast Corporation to:
x
Actively pursue process innovation in order to reduce and eliminate waste from its
operations and prevent environmental pollution.
Routinely review and assess its operations for the purpose of making continual
improvements in areas of health, safety and environmental concern, beyond those legally
required, where such improvements provide significant benefits.
Comply with all applicable laws, regulations and standards in its product development,
manufacturing, marketing and distribution activities.
Using its established EMS policy, this facility will develop annual safety and environmental
goals, and implement action plans in accordance with corporate performance standards to ensure
that its operations comply with this policy.
Blue Diecast Corporation will provide the support and resources necessary, as its commitment to
these goals and objectives.
All employees have been informed of this policy and are expected to incorporate sound health,
safety and environmental practices in the conduct of their jobs.
Module 2 - 6

September 2003
Red Die Casting

Environmental Policy Statement
Red Die Casting Co., Inc. is committed to achieving the highest worldwide environmental
standard. We are concerned for the well being of our employees and our environment. This
policy is designed to address Reds environmental concerns and then insure a continuous
commitment to environmental awareness and excellence.
It is the policy of Red Die Casting Co., Inc. to:
* Comply with all applicable federal, state, and local environmental regulations while also
complying with other voluntary initiatives to reduce our Environmental Impacts.
* Pursue waste minimization and pollution prevention strategies via the implementing and
tracking of targets and objectives that we evaluate quarterly.
* Strive to continually improve our Environmental Management System to become more
efficient and environmentally conscious in our operations.
* Routinely train our employees and communicate with our neighbors the applicable aspects of
Red's Environmental Management System.
In following our Environmental Policy, Red Die Casting Co., Inc., will become a safer and more
environmentally sound company for our employees, customers, suppliers and our community.
_______________________
President
_______________________
Facility Manager
Module 2 - 7

September 2003
ENVIRONMENTAL POLICY
OF
GREEN DIE CASTINGS INCORPORATED
Green Die Castings, Inc. is committed to continually striving to protect its employees and the
environment by being responsive and responsible. In achieving that goal we are committed to
the prevention of pollution and to the continuing effort of improving the processes and
procedures of our facility to be as compatible with our surrounding environment as possible.
To that end, Green Die Castings, Inc. sets out the following Environmental Policy objectives:
1. To comply with any and all applicable laws, regulations, and other applicable
requirements to ensure that our organization is a diligent community partner;
2. To establish procedures by which we can continually set and review our environmental
objectives and goals to evaluate our compliance and conformance;
3. To develop processes to document, implement and maintain our efforts associated with
improving our environmental performance;
4. To create a procedure for effectively communicating this information to the employees of
Green Die Castings, Inc.; and
5. To make information about our environmental management system available to the public.
In following this policy, Green Die Castings, Inc. will become a safer and more environmentally
sound company for our employees, customers, suppliers and our community.
________________________________
President
Module 2 - 8

September 2003

Guidance ..................................................................................................................................... 3-2
Tools ............................................................................................................................................ 3-6
Exhibit 3-1: Sample Procedure for Identification of Environmental Aspects and
Determination of Significant Aspects......................................................... 3-6
Exhibit 3-2: Sample Form for Identification and Significance Determination of
Environmental Aspects ............................................................................... 3-9
Examples................................................................................................................................... 3-11
Example 3-1:
Example 3-2:
Example 3-3:
Example 3-4:
Example 3-5:
The Link Between Aspects and Impacts ............................................... 3-12

Flow Diagrams of Typical Die Casting Processes ................................ 3-13
Identification of Environmental Aspects............................................... 3-16
A Numerical Scoring System Approach ............................................... 3-18
A Second Numerical Scoring System Approach .................................. 3-25
Module 3 - 1

September 2003
GUIDANCE
To plan for and control its environmental impacts, an organization must know what these
impacts are. But knowing what the impacts are is only part of the challenge you also should
know where these impacts come from and which impacts are significant. Stated another way,
how does your organization (i.e., your products, services, and activities) interact with the
environment?
Environmental aspect (EA): An element of a companys activities, products, or services that
can or does interact with the environment (create an environmental impact)
Environmental impact: Any change to the environment, whether adverse or beneficial,
resulting from a companys activities, products, or services
You will need to identify environmental aspects that the organization:
x
x
can control, and

over which it can have an influence.
Your organization is not expected to manage issues outside

its sphere of influence or control. For example, while your
organization probably has control over how much
electricity it buys from a supplier, it likely does not control
or influence the way in which that electricity is generated.
Similarly, if your organization manufactures a product that
is subsequently incorporated into another product (for
example, a bumper that becomes part of an automobile),
your organization does not control the environmental
aspects of that finished product (the automobile). Thus,
your focus should be on the environmental aspects of your
products or services.
D e fin e
e n v ir o n m e n ta l
a s p e c ts
D e c id e if u n d e r
y o u r c o n tr o l
a n d in flu e n c e
Id e n tify r e la te d
im p a c ts
D e fin e
a s p e c ts
The relationship between aspects and impacts is often one of cause and effect. Aspects can be
either positive (such as making a product out of recycled materials) or negative (such as
discharging toxic materials to a stream).
Module 3 - 2

September 2003
Once you have identified the environmental aspects of your products, activities, and services,
you should determine which aspects could have significant impacts on the environment.
Aspects that have one or more significant impacts should be considered significant
environmental aspects. These significant aspects should be considered when you establish
environmental objectives, define operational controls, perform monitoring and measurement,
and consider other actions, as discussed later.
Various techniques can be used to identify environmental aspects and evaluate their aspects. For
the die casting industry, common methods are by mapping the processes involved in a die casting
operation or by looking at materials flow throughout the facility. Process mapping is described
below and in Example 3-3. Using materials flow to define aspects is described in Exhibit 3-1
and in Examples 3-4 and 3-5. An additional method is by looking at your environmental
footprint, a measure of the burden or impact that a product, operation or corporation places on
the environment. Life cycle assessment, which is used to assess the full range of impacts of a
product, from raw material procurement through product disposal, can be used to determine the
environmental footprint. This is a resource-intensive methodology and is described further in
ISO 14040-14048.
Getting Started
x
Start by assembling your Cross Functional Team (CFT) and reviewing Section 4.3.1 of
the ISO 14001 Standard and the associated guidance in Annex A of the Standard. This
section of the standard requires that an organization identify the environmental aspects of
their activities, products and services.
To identify your environmental aspects you will need a detailed understanding of all the
processes and support activities that allow you to generate products and services. To
assist in this process, assemble the following materials:
o Process flow diagrams
o Plant diagrams
o Environmental cost data (waste disposal, permit fees, energy and water use,
consultant fees, training, etc.)
o Material Safety Data Sheets (MSDSs)
o Incident reports (spills, complaints, fires, etc.)
o List of legal and other requirements (see Module 4)
Discuss with the team members the definition of aspects and impacts, and develop a set
of impacts to reference - this will help make your list more consistent. For impacts,
consider (actual or potential):
o Waste (scrap metal, waste paper, etc.)
o Unusable product
o Natural resource use (water, chemicals, landfill space)
o Energy use
o Air emissions
o Impact to surface water or sewer system
Module 3 - 3

September 2003
o
o
o
o
Impact to soil and groundwater (spills/releases)

Noise
Odors
Others (light, radiation, vibration, etc.)
Determine the categories of activities at your facility (e.g., receiving, melting, casting,
parts, trim, machining, inspection, assembly, packaging, and shipping)
Pick one category and sketch a simple flow chart, noting inputs (chemicals, materials,
energy, natural resources) and outputs (product, emissions, wastes). Look at the
various activities (or aspects) associated with the inputs and the impacts (actual or
potential) associated with the outputs. Record the identified aspects and impacts (see
example in Exhibit 3-2).
Remember to look at services as well as products. While the need to examine on-site
operations might be obvious, you also should consider the potential impacts of what you
might do off-site (such as servicing equipment at customer sites). Similarly, the
environmental aspects of the products, vendors, and contractors you use may be less
obvious, but should still be considered. You will also want to consider normal
operating conditions, shut-down and start-up situations, as well as reasonably
foreseeable emergency situations.
Section 4.3.1 of the ISO 14001 Standard requires that organizations consider their
significant impacts when setting objectives and targets. But which impacts are
significant? ISO 14001 does not define the word "significant". Instead, each
organization must determine which of its impacts are significant. Your team therefore
will define the criteria that will be used to determine significance.
o One criterion may be whether or not the associated aspect is subject to
environmental regulation or the subject of already established company policy.
o Another criterion might be tied to the views of interested parties. One of the
commitments of your EMS policy must be good communication with external
stakeholders. Thus, the aspects that they consider important, perhaps ones they
have lodged complaints about, could be significant in your EMS.
o Other criteria often include the magnitude, frequency, and duration of the impact.
Some organizations use a numerical scoring system (see Examples 3-4 and 3-5); others
simply use a criteria based approach.
You may choose to use the procedures and forms in the tools provided at the end of this
section to capture some of your ideas. Using these worksheets will give you a jump
start on implementing this EMS element. You may also refer to Exhibit 3-1 for a
Sample Procedure for Environmental Aspects Identification and Significant Aspects
Determination.
Once you have identified environmental aspects, impacts, and significant environmental
aspects you will use this information as a basis for setting your objectives and targets
which will be discussed in Module 5. You must effectively manage and control all
Module 3 - 4

September 2003
aspects that are significant as a result of being subject to environmental regulations. This
does not mean that you need to improve your performance on all of your significant
aspects at once. There may be good reasons (such as cost, availability of technology, or
scientific uncertainty) for making environmental improvements regarding some
significant aspects now while deferring action on others.
Module 3 - 5

September 2003
TOOLS
Exhibit 3-1: Sample Procedure for Identification of Environmental Aspects and

Determination of Significant Aspects
Purpose
This procedure defines the method for the identification of environmental aspects of the [Your
Facilitys Name] operations and determination of significance for aspects that have actual or
potential significant impacts on the environment.
Procedure for Environmental Aspect Identification
Procedure for
Environm ental
Aspect
Identification
Establish Cross
Functional Team
(CFT)
Determ ine C ore

Processes and
Supporting Activities
Inspect each
Process/Activity and
conduct m aterial
balance
Identify and record

aspects
Responsibilities of the CFT

The facility Cross Functional Team (CFT) led by the
Environmental Management Representative (EMR) or
his designee is responsible for completing the form for
each core process and supporting activity within a
facility. If possible, members of the CFT must conduct
a physical inspection when completing this form. The
completed form is a material balance of a process or
activity and is used to identify Environmental Aspects.
At a minimum, the CFT will review and revise the
completed forms, by means of physical inspection, as
necessary at issuance, annually, prior to and
immediately following implementation of new or
modified processes/activities.
All environmental aspects are evaluated for significance
as defined in the Procedure for Determination of
Significant Environmental Aspects section.
Proceed to
Determ ination of
Significant
Environm ental
Aspects
Module 3 - 6

September 2003
Conducting a Material Balance

The following procedure is used to fill out the Aspect Identification portion of Exhibit 3-2,
Identification and Significance Determination of Environmental Aspects.
The material balance consists of identifying all raw materials, chemicals, and utilities used as
inputs along with their relative usage rates, and all output as product and by-products produced.
The latter is all wastes produced, all recycled materials, water discharges, and air emissions
known for the process(es), and any available rates of production.
For inputs and outputs, identify the category of aspects, the mode of operation under which the
aspect is conducted (normal, startup, shutdown, or emergency), and the quantity or volume used
per month.
Inputs
x Supplies: Enter the major, non-chemical supplies used in the process.
x Chemical: Enter any chemical materials used in the process.
x Energy Use: Enter energy type and usage. (Levels are relative to the facility.)
x Water Use: Enter water type (e.g. city, well, storm, process, chilled) and usage. (Levels
are relative to the facility.)
x Other Input: Enter inputs that are not covered clearly in other categories.
Outputs
x Products: List all products produced by the process specifically produced for sale.
Recyclable and Chemical By-Product (e.g., Rebond) outputs are entered in the waste
section.
x Air Emissions: List all air emissions whether they are drawn directly through a stack or
are discharged into the room and escape as fugitive emissions.
x Noise/Odor/Radiation: Include noise and odor as an air emission if potentially noticeable
outside the facility and list any potential radiation emitted from the facility.
x Water Discharges: Enter all wastewater streams that discharge directly to storm or
sanitary sewer systems or surface waters. Containerized wastewater should be included
in the waste section.
x Solid / Residual Wastes: Wastes are any materials intended to be discarded or disposed
of, whether regulated or not, and include liquids, solids, and gases. Also include recycled
materials, returnable containers, and chemical by-products under this category
x Storm Water Discharges: List all storm water discharges from all process areas
x Spills: Enter all potential spills that might occur in all process areas.
Module 3 - 7

September 2003
Procedure for Determination of Significant Environmental Aspects

Where appropriate, individual aspects can be grouped. (For example, if consumption of energy is
listed as an environmental aspect in several areas, the CFT could choose to group these listings
such that consumption of energy appears just once on a facility-wide form.)
Using the Significance Determination portion of Exhibit 3-2, the CFT or a subset thereof shall
evaluate, using its best judgment, each identified aspect and determine whether or not it is
significant. The environmental aspects of [Your Facilitys Name] may be considered by the CFT
to be significant where the aspect has an impact on the environment and meets one or more of
the following criteria:
1. Subject to specifically relevant legislation, regulation and/or permit requirements that
address significant impacts to the environment. This will likely include aspects
associated with processes and activities if (1) environmental regulations specify controls
and conditions, (2) information must be provided to the authorities, and/or (3) there are or
may be periodic inspections or enforcements by the authorities. Potential aspects that are
subject to environmental regulations in the event of incidents will be recognized as
significant when such as event occurs.
2. Subject to or associated with environmentally-related company goals, directives, policies
or subject to or associated with voluntary covenants to which the company had
committed.
3. Subject to or associated with community concerns, such as those previously expressed in
the form of complaints or critical inquiry. This criterion only shall be reviewed when an
aspect is not significant because criteria 1 or 2 apply.
4. Based on technical and business conditions, has a high potential for pollution prevention
or resource-use reduction. This criterion only shall be reviewed when an aspect is not
significant because criteria 1 or 2 apply.
5. Associated with potential release to the environment from the high environmental loading
due to one or more of the following:
a.
b.
c.
d.
e.
Toxicity (compositional characterization of materials and wastes)

Amounts (volumes and masses of release)
Amounts (consumption of renewable and non-renewable resources)
Frequency of episodes
Severity of actual or potential impacts
This criterion only shall be reviewed when an aspect is not significant because criteria 1 or 2
apply.
Module 3 - 8

September 2003
Frequency
This procedure is to be repeated at least annually, if not more frequently. More frequent updates
apply especially to new project or processes that effect the list of the facilitys significant
aspects.
Records
Exhibit 3-2 is maintained by the Environmental Management Representative (EMR) or his
designee.
Module 3 - 9

September 2003
Exhibit 3-2: Sample Form for Identification and Significance Determination of Environmental Aspects
Person Completing Form:
Area/Process:
I or S
Pollution Prevention
Potential
Potential Release to
the Environment
Community Concern
Company goal or
policy
SD=shutdown,
ST=startup,
NM=normal,
E = emergency
Legal Requirements
Mode
Category/ Aspect
SIGNIFICANCE DETERMINATION
Quantity or
Volume (e.g.
lbs/month)
ASPECT IDENTIFICATION
Date:
Rationale for
Significance (S) or
Insignificance (I)
OBJECTIVES AND TARGETS
Objective & Type

C = control or maintain
S = study or investigate
I = improve
Target
Supplies:
Chemicals:
Energy Use:
Water Use:
Products:
Air Emissions:
Noise/Odor/Radiation:
Module 3 - 10

September 2003
I or S
Pollution Prevention
Potential
Potential Release to
the Environment
Community Concern
Company goal or
policy
SD=shutdown,
ST=startup,
NM=normal,
E = emergency
Legal Requirements
Mode
Category/ Aspect
SIGNIFICANCE DETERMINATION
Quantity or
Volume (e.g.
lbs/month)
ASPECT IDENTIFICATION
Rationale for
Significance (S) or
Insignificance (I)
OBJECTIVES AND TARGETS
Objective & Type

C = control or maintain
S = study or investigate
I = improve
Target
Water Discharges:
Solid Wastes:
Storm Water Discharges:
Spills:
Other inputs and outputs:
Module 3 - 11

September 2003
EXAMPLES
The following examples provide step-by-step guidance on identifying environmental aspects and
determining significance of environmental aspects in the Die Casting Industry.
x
Example 3-1 provides examples of links between aspects and impacts.
Example 3-2 provides several flow diagrams of the main levels (or components) of die
casting activities. A General Operations flow chart is shown, and then specific activities
(aluminum casting and assembly/shipping) are displayed. These charts are from the
NADCA Blueprint to ISO 14001.
Example 3-3 provides an example of the typical environmental aspects associated with
an aluminum die caster. This die caster identified aspects and impacts by looking at the
processes involved in their operation.
Example 3-4 is an example of a numerical scoring system approach used by one die
caster. Both the criteria used (Example 3-4a) and the implementation of the system for
two processes (Example 3-4b) are shown.
Example 3-5 demonstrates a different scoring system used by another die caster.
Module 3 - 12

September 2003
Example 3-1: The Link Between Aspects and Impacts

Aspects
Potential Impacts
Emissions of fugitive dust
Decreased visibility at ground level
Discharges to sanitary sewer
Upsets and disruptions at local Publicly-Owned

Treatment Works (POTW)
Spills and leaks
Soil and groundwater contamination
Electricity use
Air pollution, global warming
Use of recycled paper
Conservation of natural resources
Module 3 - 13

September 2003
Example 3-2: Flow Diagrams of Typical Die Casting Processes
Module 3 - 14

September 2003
Example 3-2: Flow Diagrams of Typical Die Casting Processes (continued)
Module 3 - 15

September 2003
Example 3-2: Flow Diagrams of Typical Die Casting Processes (continued)
Module 3 - 16

September 2003
Example 3-3: Identification of Environmental Aspects of a Die Casting Operation
Module 3 - 17

September 2003
Example 3-3: Identification of Environmental Aspects of a Die Casting Operation

(continued)
Module 3 - 18

September 2003
Example 3-4a: A Numerical Scoring System Approach (Definitions)

Criteria
None = 1
Public Health
no public health impacts;

no awareness or inquiry
Environment
Low = 2
A possibility of minor
public health impacts;
localized public inquiry or
complaints
Environmental impacts not Environmental impacts
expected; no natural
limited to a relatively small
resource damage.
area.
Medium = 3
High = 4
a possibility of moderate
adverse public health
impacts or multiple
complaints
Local environmental
impacts with degradation
of sensitive habitat or
potential impact to natural
resources.
possibility of
fatalities or
widespread human
health effects
Regional or greater
environmental
impacts with severe
impacts to habitat
or extensive impact
to natural
resources.
a low possibility that a law a moderate possibility that the company would
would be broken or low
an environmental law
be likely to be
regulatory action would be could be broken and that served with one or
generally expected
the company would be
more NOVs, fines,
served with a notice of
and/or (a) major
violation (NOV).
legal action(s).
Legal
No regulatory or legal
obligation
Reputation
No possible impact to
reputation
Business
Interruption
(Impact on
Customer)
No potential to shut down Premier's operation

operations.
shutdown without impact
to customer.
Shutdown of Premier's
plant and Shutdown of
customer.
Economic
Operational &
Maintenance
Costs
Criteria
Frequency
Little or no impact on O&M Small impact on O&M (<

$1000)
Moderate impact on O&M Large impact on

($1000 - $10000)
O&M (>$10000)
Low = 1
Under normal operational
mode activity, product or
service (APS) occurs less
frequently than once a
year
Very High = 1
Medium = 2
mode APS occurs monthly
to annually
High = 3
mode APS occurs weekly
to monthly
Very High = 4
Under normal
operational mode
APS occurs weekly
or more frequently
High = 2
Medium = 3
Low = 4
Existing controls are

considered to be
adequately protective of
the public health,
environment, and are
certain to protect against
impact or legal violations
Operational controls are in

place, and are likely to
protect against impact or
legal violations
Limited operational
controls are in place and
there is some uncertainty
regarding the adequacy of
existing controls
No operational
controls are in
place or existing
controls are known
to be inadequate.
Criteria
Control
Low possibility of damage Moderate potential for

to Premier's reputation or local media coverage with
transitory effects only
short term impacts to
Premier's reputation.
the environmental
event could
jeopardize
Premier's license to
operate, receive
national media
attention, or have
long term (beyond
3 months) impacts
to Premiers
reputation.
Shut down of
Premier's plant and
shutdown the
assembly plant.
Module 3 - 19

September 2003
Example 3-4b: A Numerical Scoring System Approach (Implementation)
Control
Natural resource consumption

Frequency
Combine Rank
Natural resource management

Recycle scrap
Check on cost of cardboard & disposal
Check on cost of skids purchased and
recycled
Economic O&M Cost
Steel bands
Plastic bags
Gas
Flux
Refractory
Cer Wool
Cones
Natural gas
Air filters
Oil filters
Ladel lauder elements
Tip lube
Shot beads
Die lube
Anti-solder wax

Score
Business Interruption
Inputs
Aluminum ingots
Scrap (Aluminum)
Cardboard
Skids
Comments
Reputation
Impacts
Legal
Aspects
Aspect Score (1-4)
Environment
Die Cast
Public health
Process/Activity =
1
1
1
1
1
1
2
2
2
2
1
1
1
1
1
1
2
1
1
1
4
4
3
3
11
10
9
9
4
4
3
2
1
1
1
1
44
40
27
18
1
1
1
1
1
1
1
2
1
1
1
1
1
1
1
1
1
2
2
1
1
1
2
1
1
1
2
1
2
2
1
1
1
2
1
1
1
2
1
1
1
1
1
1
1
1
1
1
2
1
1
1
2
1
1
1
1
1
1
1
1
1
4
2
1
1
2
3
1
1
2
1
2
1
1
1
1
3
2
2
2
2
4
2
2
3
2
2
2
1
6
6
12
11
7
7
8
15
7
7
9
8
8
8
7
3
3
4
4
4
3
4
4
2
2
4
3
4
4
4
1
1
2
2
1
1
1
1
1
1
1
1
1
1
1
18
18
96
88
28
21
32
60
14
14
36
24
32
32
28
Module 3 - 20

September 2003

Process/Activity =
WD 40
Beeswax
Die grease
Water
Hot oil
Water glycol
Linkage lube
Quench water
Quench lube
Tapping fluid
Hydraulic fluid
Dies
Mold savers
Compressed air
Nitrogen
Oxyacetylene
Culligan water chemicals
Fire extinguishers
Outputs
Scrap shrink wrap
Steel bands
Flue gases (air
emissions)
Heat (energy)
Dross
Castings
Scrap (Aluminum)
Water + additives
Ladel Lauder elements
Cardboard
Skids
Die Cast
Aspect Score (1-4)

1
1
1
1
1
1
1
2
2
1
1
1
1
1
1
1
1
1
2
1
1
1
1
1
1
2
2
2
2
1
1
1
1
1
2
1
1
1
1
1
1
1
1
2
2
1
1
1
1
1
2
1
1
1
1
1
1
2
1
1
1
2
2
1
1
1
1
1
2
1
2
1
1
1
1
2
1
2
1
1
1
1
2
3
2
1
1
1
1
1
2
1
2
4
3
3
2
2
2
2
3
4
1
3
2
2
2
1
8
6
7
11
8
9
7
11
11
8
10
11
7
8
9
7
9
6
4
3
4
4
4
4
4
4
4
4
4
4
4
4
4
4
3
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
32
18
28
44
32
36
28
44
44
32
40
44
28
32
36
28
27
6
1
1
3
1
1
3
1
1
2
1
1
2
1
1
1
1
1
1
6 4
6 4
12 4
2
2
2
48
48
96
1
1
1
1
1
1
1
1
2
1
1
2
1
1
1
1
2
1
2
1
1
1
1
3
4
4
4
4
2
1
2
1
1
1
1
1
1
2
1
1
1
1
1
1
1
2
3
2
3
3
8
6
7
9
0
7
9
11
3
4
4
1
1
1
64
24
56
36
0
21
36
44
Redundant system
Landfill space reduction

Air quality degradation
Contains vaporized flux, oil, and other

additives

Contract for reclaim
Water quality
Recycle (Re-melt)
See Grounds
Reuse / Contract to recycle
Module 3 - 21

September 2003

Process/Activity =
Die Cast
Aspect Score (1-4)
Used oil filters

Used air filters
Used extinguishers

Chemical reclaim
1
1
1
Contract to outside service
2
2
1
1
1
1
2
2
1
1
1
1
2
2
1
9
9
6
2
2
2
1
1
1
18
18
12
Module 3 - 22

September 2003
Working Dies
Working Dies
Conservation reprocessed
Waste handler / Recycling
1
1
1
2
2
2
2
1
1
1
1
1
1
1
1
1
1
1
2
2
2
2
2
1
1
1
1
2
2
1
1
1
1
1
1
2
1
1
1
1
1
1
2
2
1
1
1
1
1
1
2
1
1
1
1
1
1
2
2
1
2
1
2
2
1
1
1
1
1
1
1
1
1
1
3
2 8 4
2 7 4
1 7 3
2 10 4
2 9 4
1 10 2
2 9 3
2 8 4
2 7 4
2 7 4
3 8 4
2 7 4
1 9 4
1 9 4
1 8 4
1
1
1
1
1
2
1
1
1
1
1
1
1
1
1
32
28
21
40
36
40
27
32
28
28
32
28
36
36
32
32
Combine Rank
Control
Neutralized, waste pond

Cleaning only
Frequency
Carbon
Tig, wire & stick
Economic O&M Cost
Outputs
Steel chips
Production & new
Score
Business Interruption
Inputs
Dies
Steel
Electrodes
Welding supplies
Cutting fluids
Caustic soda
Solvent (stoddard)
Kerosene
Blueing
Grinding stones
Carbide cutting tools
Sanding discs
Hot oil
Water
BeCu Tips
Comments
Reputation
Impacts
Legal
Aspects
Aspect Score (1-4)
Environment
Tool Room
Public health
Process/Activity =
Module 3 - 23

September 2003

Process/Activity =
Tool Room
Scrap metal
Grinding dust (steel)
Scrap cutting tools
BeCu tips
BeCu chips
Caustic soda
Waste Water
Waste Oils
Shop Rags
Conservation
Aspect Score (1-4)

Sold for recycling
Reused / Sold for recycling
Sold for recycling
Neutralized to waste tank
See Grounds
See Grounds
Contract Cleaning Service
1
2
1
1
1
2
1
2
1
1
1
1
1
1
1
1
1
3
2
2
1
1
1
2
1
1
1
1
1
1
2 8 4 1
2 10 4 1
1 6 3 1
1 6 3 1
1 6 3 1
2 11 1 3
0
0
2
7 4 1
32
40
18
18
18
33
0
0
28
Module 3 - 24

September 2003
Example 3-5: A Second Numerical Scoring System Approach

ISO14001 ASPECTS, IMPACTS, AND SIGNIFICANCE REGISTER
1 - ASPECT IDENTIFICATION
FREQUENCY
PROBABILITY
RANKING NUMBER
SIGNIFICANCE
DETERMINATION
OBJECTIVE & TYPE TARGET

M = MAINTAIN OR
CONTROL S =
STUDY OR
INVESTIGATE
I = IMPROVE
POLLUTION
PREVENTION
POTENTIAL
POSSIBLE IMPACT
POTENTIAL
RELEASE TO THE
ENVIRONMENT
SOURCE
PUBLIC CONCERNS
ANNUAL
USAGE
COMPANY
GOALS/POLICY
ASPECTS /
SOURCE
3 - OBJECTIVES &
TARGETS
LEGAL
REQUIREMENTS
CATEGORY
2 - SIGNIFICANCE DETERMINATION
MELT
USE OF NATURAL RESOURCE
Increase net
production yield (S,I)
HARDWARE
ASSEMBLY
(M)
INSERTS
DIE CAST
(M)
(M)
INPUTS:
SUPPLIES: ALUMINUM
1137T
CARDBOARD
CARTONING
SHRINK WRAP
SHIPPING
(M)
BANDING, PLASTIC
SHIPPING
(M)
PALLETS
CARTONING
(M)
MELT OF METAL
SOIL & GROUNDWATER CONTAMINATION
AIR EMISSIONS
M
(M)
TRIM SOLUTION
DEGAS
ALUMINUM
LUBRICANT
(M)
DIE LUBE
LUBRICANT
(M)
ANTI SOLDER WAX
LUBRICANT
(M)
(M)
CHEMICALS: FLUX
NITROGEN
WD-40
LUBRICANT
CLEANERS
PARTS WASHER
(M)
MORPHOLENE
DC MACHINE
Control usage (S,M)
FURNACES
Reduce usage (S,I)
ENERGY NATURAL GAS
Module 3 - 25

September 2003
ISO14001 ASPECTS, IMPACTS, AND SIGNIFICANCE REGISTER
1 - ASPECT IDENTIFICATION
FREQUENCY
PROBABILITY
RANKING NUMBER
SIGNIFICANCE
DETERMINATION
OBJECTIVE & TYPE TARGET

M = MAINTAIN OR
CONTROL S =
STUDY OR
INVESTIGATE
I = IMPROVE
POLLUTION
PREVENTION
POTENTIAL
POSSIBLE IMPACT
POTENTIAL
RELEASE TO THE
ENVIRONMENT
SOURCE
PUBLIC CONCERNS
ANNUAL
USAGE
COMPANY
GOALS/POLICY
ASPECTS /
SOURCE
3 - OBJECTIVES &
TARGETS
LEGAL
REQUIREMENTS
CATEGORY
2 - SIGNIFICANCE DETERMINATION
AIR POLLUTION, GLOBAL WARMING
Reduce usage (S,I)
PROPANE
PLANT-WIDE
USAGE
LIFT TRUCKS
Reduce usage (S,I)
GASOLINE
LIFT TRUCKS
USAGE
8.
0
Prevent any spills or

leaks (S,M)
Reduce usage (S,I)
USE:
ELECTRICITY
WATER USE: CITY WELL
Module 3 - 26

September 2003

Guidance ..................................................................................................................................... 4-2
Tools ............................................................................................................................................ 4-4
Exhibit 4-1:
Exhibit 4-2:
Exhibit 4-3:
Exhibit 4-4:
Exhibit 4-5:
Legal and Other Requirements Worksheet .............................................. 4-4

Information Resources for Legal Requirements ...................................... 4-5
Sample Procedure for Identification of Legal and Other Requirements.. 4-6
Sample Form for Environmental and other Legal Requirements ............ 4-7
Sample Worksheet for Identifying Legal Requirements ......................... 4-8
Examples..................................................................................................................................... 4-9
Example 4-1: Regulatory Checklist for a Die Casting Facility ..................................... 4-9
Legal and Other Requirements
Module 4 - 1

September 2003
GUIDANCE
Setting the legal framework for your EMS

Section 5.4.3 of ISO 14001 requires organizations to define and have access to their legal and
other requirements. Compliance with these legal requirements is one of the main pillars upon
which your environmental policy should be based. The potential costs of non-compliance
(possible damage to the environment, revenue loss and impact on public image, for example) can
be very high.
An effective EMS will build on what you already have and should include processes to:
x
identify and communicate applicable legal and other requirements and
ensure that these requirements are factored into the organizations management efforts.
New or revised legal requirements might require modification of your environmental objectives
or other EMS elements. By anticipating new requirements and making changes to your
operations, you might avoid some future compliance obligations and their costs.
Getting Started
Your EMS should include a procedure for identifying, having access to, and analyzing
applicable legal and other requirements. Other requirements might include industry codes of
practice or similar requirements to which your organization might subscribe.
Legal requirements include, but are not limited to:
x Federal Requirements
x State and Local Requirements
x Permit Conditions
Other requirements might include:
x Customer needs (such as maintaining an ISO 14001 system, packaging, labeling, etc.)
x Parent Company or Corporate requirements
x Industry or trade group codes of practice
x EMS Requirement (like reviewing the legal and other requirements list annually)
x Neighborhood or community associations
Module 4 - 2

September 2003
Exhibit 4-1 will help you get started on evaluating your legal requirements. Identifying
applicable regulations, interpreting them, and determining their impacts on your operations can
be a time-consuming task. Fortunately, there are many sources for obtaining information about
applicable laws or regulations. These sources include:
x
x
x
x
x
x
commercial services (with updates offered on-line, on CD-ROM, or in paper form);

regulatory agencies (federal, state, and local);
North American Die Casting Association;
the Internet;
consultants and attorneys; and
customers, vendors and other companies.
Exhibit 4-2 provides a more comprehensive list. See Example 4-1 for a comprehensive list of
environmental laws applicable to a die casting facility.
Once the applicable environmental requirements have been identified and adopted into the
appropriate operations, communicate these requirements (and plans for complying with them) to
employees, on-site contractors and others, as needed. Communicating other applicable
requirements (as well as their influence on the organization) is an important but often
overlooked step. Keep in mind that different people may have different information needs.
As with many EMS elements, this is not a one time activity. Because legal and other
requirements change over time, your process should ensure that you are working with up-to-date
information. The list of Legal and Other Requirements for your facility should be reviewed and
updated:
x
x
x
x
x
When changes in the plant affect legal status;

When the regulations change;
When permits are renewed or modified;
When customer requirements change (packaging, materials, reporting, etc.); or
Annually.
Module 4 - 3

September 2003
TOOLS
To begin the process of identifying applicable regulations and help determine their impacts on
your operations, it will be helpful to keep a list of answers to the questions in this tool for current
use and future reference.
Exhibit 4-1: Worksheet for Evaluation of Legal and Other Requirements

Do we have an existing process for identifying
applicable legal and other requirements?
If yes, does that process need to be revised? In
what way?
Who needs to be involved in this process within
our organization? What should their
responsibilities be?
What sources of information do we use to identify
applicable legal and other requirements?
Are these sources adequate and effective? How
often do we review these sources for possible
changes?
How do we ensure that we have access to legal and
other requirements? (List any methods used, such
as on-site library, use of web sites, commercial
services, etc.)
How do we communicate information on legal
and other requirements to people within the
organization who need such information?
Who is responsible for analyzing new or modified
legal requirements to determine how we might be
affected?
How will we keep information on legal and other
requirements up-to-date?
Our next step on legal and other requirements is
to
Module 4 - 4

September 2003
Exhibit 4-2 describes a variety of commercial and non-commercial sources of information on

federal and state environmental laws and regulations. This list is not intended to be
comprehensive. Appearance on this list should not be construed as an endorsement by EPA of
any commercial products listed here.
Exhibit 4-2: Information Resources for Legal Requirements

Source
USEPA Web Site
USEPA
Small Business Ombudsman
(1-800-368-5888)
Small Business Assistance
Programs (various states) and
Other State Agencies
US Small Business
Administration
US Government Printing Office
(202-512-1800)
Trade and Professional
Associations
x
North American Die Casting

Association (NADCA)
(847) 292-3600
Counterpoint Publishing
(1-800-998-4515)
Bureau of National Affairs
(1-800-372-1033)
Thompson Publishing Group
(1-800-677-3789)
Business & Legal Reports, Inc.
(1-800-727-5257)
Aspen Law and Business
(1-800-638-8437)
Description
Provides a variety of information on environmental laws and
regulations as well as tools and compliance guidance.
(http://www.epa.gov).
Regulatory explanations and guidance, research, case studies,
contacts for additional information. Variety of hotlines available for
particular statutes (such as RCRA). Internet access also available
(http://www.epa.gov).
Guidance on regulations and compliance issues. Initially focused on
Clean Air Act requirements, but expanding into other environmental
media.
Various services available to small businesses in the US
(http://www.sba.gov).
Federal Register published daily with all federal proposed and final
rules. (Also available on line via GPO Access at
http://www.gpoaccess.gov)
Trade associations provide a variety of services related to
environmental laws and regulations, including regulatory updates
and training.
Regulatory explanations and guidance, research, contacts for
additional information. (http://www.diecasting.org)
CD-ROM and Internet dial-up access to legal / regulatory
information for federal government and all 50 states, updated daily.
Information on EHS laws, regulations and activities at international,
national and state level. Paper and electronic access available.
Manuals on a variety of federal and state environmental programs
with monthly updates and newsletters.
Access to federal and state regulations with monthly, updates on
available on CD-ROM.
Publishes compliance manuals with regular update service for
RCRA and Clean Air Act.
Module 4 - 5

September 2003
The following is a sample procedure for environmental legal and other requirements that
incorporates the principles presented in the guidance.
Exhibit 4-3: Sample Procedure for Identification of Legal and other Requirements
Exhibit 4-4 demonstrates the form used for this procedure.
Purpose
[Your Facilitys Name] is committed to complying with all applicable environmental regulations.
This procedure describes how [Your Facilitys Name] identifies applicable regulations and other
requirements.
Procedure
1. The Environmental Management Representative (EMR) is responsible for tracking
applicable environmental laws and regulations and evaluating their potential impact on
the facilitys operations. He or she employs several techniques to track, identify, and
evaluate applicable laws and regulations. These techniques include commercial
databases, information from the trade association, direct communication with national
and state regulatory agencies, and periodic refresher training on environmental laws.
2. As necessary, the EMR may call upon off-site resources such as consultants or attorneys.
3. The EMR compiles and maintains updated copies of applicable environmental laws and
regulations and other requirements.
4. The EMR, working with the EMS coordinator and cross functional team (CFT),
correlates these regulations to the business activities and environmental aspects
associated with them using Exhibit 4-4.
Frequency
Periodic: Depends on information source.
Records
Exhibit 4-4 is maintained by the EMS coordinator. The EMR maintains access to the applicable
regulations.
Module 4 - 6

September 2003
Exhibit 4-4: Die Casting Industry Operations: Sample Form for Environmental and other Legal Requirements
All*
Medical Facilities for

Employees
Generation of Power,
Compressed Air,
Steam, and Process
Water
Administration
Chemical and Waste

Storage
Tank Farm and Fuel

Transfer
Facility Plant
Maintenance
Purchase of Raw
Material
Facility Support
Secondary Operations
Parts Trim
Welding
Casting
Melting
Production Process
Description
Legal and Other

Requirement
Category/
Aspect
Identification
* Applicable to all components of the facility.

See Example 4-1 on how to fill out this tool.
Module 4 - 7

September 2003
Exhibit 4-5: Sample Worksheet for Identifying Legal Requirements

MEDIA/
PROGRAM
PLANS/
PERMITS
SOURCES/
DISCHARGES
KNOWLEDGE OF
REGULATIONS
MGMT.
PROCEDURES
CAA
SDWA
UIC
FIFRA
NPDES
WETLANDS
RCRA
Generator
Status:
TSCA/PCBS
UST
Module 4 - 8

September 2003
EXAMPLES
Example 4-1: Regulatory Checklist for Die Casting Facilities
Air Emissions
40CFR Part 50
Air Emissions
40CFR Part 51
Air Emissions
40CFR Part 52
NAAQS national
Primary and
Secondary Air
Quality Standards
Emission of
Hazardous Air
Pollutants
Emission of
Hazardous Air
Pollutants
All*
Medical Facilities
for Employees
Generation of
Power, Compressed
Air, Steam, and
Process Water
Administration
Chemical and
Waste Storage
Tank Farm and Fuel

Transfer
Facility Plant
Maintenance
Purchase of Raw
Material
Facility Support
Assembly
Secondary
Operations
Parts Trim
Casting
Melting
Production Process
Description
Legal Requirement
Category
Identification
Module 4 - 9

September 2003
40CFR Part 60
40CFR 60.42c
and 60.43c
(Boiler
emission
standards for
sulfur dioxide
and PM)
Verification of VOC
Emissions
Air Emissions
40CFR Part 63
National Emissions
Standards for
Hazardous Air
Pollutants for Source
Categories
Air Emissions
40CFR Part 68
Chemical Accident
Prevention
Provisions
Air Emissions
40CFR Part 72
Permits (Title V)
Solid/Liquid
Waste
40CFR Part
261-265
Air Emissions
Hazardous Waste
RCRA
All*
Medical Facilities
for Employees
Generation of
Power, Compressed
Air, Steam, and
Process Water
Administration
Chemical and
Waste Storage
Tank Farm and Fuel

Transfer
Facility Plant
Maintenance
Purchase of Raw
Material
Facility Support
Assembly
Secondary
Operations
Parts Trim
Casting
Melting
Production Process
Description
Legal Requirement
Category
Identification
Module 4 - 10

September 2003
Solid/Liquid
Waste
40CFR Part 279
Standards for the

Management of Used
Oil
Solid/Liquid
Waste
40CFR part
265,280
Underground Storage
Tanks (USTs)
Solid/Liquid
Waste
40CFR Part 300
Hazardous Ranking
System (HRS)
Solid/Liquid
Waste
40CFR part 302
Hazardous
Substances and
Reportable Quantities
Solid/Liquid
Waste
40CFRpart 311
Solid/Liquid
Waste
40CFR Part 355
Extremely Hazardous
Substances (EHS)
Solid/Liquid
Waste
40CFR part
265,280
Underground Storage
Tanks (USTs)
Hazardous Materials
Management/Worker
Protection
All*
Medical Facilities
for Employees
Generation of
Power, Compressed
Air, Steam, and
Process Water
Administration
Chemical and
Waste Storage
Tank Farm and Fuel

Transfer
Facility Plant
Maintenance
Purchase of Raw
Material
Facility Support
Assembly
Secondary
Operations
Parts Trim
Casting
Melting
Production Process
Description
Legal Requirement
Category
Identification
Module 4 - 11

September 2003
Solid/Liquid
Waste
40CFR 710
Toxic Substances
Control Act (TSCA)
Solid/Liquid
Waste
CERCLA 103
Hazardous Waste
Storage
Waste Water
Discharge
NPDES State
Permit
Stormwater discharge
permits
Waste Water
Discharge
40CFR Part
121-125
NPDES 122
Stormwater discharge
permits
Waste Water
Discharge
40CFR parts
400-409
Effluent Guidelines
and Standards
Spills
40CFR 112
Oil Spill Prevention

(SPCC)
All*
Medical Facilities
for Employees
Generation of
Power, Compressed
Air, Steam, and
Process Water
Administration
Chemical and
Waste Storage
Tank Farm and Fuel

Transfer
Facility Plant
Maintenance
Purchase of Raw
Material
Facility Support
Assembly
Secondary
Operations
Parts Trim
Casting
Melting
Production Process
Description
Legal Requirement
Category
Identification
Module 4 - 12

September 2003
Casting
All*
PCB Regulations
Medical Facilities
for Employees
40CFR Part 761
Generation of
Power, Compressed
Air, Steam, and
Process Water
PCBs
Administration
Chemical and
Waste Storage
Tank Farm and Fuel

Transfer
40CFR Part 372
Form R (TRI)
Toxic substances
processed or used in
excess quantities
Facility Plant
Maintenance
Emergency
Planning and
Community
Right to Know
Purchase of Raw
Material
Assembly
Facility Support
Secondary
Operations
MSDSs on chemicals
required by OSHA
Parts Trim
29CFR part
1910.1200
and 40CFR Part
370
Melting
Emergency
Planning and
Community
Right to Know
Description
Legal Requirement
Production Process
Category
Identification
* Applicable to all components of the facility
Module 4 - 13

September 2003

Guidance ..................................................................................................................................... 5-2
Figure 5-1: Considerations for Developing Objectives and Targets.............................. 5-3
Tools ............................................................................................................................................ 5-5
Exhibit 5-1: Objectives and Targets Worksheet ............................................................ 5-5
Exhibit 5-2: Sample Procedure for Identification of Objectives and Targets................ 5-6
Examples..................................................................................................................................... 5-7
Example 5-1: Possible Objectives and Targets Organized by Category ....................... 5-7
Objectives and Targets
Module 5 - 1

September 2003
GUIDANCE
Section 4.3.3 of the ISO 14001 Standard requires organizations to establish environmental
objectives and targets. Objectives and targets help an organization translate purpose into action.
Objectives are defined as overall environmental goals arising from the Environmental Policy
that the facility determines to achieve, which are quantifiable where practicable.
Targets are defined as detailed performance requirements (quantified wherever practicable)
based on an Environmental Objective. The Target needs to be set and met in order for the
Environmental Objective to be achieved.
You determine what objectives and targets are appropriate for your organization. These goals
can be applied organization-wide or to individual units, departments, or functions -- depending
on where the implementing actions will be needed.
In setting objectives, keep in mind your environmental policy, including its pillars. You
should also consider your significant environmental aspects, applicable legal and other
requirements, the views of interested parties, your technological options, and financial,
operational, and other organizational considerations. Figure 5-1 summarizes correlations of
the considerations mentioned above.
There are no standard environmental objectives that make sense for all organizations. Your
objectives and targets should reflect what your organization does, how well it is performing, and
what it wants to achieve.
Hints
x
Setting objectives and targets should involve people in the relevant functional area(s).
These people should be well positioned to establish, plan for, and achieve these goals.
Involving people helps to build commitment.
Get top management buy-in for your objectives. This should help to ensure that
adequate resources are applied and that the objectives are integrated with other
organizational goals.
In communicating objectives to employees, try to link the objectives to the actual
environmental improvements being sought. This should give people something
tangible to work towards.
Module 5 - 2

September 2003
Figure 5-1. Considerations for Developing Objectives and Targets
Policy
Environmental
Aspects
Legal / Other
Requirements
Views of
Interested Parties
Objectives
and
Targets
Technology
x
x
x
x
Finance
Operations
Environmental
Management
Program
Other Business
Considerations
Objectives should be consistent with your overall mission and plan and the key
commitments established in your policy (pollution prevention, continual improvement,
and compliance). Targets should be sufficiently clear to answer the question: Did we
achieve our objectives?
Be flexible in your objectives. Define a desired result, then let the people responsible
determine how to achieve the result.
Objectives can be established to maintain current levels of performance as well as to
improve performance. For some environmental aspects you might have both
maintenance and improvement objectives.
Communicate your progress in achieving objectives and targets across the organization.
Consider a regular report on this progress at staff meetings.
To obtain the views of interested parties, consider holding an open house or establishing
a focus group with people in the community. These activities can have other payoffs as
well.
It is best to start with a limited number of objectives (three to five) and then expand the
list over time. Keep your objectives simple initially, gain some early successes, and
then build on them.
Make sure your objectives and targets are realistic. Determine how you will measure
progress towards achieving them.
Module 5 - 3

September 2003
x
x
Keep in mind that your suppliers (of service or materials) can help you in meeting your
objectives and targets (e.g., by providing more environmentally friendly products).
If an environmental aspect is not significant then it does not need an objective and target.
Module 5 - 4

September 2003
TOOLS
Exhibit 5-1: Objectives and Targets Worksheet
Do we have an existing process for setting and reviewing
environmental objectives and targets?
If so, does that process need to be revised? In what way(s)?
Who needs to be involved in this process within our

organization?
Should any outside parties be involved?
When is the best time for us to implement this process?

Can it be linked to another existing organizational process
(like our annual or strategic planning process?)
What are our existing environmental goals? How were

these developed? Who was involved?
What factors were considered in setting these goals?
Who are our interested parties?

How do we obtain their views?
How effective has our process been?
How can we effectively and efficiently track our progress

and communicate the results?
Who is in the best position to do this?
Our next step on environmental objectives and targets

is to
Module 5 - 5

September 2003
Exhibit 5-2: Sample Procedure for Identification of Objectives and Targets

Purpose
[Your Facilitys Name] sets objectives for environmental improvement and develops targets and
action plans to meet those objectives. These objectives are directly related to the companys
significant environmental aspects and follow from its environmental policy commitments.
Procedure
1. Top plant management sets environmental objectives for [Your Facilitys Name] such
that the plant has one or more environmental objectives at any one time. The
environmental objectives and targets are recorded using Exhibit 3-2. For every
significant environmental aspect, an appropriate objective and target will be established
2. The Cross-Functional Team is responsible for developing and recommending potential
new environmental objectives to top plant management. In identifying potential new
objectives, the committee considers the following:
x
x
x
x
x
Environmental policy
The Significant Environmental Aspects of the company.
Applicable laws and regulations and potential future laws and regulations
Practical business criteria, such as the potential costs and benefits of pursuing a
particular environmental objective
The views of employees and other interested parties
3. Once environmental objectives are established by top plant management, the

Environmental Management Representative (EMR) assigns responsibility (to the
manager of the operations in question, where appropriate) for developing targets and
action plans to realize the objectives. Sometimes, this may require an alternatives
evaluation as the first target (or action item). This will be developed in Module 6,
Environmental Management Programs.
Frequency
Environmental objectives are reviewed on a yearly basis. The targets and action plans are
developed and revised as needed by the committee.
Records
Environmental objectives are recorded using Exhibit 3-2 and the targets and Environmental
Management Programs (EMPs) that correspond to each objective are recorded using the
procedure in Exhibit 6-2. The EMR or designee is responsible for maintaining these records.
Module 5 - 6

September 2003
EXAMPLES
Example 5-1: Possible Objectives and Targets Organized by Category
Objectives
Targets
Supplies
Increase use of non hazardous chemicals by
suppliers
Reduce amount of supplies used
x
Chemicals
Reduce usage of hazardous chemicals
x
x
Energy Use
Reduce energy usage
x
x
Increase use of suppliers that provide

alternative chemicals by 15% by January
2005 (based on 2003 production rates)
Increase recycle of supplies (abrasive media,
oil, wood, plastic, laser cartridges, metal,
paint booth water) respectively by January
2004
Implement reuse program by January 2004
Increase use of water soluble cutting fluids
by 15% by January 2004 (based on 2002
usage rates)
Eliminate chlorinated spray degreasers (e.g.,
Brakekleen) by January 2004
Reduce electricity use by 10% by January
2004 (based on 2002 usage rates)
Reduce natural gas use by 15% by January
2004 (based on 2002 usage rates)
Water Use
Reduce water use
Reduce water use by 10% by January 2005

(based on 2003 usage rates)
Air Emissions
Reduce air emissions
Evaluate paving roadways to reduce fugitive

road dust
Noise/Odor/Radiation
Reduce odor releases
Conduct study to identify odor sources by 3rd

quarter 2004
Module 5 - 7

September 2003
Objectives
Water Discharges
Improve process wastewater quality
Improve storm water discharge quality
Solid/Liquid Wastes
Paint waste reduction
Hazardous waste reduction
Spills
Reduce occurrence of spills
Targets
Create water balance through sampling
project by 3rd quarter 2004
Establish water filtering greenbelt along
storm water ditches by summer 2005
Modify purchasing procedures to eliminate
bulk paint purchases when no immediate use
is identified
Reduce hazardous waste 15% by January
2004 (based on 2002 production rates)
Reduce spill occurrence by 10% by January
2004
Module 5 - 8

September 2003

Guidance ..................................................................................................................................... 6-2
Tools ............................................................................................................................................ 6-4
Exhibit 6-1: Environmental Management Program Worksheet................................... 6-4
Exhibit 6-2: Sample Form for Environmental Management Programs ....................... 6-5
Exhibit 6-3: Sample Procedure for Environmental Review for New Purchases,
Processes, and Products ........................................................................... 6-6
Exhibit 6-4: Sample New Purchase Approval Form for Environmental Review of
New Processes, Products, and Activities ................................................. 6-7
Examples..................................................................................................................................... 6-8
Example 6-1: Environmental Management Program for Non-Abated Emissions
of VOCs and HAPs.................................................................................. 6-8
Example 6-2: Environmental Management Program for Solid Waste from the
Unmasking Process................................................................................ 6-10
Module 6 - 1

September 2003
GUIDANCE
Environmental Management Programs (EMPs)
Section 4.3.4 of the ISO 14001 Standard requires an
organization to establish and maintain programs for achieving
its objectives and targets. These are referred to as
Environmental Management Programs (EMPs). EMPs consist
of action plans that are necessary to achieve environmental
objectives and targets. Therefore, your EMPs should be
linked directly to your objectives and targets that is, they
form the bridge between concept and application. Progress
toward objectives and targets should be measurable (see
Module 13, Monitoring and Measurement).
Objectives and
Targets
Established
Environmental
Management Program
Defined
Monitoring and
Measurement
To ensure its effectiveness, your environmental management

programs should define:
x
x
x
the responsibilities for achieving targets (who will do it?)

the steps for achieving targets (how will they do it and
what specifically will be done?)
the time frame for achieving those targets (when?)
If you don't have enough information to create a quantifiable target, then one of the steps of the
program should be to collect data or evaluate the program in order to establish a measurable
target later.
Keep in mind that your EMPs should be dynamic. For example, consider modifying your
programs when:
x
x
x
x
objectives and targets are modified or added;

relevant legal requirements are introduced or changed;
substantial progress in achieving your objectives and targets has been made (or has not
been made); or
your products, services, processes, or facilities change or other issues arise.
Module 6 - 2

September 2003
Your action plan need not be compiled into a single document. A road map to several action
plans is an acceptable alternative, as long as the key responsibilities, tactical steps, resource
needs, and schedules are defined adequately in these other documents.
Hints:
x
x
x
x
x
Build on the plans and programs you have now for compliance, health & safety, or
quality management.
Involve your employees early in establishing and carrying out the program.
Clearly communicate the expectations and responsibilities defined in the EMP to those
who need to know.
Re-evaluate your EMP when you are considering changes to your products, processes,
facilities or materials. Make this re-evaluation part of your change management process.
Keep it simple and focus on continual improvement of the program over time.
In some cases, your environmental management program may encompass a number of existing
operating procedures or work instructions for particular operations or activities. In other cases, new
operating procedures or work instructions might be required to implement the program. There may be
real opportunities here! Coordinating your environmental program with your overall plans and
strategies may position your organization to exploit some significant cost-saving opportunities.
Environmental Review for New Products, Processes, and Activities

Change is an important part of business survival for most companies. Products, technologies,
and ways of doing things are updated regularly. To avoid creating new significant
environmental aspects that must be addressed later, it is helpful to integrate new processes,
products, and activities into the environmental management program that you are developing for
the rest of your company. You can do so by setting up a procedure for reviewing new processes,
products, or activities while they are in the planning stage (see Exhibit 6-3: Sample Procedure
for Environmental Review for New Purchases, Processes, and Products). One way to
accomplish this is to create a sign-off form to be circulated among the people responsible for, or
affected by, the new process or product, including those responsible for the area of the company
where the new process or activity will be implemented.
Module 6 - 3

September 2003
TOOLS
This section provides worksheets and tools to develop an effective environmental management
programs and EMS tracking systems for an environmental review process for new processes,
purchases, and products.
Exhibit 6-1: Environmental Management Program Worksheet

Do we have an existing process for establishing
environmental management programs?
If yes, does that process need to be revised? In what way?
What environmental management programs do we have in

place now?
What is the basis for our environmental management
programs (for example, do they consider our environmental
objectives, our environmental policy commitments and other
organizational priorities)?
Who needs to be involved in the design and implementation

of these programs within our organization?
When is the best time for us to establish and review such

programs? Can this effort be linked to an existing
organization process (such as our budget, planning or
auditing cycles?)
How do we ensure that changes to products, processes,

equipment and infrastructure are considered in our
programs?
How will we otherwise keep our programs up-to-date?
Our next step on environmental management programs is

to
Module 6 - 4

September 2003
Exhibit 6-2: Sample Form for Environmental Management Programs

Area/Department(s):
Process:
Significant Aspect:
Legal & Regulatory Requirement:
Objective:
Target:
Category :
Improve
Control
Investigate
Action Plan:
Task/Action
Items
Responsible
Party
Responsibilities
Resources
Needed
Project
Start Date
Project Completion
Date
Comments/Deliverables
See Example 6-1 and 6-2 on how to fill out this form.
Module 6 - 5

September 2003
Exhibit 6-3: Sample Procedure for Environmental Review for New Purchases,
Processes, and Products
[Note: This procedure will almost certainly need to be substantially modified in order to fit the situation of your
company. Smaller companies may not have a formal new product design or facilities engineering group, for
example. The key is to find a way (that can be documented and verified, if possible) of ensuring that when new
chemicals are being purchased, when new products are being developed, or when a facility is being substantially
modified, environmental considerations are taken into account.
Purpose
When purchasing new chemical supplies, modifying its processes, and making new products, [Your Facilitys
Name] strives to ensure that environmental considerations, particularly those related to significant environmental
aspects (SEAs), are taken into account.
Procedure
1.
When processing an order for a new chemical or other potentially harmful input, the purchasing manager
clears the purchase with a member of the Cross Functional Team (CFT). The CFT member initials the box
marked environmental approval in the New Purchase Approval Form to signify his or her approval of the
purchase.
2.
[Your Facility's Name] has a product development group and facilities engineering group. The product
development group develops potential new products that [Your Facilitys Name] could offer (sometimes
these are identified by the sales and marketing group, sometimes they are identified internally). The
facilities engineering group is responsible for reconfiguring (or, in some cases, expanding) the facilitys
production lines to produce new products.
3.
The product development group notifies a member of the CFT before final approval of a new product
design. The CFT member reviews the design in light of the facilitys SEAs and environmental objectives
and targets. When the committee member is satisfied that the new design is in accordance with the plants
environmental goals, he initials the appropriate box in the Design Approval Form that is sent to the
president for approval.
4.
The facilities engineering group is responsible for notifying a member of the CFT before final approval of
any Facility Modification or Expansion Plan. (The Facility Modification or Expansion Plan is required for
any facilities engineering job that costs more than $20,000.) The CFT member reviews the plan in light of
the facilitys SEAs and environmental objectives and targets. When the committee member is satisfied that
the new design is in accordance with the plants environmental management goals, he initials the
appropriate box in the Facility Modification or Expansion Plan form that is sent to the operations manager
for ultimate approval.
Frequency
As new chemicals are purchased, new products are developed, and/or production lines are modified.
Records
The New Purchase Approval Forms [Exhibit 6-4] are maintained by the purchasing manager. The Design Approval
Forms are maintained by the product development group. The Facility Modification or Expansion Plans are
maintained by the facilities engineering group.
Module 6 - 6

September 2003
Exhibit 6-4: Sample New Purchase Approval Form for Environmental Review of New Processes, Products, and
Activities
This worksheet is an example of a sign-off form that can be used for such reviews. The worksheet is a model that should be modified
to reflect your companys activities and environmental policy.
Area Company
New Process, Product,

or Activity
Contact for form:
Environmental
Review by
Manager/Date
Environmental
Effects
Pollution Prevention Opportunities
Date Completed:
Module 6 - 7

September 2003
EXAMPLES
Example 6-1: Environmental Management Program for Non-abated Emissions of VOCs and HAPs
Area/Department(s): Painting
Process: New Construction Indoor Painting
Significant Aspect: Non-abated emissions of VOCs and HAPs
Legal & Regulatory Requirement: None
Objective: Reduce VOC and HAPs emissions
Target: 10% Reduction by June 2002 (relative to year 2001 baseline)
Category:
Control/Maintain
Improve
Investigate
No. 1 Action Plan: Substitution of Raw Materials

Task/Action Items
Identify list of suitable

vendors that supply low
VOCs paint
Responsible
Party
Resources
Needed
Project Start
Date
Project Completion
Date
John Smith,
Environmental
Manager
MSDS
Paint
Manufacturer
Association
August 1,
2001
October 1, 2001
Comments (C)/Deliverables (D)
D List of potential vendors of low-VOC

paint
Module 6 - 8

September 2003
Task/Action Items
Develop evaluation on
technical feasibility and cost
effectiveness of select paint
products.
Responsible
Party
Resources
Needed
Cross
Functional
Team
Project Start
Date
Project Completion
Date
October 1,
2001
December 1, 2001
D Comparative cost analysis of select

low-VOC paint application
D Technical feasibility analysis of select
low-VOC paint application
No. 2 Action Plan: Process Modification

Task/Action Items
Responsible
Party
Resources
Needed
Project Start
Date
Project Completion
Date
Identify process
modification that can be
done to reduce emissions of
VOC and HAPs
John Smith,
Environmental
Manager
August 1,
2001
August 31, 2001
D List of potential process modification
Develop preliminary
evaluation on technical
feasibility and cost
effectiveness of process
modification alternatives
John Smith,
Environmental
Manager
September 1,
2001
September 30, 2001
D Technical feasibility report of process

Conduct pilot test of the

preferred alternative of
process modification
Kim Weinstein,
Environmental
Department
October 1,
2001
Full scale implementation
John Smith
(Environmental
Department)
and Will Gibson
(Paint
Department)
February
2002
D Comparative cost analysis of process

January 1, 2002
D Workplan of the pilot test

D Weekly progress report of the pilot test
D Final report and recommendation
D Quarterly progress and performance
report
Module 6 - 9

September 2003
Example 6-2: Environmental Management Program for Solid Waste from the Unmasking Process
Area/Department(s): Painting
Process: Block painting process
Significant Aspect: Solid Waste from the Unmasking Process
Legal & Regulatory Requirement: Yes (40CFR, State rules and regulations, company directive)
Objective: Study waste reduction
Target: Complete study by January 2002 (relative to year 2001 baseline)
Category:
Control/Maintain
Improve
Investigate
No. 1 Action Plan: Study of Potential Waste Reduction

Task/Action Items
Responsible
Party
Resources
Needed
Project Start
Date
Project Completion
Date
Identify potential waste

reduction initiative
John Smith,
Environmental
Manger
August 1,
2001
October 1, 2001
D List of steps to be taken to fulfill

initiative and responsibilities

technology to achieve
volume reduction
CrossFunctional
Team
October 1,
2001
October 31, 2001
D List of potential technology

vendors that supply
technology available to
achieve volume reduction
CrossFunctional
Team
November 1,
2001
November 31, 2001
D List of potential vendors of compactors

and waste compaction technology
Module 6 - 10

September 2003
Task/Action Items
Responsible
Party
Resources
Needed
Project Start
Date
Project Completion
Date
February 1, 2001
Develop evaluation on
technical feasibility and cost
effectiveness of select
compacting products
CrossFunctional
Team
December 1,
2001
Present recommendation to
management for waste
reduction
CrossFunctional
Team
March 1,
2001
D Comparative cost analysis of

compactor technology
D Technical feasibility analysis of select
compactor technology
March 31, 2001
D List of evaluations and

recommendations for waste reduction
Module 6 - 11
DieCasting Industry - EMS Template

September 2003

Guidance ..................................................................................................................................... 7-2
Tools ............................................................................................................................................ 7-3
Exhibit 7-1: Structure & Responsibility Worksheet ....................................................... 7-3
Exhibit 7-2: Sample EMS Responsibilities Descriptions ............................................... 7-4
Exhibit 7-3: Sample EMS Responsibilities Form ........................................................... 7-5
Exhibit 7-4: Functions to Include in Your EMS Team and Possible Roles.................... 7-6
Examples..................................................................................................................................... 7-8
Example 7-1: Responsibility Matrix .............................................................................. 7-8
Structure and Responsibility
Module 7 - 1

September 2003
GUIDANCE
Assigning Responsible Persons
As discussed in Module 1, it is important to designate, as soon as possible, the Environmental
Management Representative (EMR), the EMS Coordinator, and a Cross Functional Team (CFT)
who will be responsible for promoting and developing your EMS. It is also important to
designate who will be responsible for other environmental activities. Exhibit 7-1 is a set of
questions for you to consider in establishing the structure and responsibility element of your
EMS. Exhibit 7-2 provides an example description of roles and responsibilities associated with
an EMS that can be placed in your facilitys EMS Manual. When complete, Exhibit 7-3 can
provide documentation of who in your facility will fill key EMS roles.
Throughout the process of assigning responsible persons in the EMS, it is important to take into
consideration the job functions and skills that would make a strong contribution to the EMS
team. Exhibit 7-4 provides a list to help identify these skills. However, the list does not suggest
that a company would need all of these skills.
One use of this information is to create a responsibility matrix that shows which employees are
responsible for which aspects of the EMS. This will help to clarify roles. An sample form for a
die casting facility is shown in Example 7-1.
Module 7 - 2

September 2003
TOOLS
Exhibit 7-1: Structure & Responsibility Worksheet
How do we define roles, responsibilities, and authorities
for environmental management now?
Is this process effective?
Who is / should be our EMS Management Representative?

Does this individual have the necessary authority to carry out
the responsibilities of this job?
Are our key roles and responsibilities for environmental

management documented in some manner? If so, how (e.g.,
job descriptions, organizational charts, responsibility matrix,
etc.)?
How are EMS roles and responsibilities communicated

within our organization?
How do we ensure that adequate resources have been

allocated for environmental management? How is this
process integrated with our overall budgeting process?
How are environmental expenditures tracked?
How will we keep this information up-to-date?
Our next step on structure and responsibility is to
Module 7 - 3

September 2003
Exhibit 7-2: Sample EMS Responsibilities Descriptions

[Your Facilitys Name] has established an Environmental Management Representative (EMR),
an EMS Coordinator, and a Cross Functional Team (CFT) with the following responsibilities:
x
Environmental Management Representative. The EMR is the member of [Your Facilitys

Name] top plant management group responsible for the functioning of the EMS. It is his
or her job to ensure that all tasks relating to the EMS are identified and completed in a
timely manner. He or she is also responsible for reporting periodically to the top plant
management group on the progress and results of the EMS.
EMS Coordinator. The EMS coordinators responsibility is to identify, assign, schedule,

provide the necessary support for, and ensure completion of all tasks relating to the EMS.
The coordinator works closely with the management representative and with the
committee. The EMS coordinator is also responsible for maintaining this manual, under
the leadership of the management representative. The functions of coordinator and EMR
may be filled by the same person.
Cross Functional Team. The CFT (which also serves as the plants safety committee) is
composed of 6-8 supervisors and employees from major groups or areas within the plant.
The CFT is responsible for ensuring that EMS activities in their areas are carried out and
for reporting the results of these activities to the committee as a whole. In addition, the
CFT itself undertakes certain EMS activities such as the selection of significant
environmental aspects. The CFT meets to discuss the EMS on at least a monthly basis.
Records
The EMS coordinator maintains an updated list of EMR, EMS coordinator, and CFT members
using Exhibit 7-2, EMS Responsibilities Form.
Module 7 - 4

September 2003
Exhibit 7-3: Sample EMS Responsibilities Form

The following table lists [Your Facilitys Name] Environmental Management Representative,
EMS Coordinator, and Cross Functional Team:
EMS Function
Environmental Management
Representative
Name
Regular Position
EMS Coordinator
Cross Functional Team
Module 7 - 5

September 2003
Figure 7-4: Functions to Include in Your EMS Team and Possible Roles
Company Function
Production
Expertise Brought to Project Team

Management of environmental aspects of production
How They Can Help (Possible Roles)

Help identify aspects; provide input to objectives
and targets; participate in environmental
management programs; serve as trainers and internal
auditors; help carryout corrective and preventive
action
Maintenance
Management of environmental aspects of equipment

maintenance
Implement preventive maintenance program for key

equipment; support identification of environmental
aspects
Facilities Engineering
Management of environmental aspects of new construction

and installation/ modification of equipment
Consider environmental impacts of new or modified

products and processes; identify pollution prevention
opportunities
Storage/Inventory
Management of environmental aspects of raw material and

product storage and in-facility transportation

action
Shipping, Receiving,
Transportation, Logistics
Management of environmental aspects of shipping,

receiving, and transportation

action
Product Design
System for examining environmental aspects of new

designs
Participating in product-related objectives, targets,

and EMPs
Quality
Quality management system, including document control

procedures
Support document control, records management, and

employee training efforts; support integration of
environmental and quality management systems
Module 7 - 6

September 2003
Company Function
Human Resources
Expertise Brought to Project Team

Training on environmental issues
Inclusion of environmental incentives in performance
measurement system
Environmental
System for complying with environmental regulations

Management of environmental records
How They Can Help (Possible Roles)

Define competency requirements and job
descriptions for various EMS roles; train temporary
workers and contractors; maintain training records;
integrate environmental management into reward,
discipline, and appraisal systems
Provide an organizational and functionary role in
establishing and maintaining the EMS.
Purchasing
System for procurement (including screening of suppliers,

material composition of components)
Develop and implement controls for chemical / other

material purchases and for communicating
requirements to contractors and suppliers
Sales/Marketing
Environment-related commitments to customers
Assist communications with external stakeholders
Public Relations
System for communicating with public on environmental

issues
Assist communications with external stakeholders
Accounting/Finance
System for tracking environmental costs of operations
Track data on environmental-related costs (such as

resource, material, and energy costs, waste disposal
costs, etc.); prepare budgets for environmental
management program; evaluate economic feasibility
of environmental projects
Line Workers
Thorough knowledge of processes and operations
Provide first-hand knowledge of environmental

aspects of their operations; support training for new
employees
Top Management
Capability for ensuring continual improvement
Communicate importance of EMS throughout

organization; provide necessary resources; track and
review EMS performance
Module 7 - 7

September 2003
EXAMPLES
Legend: L=Lead Role

S=Supporting Role
EMS
Manager Rep.
Employees
Conform with organization's

EMS requirements
Obtain permits and develop

compliance plans
Prepare reports required by

regulations
Coordinate communications
with interested parties
S
S
Train employees
Integrate environmental into

recruiting practices
Integrate environmental into

performance appraisal process
Communicate with contractors

on environmental expectations
Maintain equipment / tools to

control environmental impact
Monitor key processes
Coordinate emergency
response efforts
Identify environmental aspects

of products, activities, or
services
Production
Supervisor(s)
Track/analyze new regulations

(and maintain library)
Engineering
Coordinate auditing efforts
Purchasing/
Materials
Maintenance
HR
Manager
EHS
Manager
Comply with applicable

regulatory requirements
Communicate importance of
environmental management
Plant
Manager
Finance
Example 7-1: Responsibility Matrix
Module 7 - 8
Develop budget for

environmental management
Maintain EMS records

(training, etc.)
Coordinate EMS document

control efforts
Employees
EMS
Manager Rep.
Finance
Production
Supervisor(s)
Engineering
Purchasing/
Materials
Maintenance
HR
Manager
EHS
Manager
Establish environmental
objectives and targets
Plant
Manager

September 2003
S
L
Module 7 - 9

September 2003

Guidance ..................................................................................................................................... 8-2
Figure 8-1: Two Areas of EMS Training....................................................................... 8-3
Tools ........................................................................................................................................
8-5
Exhibit 8-1: Training, Awareness & Competence Worksheet........................................ 8-5

Exhibit 8-2: Sample Training Needs Analysis Form ...................................................... 8-6
Examples..................................................................................................................................... 8-7
Example 8-1: Training Needs Analysis Form................................................................ 8-7
Training, Awareness, and Competence
Module 8 - 1

September 2003
GUIDANCE
Section 4.4.2 of ISO 14001 requires organizations to identify training needs and to establish
training procedures. It requires that all personnel whose work may create a significant impact on
the environment receive appropriate training. Personnel performing the tasks which can cause
significant environmental impacts must be competent on the basis of appropriate education,
training, and/or experience.
Every employee should be aware of the environmental policy, the significant environmental
impacts of their work activities, the key EMS roles and responsibilities, the procedures that apply
to their work, and the importance of conformance with EMS requirements. Employees also
should understand the potential consequences of not following EMS requirements (such as
spills, releases, and fines or other penalties).
Training should be tailored to the different needs of various levels or functions in the
organization. However, training is just one element of establishing competence, which is
typically based on a combination of education, training, and experience. For certain jobs
(particularly tasks that can cause significant environmental impacts), you should establish criteria
to measure the competence of individuals performing those tasks.
Training is needed both in technical work and for general awareness on the part of all employees.
Module 8 - 2

September 2003
Figure 8-1. Two Areas of EMS Training
AWARENESS
(ALL EMPLOYEES)
TASK SPECIFIC
For employees
associated with
Significant Aspects
The following are some examples of areas where training is needed:

x
x
x
x
x
x
legal requirements,
ability to recognize new problems,
technical skills needed to solve problems,
procedures to implement operational controls,
any new procedures or needs related to significant environmental aspects, and
awareness of the companys environmental policy and the EMS and its objectives
Hint
x
Dont overlook the need for on-going training when experiencing employee turnover. Be
sure that new employees are trained soon after they arrive.
Go through the Action Steps listed below and use Exhibit 8-1 to help you identify, plan for, and
track the training needed to assist in developing and putting your EMS in place. You will
probably be able to identify some general training needs now, but will need to return to this
module to add specific technical training needs that may be identified as you proceed with the
EMS. Exhibit 8-2 is a sample Training Needs Analysis Form.
Module 8 - 3

September 2003
Action Steps
x
Identify all job functions that affect the environment. Small companies may wish to
identify individuals. Identify who is responsible for employee health and safety.
Identify the training and type of training these people currently receive that relates to
environmental and health and safety concerns.
Determine if EMS education could be included in this training or whether there should be
special EMS training, at least in the beginning.
Identify training materials or programs available outside your company. Some places to
check include:
o
o
o
o
o
o
Trade Associations
Small Business Administration
EPA materials
State Departments of Environmental Protection
Suppliers
Certified Contractors
Module 8 - 4

September 2003
TOOLS
Exhibit 8-1: Training, Awareness & Competence Worksheet

Do we have an existing process for environmental training?
If so, does that process need to be revised? In what way(s)?
What types of training do we provide now (e.g., new

employee orientation, contractor training, safety training)?
How would EMS-related training fit with our existing training
program?
Who is responsible for training now? Who else might need

to be involved within our organization?
How do we determine training needs now? (List methods

used) Are these processes effective?
Who is responsible for ensuring that employees receive

appropriate training? How do we track training to ensure we
are on target?
How do we evaluate training effectiveness? (List methods

used, such as course evaluation, post-training testing, behavior
observation)
How do we establish competency, where needed? (List

methods used, such as professional certifications)
What are the key job functions and activities where we need
to ensure environmental competency?
Our next step on training, awareness & competence is to
Module 8 - 5

September 2003
Exhibit 8-2: Sample Training Needs Analysis Form

Jobs Affecting
Environment
Training Needs
Contact Person:
How to Train
When/ Length
Budget
Completion
Date
Who is
Responsible
Date Completed:
See Example 8-1 on how to fill out this form.
Module 8 - 6

September 2003
EXAMPLES
Example 8-1: Training Needs Analysis Form
Jobs Affecting Environment
Training Needs
Staff EH&S Person
Production Employees
Emergency Preparedness &

Response
Contact Person:
How to Train
Staff Training
Session
When/ Length
Once/ Two hrs.
Completion
Date
Budget
?
Who is
Responsible
?
Date Completed:
Module 8 - 7

September 2003
Guidance ..................................................................................................................................... 9-2
Figure 9-1: Levels of Stakeholder Interest..................................................................... 9-3
Tools ............................................................................................................................................ 9-6
Exhibit 9-1:
Exhibit 9-2:
Exhibit 9-3:
Exhibit 9-4:
Communication
Communications Worksheet...................................................................... 9-6

Sample Procedure for Communication with Stakeholders ........................ 9-7
Sample Form for Stakeholders and Environmental Issues ........................ 9-8
Sample Form for Stakeholder Communication Record............................. 9-9
Module 9 - 1

September 2003
GUIDANCE
Section 4.4.3 of the ISO 14001 Standard requires organizations to establish procedures for
internal and external communication of environmental activities. This communication should:
x
x
x
x
Demonstrate managements commitment to the environment;

Make others aware of the organizations environmental policy and commitment to the
environment;
Address concerns about the organizations environmental activities by external parties;
and
Establish a line of communication that clearly defines emergency responsibilities.
Identifying Stakeholders
Stakeholders include anyone who has a stake in your companys environmental performance.
This group can play an important role in helping your company develop an EMS. Employees
have strong stakeholder interest in your company and can provide substantial support for EMS
development. Customers, suppliers, and neighbors can provide useful inputs. In addition,
establishing partnerships with trade associations, suppliers, professional associations, and
community colleges can be very helpful in developing parts of your EMS.
The following list provides types of stakeholders:
Internal Stakeholders
x Employees
x Shareholders
x Customers
x Suppliers
x Investors & Insurers
x Trading Partners
Communication
External Stakeholders
x Neighbors
x Community Organizations
x Environmental Groups
x Larger Companies
x The Media
x The General Public
Module 9 - 2

September 2003
How to Work With Your Stakeholders

The next stage of the process is to establish dialogue with stakeholders. You may view this as an
opportunity to further refine your understanding of the various interests of the groups. You
might think about the different kinds of stakeholders as forming ever-broader circles around your
business (see Figure 9-1). Begin with the innermost circle and work outward.
Figure 9-1. Levels of Stakeholder Interest
Neighbors
Customers/
Staff
Suppliers
Communication
Module 9 - 3

September 2003
Communications
When working with either internal or external stakeholders, including your Cross Functional
Team (CFT), effective communication will facilitate a smooth implementation of your EMS.
You will want to follow these effective rules of communication:
1. Begin early in the process. Let people know what you are doing. In most cases, you
will need the cooperation of several people within your company to gather information
and develop an EMS that will work. In small and large organizations alike, early
communication will pay off in greater acceptance of the resulting system.
2. Set your communication objectives. Decide what you want to achieve in your
communication. Setting this goal will help you get the right message across without
overwhelming people with too much information, spending too much time, or missing
the mark. It is helpful to create an EMS communication procedure for your company.
The procedure should outline what kinds of information will be communicated to
external stakeholders, and how the company will document and respond to
communications from external stakeholders. The procedure should include who reports
what, to whom, and when.
3. Communicate regularly and integrate EMS communication. To build support for the
EMS, try to communicate on a regular basis. Some simple means of regular
communication can usually be accomplished without straining resources for example, a
bulletin board posting, email messages, or articles in the organization newsletter. Dont
forget to consider direct word-of-mouth communication, particularly in smaller
organizations. Talking directly with key individuals at regular intervals may be the best
mechanism for ensuring good communication. Use existing channels of communication
to get the message out on your EMS activities.
Consider various methods of communication when informing stakeholders about your
company and what you are doing, or plan to do, to protect the environment. Methods
may include:
x
x
x
x
x
discussion in company meetings;

updating the company website;
scheduling tours of your facility;
producing a fact sheet about your facilitys activities, the EMS program, and why
and how your company would like to include stakeholders; and
holding public meetings when you feel it is appropriate.
4. Track communication from stakeholders to your company and the response made
to that communication. A procedure for documenting and responding to stakeholder
Communication
Module 9 - 4

September 2003
communication should be established and a person appointed to be responsible for

carrying it out.
Note: Section 4.4.3 of the Standard states that the organization shall consider processes for
external communication on its significant environmental aspects and record its decision. You
may choose to review requests for information on an individual basis and communicate and
record your decision. Typically a facility will do its best to respond in kind to all good-faith
communications from stakeholders about environmental issues, including complaints, comments,
and information requests. However, your facility may not choose to respond in all cases,
particularly if the request is made in bad faith or if sensitive information is requested.
Exhibit 9-1: Communications Worksheet is a set of questions to help you structure your
communications approach and lead to improvements. Exhibits 9-2 and 9-3 provide a sample
procedure and form for tracking communication with stakeholders.
Communication
Module 9 - 5

September 2003
TOOLS
Exhibit 9-1: Communications Worksheet

Who are our key external stakeholders?
How were these stakeholders identified?
With regard to our organization, what are the key concerns of

these stakeholders?
How do we know this?
What community outreach efforts are we making now (or

have we made in the recent past)?
How successful have these efforts been?
What methods do we use for external communications?

Which appear to be the most effective?
Who has primary responsibility for external communications?
How do we gather and analyze information to be
communicated?
Who has responsibility for this?
How do we communicate internally (as well as with our

suppliers and contractors)? What processes do we have to
respond to internal inquiries, concerns and suggestions?
How effective are these methods?
Our next step on communication is to
Communication
Module 9 - 6

September 2003
Exhibit 9-2: Sample Procedure for Communication with Stakeholders

Purpose
To ensure that interested external stakeholders receive appropriate information about the
facilitys environmental activities.
Procedure
1. The Cross Functional Team (CFT) identifies stakeholders and their potential interests in
the environmental performance of our Facility using Exhibit 9-3, Stakeholders and
Environmental Issues. If the CFT decides that proactive communication on
environmental issues is necessary with any group, that decision is recorded on Exhibit
9-4 and responsibility is designated.
2. When any form of communication is received regarding the corporations environmental
performance or management from a stakeholder, that communication is immediately
forwarded to the Environmental Management Representative (EMR).
3. The EMR considers the nature of the communication and makes a decision on whether
and how to respond to it based on the guidance in Exhibit 9-3. The EMR is responsible
for maintaining records of each such communication and response using Exhibit 9-4,
Stakeholder Communication Record. Where internal actions are necessary to address the
communication, this is noted on Exhibit 9-4 and a Corrective Action Form (Exhibit 14-3)
is initiated.
Frequency
As per environmental communication.
Records
Records of environmental communications from stakeholders and your corporations responses
are kept by the EMR and are tracked using Exhibit 9-4. An updated version of Exhibit 9-3,
Stakeholders and Environmental Issues, is kept in this manual.
Communication
Module 9 - 7

September 2003
Exhibit 9-3: Sample Form for Stakeholders and Environmental Issues

Stakeholder
Contact Person:
Communication
Potential Environmental Interest
Proactive Communication Plan

(if desired)
Person Responsible
Date Completed:
Module 9 - 8

September 2003
Exhibit 9-4: Sample Form for Stakeholder Communication Record

Date Communication Received
Type of Communication
Received From
Address/Telephone Number/
E-Mail
Content of Communication (attach copy if possible)
Will [Your Facilitys Name] Respond?
YES
NO
Date of Response
Person Responding
Position
Nature of Response (attach copy if possible)
Are Internal Actions Necessary?(If Yes, fill out a Corrective Action Form.)
Contact Person:
Communication
Date Completed:
Module 9 - 9

September 2003
Module 10: EMS Documentation and Document Control

Guidance ................................................................................................................................... 10-2
Tools .......................................................................................................................................... 10-6
Exhibit 10-1: EMS Documentation Worksheet ............................................................ 10-6
Exhibit 10-2: Sample Worksheet for Development of EMS Documentation............... 10-7
Exhibit 10-3: Sample Outline for EMS Manual and Other EMS Documents .............. 10-8
Exhibit 10-4: Sample Procedure for Documentation.................................................... 10-9
Exhibit 10-5: Document Control Worksheet .............................................................. 10-10
Exhibit 10-6: Sample Procedure for Document Control ............................................ 10-11
Exhibit 10-7: Sample Document Control Form.......................................................... 10-12
Exhibit 10-8: Sample Document Index Form............................................................. 10-13
EMS Documentation and Document Control
Module 10 - 1

September 2003
GUIDANCE
Requirements for system documentation are presented in several sections of ISO 14001,
including Section 4.4.4 Environmental Management System Documentation and Section 4.4.5
Document Control.
Documentation is important to the success of your EMS for several reasons:
x
x
x
Word-of-mouth information is not as reliable as written documentation.

Creating documentation helps you assess the progress of your EMS and evaluate results.
Documentation is vital to maintaining consistency in an EMS over time and from
department to department. In most companies, change is a fact of life; new products are
developed, the company grows, and employees change positions or leave the company.
Accurate documentation will make it much easier to maintain an effective and flexible
EMS during these changes.
The EMS Manual

An EMS manual provides a place to identify all relevant environmentally significant procedures
and practices in a single source. The EMS manual typically does not house the complete EMS
documentation but is rather used as a road map to other associated documents. It should describe
what the EMS consists of, where other related documents are located, and where records of
performance can be found. It should be a one-stop-shopping outline of all other sources of EMS
paperwork. For most companies this will be a simple binder, for others it may be a web site.
Other EMS Documentation

In addition to the EMS manual, your organization should maintain other documentation of its
EMS. First, you should document the processes used to meet the EMS criteria. (For example,
How do we identify environmental aspects? How do we implement corrective actions?)
This documentation generally takes the form of system procedures. In addition, you might
maintain area-or activity-specific documentation (such as work instructions) that instructs
employees on how to carry out certain operations or activities.
EMS documentation is related to (but not the same as) EMS records. EMS documentation
describes what your system consists of (i.e., what you do and how you do it), while EMS
records demonstrate that you are doing what the documentation said you would do. Document
control and records management are discussed later in this Module.
Module 10 - 2

September 2003
How to Develop Your Documentation

Step 1: Determine how EMS documentation can be integrated into existing documents.
Before you dive into your documentation, learn how deep the water is. Find out what
documentation already exists, what its purpose is, and whether it works. The goal of this search
is to locate materials you can use to begin your EMS implementation and documentation. Many
facilities use the same format for all their documents. An example of existing documentation
might be a quality plan or tracking report. See Exhibit 10-1 through Exhibit 10-4 to assist you
in developing EMS documentation while following these steps.
Hints
x
Keep EMS documentation simple. Choose a format that works best for your
organization. Your manual does not need to describe every detail of your EMS. Instead,
the manual can provide references to other documents or procedures.
Use the results of your preliminary assessment to prepare your EMS documentation.
In the course of conducting this assessment, you should have collected or prepared useful
material on how your organization satisfies the selected EMS criteria. The box on the
next page illustrates what constitutes EMS documentation.
The usefulness of your EMS manual can be improved by including the facilitys mission
statement and vision or guiding principles (if these exist). These will improve
understanding of the organization and how the EMS supports its overall goals.
An EMS manual can be a useful tool for explaining your EMS to new employees,
customers, and others.
EMS documentation should be updated as needed, based on any system improvements you put in
place. However, if you put too much detail in an EMS manual, you might need to update the
manual frequently.
Module 10 - 3

September 2003
Step 2: Tailor the documentation to your organizations individual needs.

Here are some questions to help you determine what fits your needs:
x
x
x
x
How can you incorporate documents that already exist rather than creating new ones?
Does your business operate in a single location or many? This will affect who creates
some of the documents and where they are located. It may also affect how many versions
of a document might be necessary to cover different circumstances.
What is your current computer capability? Many companies use an electronic system to
maintain documents.
What security precautions do you need? As a computer system becomes larger and can
be accessed by more people, electronic information can more likely be edited and
destroyed. Security, or at least restrictions on who can change data, can be a critical issue
for many companies.
Step 3: Determine a standard format for all documents.

Before developing your EMS documents, plan the format (document and page appearance). If a
company standard exists, use it. If not, the need for EMS documentation provides an opportunity
to create a standard company format. Consider whether pages are single- or double-sided and
why; choose margins, header, footer, typefaces, text, headings, etc. Include plans for bulleted
and numbered lists, tables, and even paragraph spacing. Once you have a consistent format for
documents, anyone who writes one will use the established electronic format and fill in the
necessary text. All documents will look like part of an organized, integrated system. Most
important, documents will be easier to read and understand!
What Constitutes EMS Documentation?

Consider the following:
x
your environmental policy
your organizational structure and key responsibilities
a description or summary of how your organization satisfies EMS

requirements (e.g., How do we identify environmental aspects?
How do we control documents? How do we comply with legal
requirements?)
system-level procedures (e.g., procedure for corrective action)
activity- or process-specific procedures/work instructions
other EMS-related documents (such as emergency response plans,

training plans, etc.)
Module 10 - 4

September 2003
Step 4: Controlling Documents

To ensure that everyone is working with the proper EMS documents, your organization should
have a procedure that describes how such documents are controlled. Implementation of this
procedure will ensure the following:
x
x
x
x
EMS documents can be located (we know where to find them),

they are periodically reviewed (we check to make sure they are still valid),
current versions are available where needed (we make sure the right people have access
to them), and
obsolete documents are removed (people wont use the wrong documents by mistake).
Your procedure should designate responsibility and authority for preparing documents, making
changes to them and keeping them up-to-date. In other words, you need to make it clear who can
actually generate and change documents and the process for doing so.
Hints
x
Dont make your procedure more complicated than it needs to be. While larger
organizations often have complex processes for document control, smaller organizations
can use simpler processes.
Limiting distribution can make the job easier. Could everyone have access to one or a
few copies? Determine how many copies you really need and where they should be
maintained for ease of access.
Consider using a paperless system through a local area network or the organizations
internal web site. There also are a number of commercial software packages that can
simplify the document control effort.
Prepare a document control index that shows all of your EMS documents and the history
of their revision (see Exhibits 10-7 and 10-8). Include this index in your manual. Also,
if multiple paper copies of documents are available at the facility, prepare a distribution
list, showing who has each copy and where the copies are located.
As your procedures or other documents are revised, highlight the changes (by
underlining, boldface, etc.). This will make it easier for readers to find the changes.
Module 10 - 5

September 2003
TOOLS
This section provides tools to develop EMS documentation.
Exhibit 10-1: EMS Documentation Worksheet

Do we have existing documentation of our EMS?
If yes, how is this EMS documentation maintained?
(Electronically? In paper form?)
Who is responsible for maintaining EMS documentation

within our organization?
Do we have an EMS manual or other summary document

that describes the key elements of the EMS?
If so, does this document describe the linkages among
system elements?
What does our EMS documentation consist of? (List

components such as environmental policy, EMS manual,
activity-level procedures or work instructions, emergency
plans, etc.)
Is our EMS documentation integrated with other

organizational documentation (such as human resource
plans or quality procedures)?
If so, how do we ensure proper coordination between
environmental and these other functions?
How will we keep our EMS documentation up-to-date?
Our next step on EMS documentation is to
Module 10 - 6

September 2003
Exhibit 10-2: Sample Worksheet for Development of EMS Documentation
List Existing
Documents
Determine
Format: Who/
Date Completed
Develop
Prototype
(Content): Who/
Date Completed
Assign Writing:
Who/ Date
Review Writing/
Compare to
Prototype:
Who/ Date
Added to
Document List/
Date
Who Has
Access
Where Located
List Documents
to be Created
Contact Person:
Date Completed:
Module 10 - 7

September 2003
Exhibit 10-3: Sample Outline for EMS Manual and Other EMS Documents
Basic EMS Manual
Index/Revision History/Distribution List
Description of How Our EMS Addresses Each of the EMS Elements (and linkages among these elements)
- How We Identify Significant Environmental Aspects
- How We Access and Analyze Legal and Other Requirements
- How We Establish and Maintain Objectives and Targets
- How the Organizational Structure Supports EMS (organization charts, key responsibilities)
- How We Train our Employees and Ensure Competence
- How We Communicate (internally and externally)
- How We Control EMS Documents
- How We Identify Key Processes and Develop Controls for them
- How We Prepare for and Respond to Emergencies
- How We Monitor Key Characteristics of Operations and Activities
- How We Identify, Investigate, and Correct Nonconformance
- etc.
Environmental Management Program Description
Annual Objectives and Targets
Action Plans (to achieve objectives and targets)
Tracking and Measuring Progress
EMS Procedures
Index/Revision History/Distribution List
Organization-wide Procedures (for some EMS elements there might be more than one procedure)
- Environmental Aspects Identification
- Access to Legal and Other Requirements
- Training, Awareness, and Competence
- Internal Communication
- External Communication
- Document Control
- Change Management Process(es)
- Management of Suppliers / Vendors
- Emergency Preparedness and Response
- Monitoring and Measurement
- Calibration and Maintenance of Monitoring Equipment
- Compliance Evaluation
- Corrective and Preventive Action
- Records Management
- EMS Auditing
- Management Review
Procedures/Work Instructions for Specific Operations or Activities
- Waste Management
- Wastewater Treatment
(These are examples only)
- Operation of the Paint Line
Other EMS Documentation (Emergency Response Plans, etc.)
Module 10 - 8

September 2003
Exhibit 10-4: Sample Procedure for Documentation
Purpose
To ensure effective operation of the EMS, [Your Facilitys Name] documents the procedures of
its EMS and keeps records of the outcomes of EMS processes, and of the important
environmental issues facing the plant. This EMS manual comprises this documentation.
Procedure
1. The Environmental Management Representative (EMR) documents the procedures that
define [Your Facilitys Name] EMS in this manual. The Cross Functional Team (CFT)
formally reviews and, if necessary, revises this manual on an annual basis. Revised
manuals are assigned a new revision number (a minor set of revisions would change the
number from, say, 1.1 to 1.2; a major revision would change the number from, say, 1.1 to
2.0). Finally, the EMS Coordinator ensures that no employees or managers use outdated
revisions of this manual.
Frequency
Manual review and revision on an annual basis.
Records
Maintained as outlined in the procedure.
Exhibit 10-5 provides you with the beginning framework for document control by presenting
you with important questions that need to be addressed. Exhibit 10-6 provides an example of a
procedure for document control, and Exhibit 10-7 and Exhibit 10-8 will help you manage your
documents once they have been created.
Module 10 - 9

September 2003
Exhibit 10-5: Document Control Worksheet

Do we have an existing process for controlling EMS
documents?
If yes, does that process need to be revised? In what way?

organization?
Who needs access to controlled copies of EMS documents?

How do we ensure that they have access?
How do we ensure that EMS documents are periodically

reviewed and updated as necessary?
Who has authority to generate new documents or modify

existing ones? How is this process managed?
How are users alerted to the existence of new EMS

documents or revisions to existing ones?
How do we ensure that obsolete documents are not used?
Is our EMS document control process integrated with other

organizational functions (such as quality)?
If so, how do we ensure proper coordination between
environmental and other functions?
Our next step on document control is to
Module 10 - 10

September 2003
Exhibit 10-6: Sample Procedure for Document Control

Purpose
To ensure effective operation of the EMS, [Your Facilitys Name] will ensure that documents are
easy to find and are kept up-to-date.
Procedure
1. The EMS Coordinator maintains updated records of the following outcomes, or results, of
the functioning of the EMS environmental policy
x Environmental aspects (Module 3)
x Applicability of legal requirements to Environmental Aspects (Module 4); note
that copies of the regulations themselves are maintained by the Environmental
Management Representative ( EMR).
x Significant environmental aspects
x Objectives, targets, and action plans for environmental management programs
(Module 5)
x List of operational control procedures related to SEAs (Module 12)
x Results of internal audits (Module 17)
x Corrective actions taken (Module 15)
x Management reviews (Module 18)
2. The EMS Coordinator is not responsible for maintaining records of environmental
training and emergency response preparations; the operational control procedures
themselves; or the New Purchase Approval Forms, the Design Approval Forms, or the
Facility Expansion or Modification Plans. These records are maintained by the
appropriate person or group.
3. The EMR or his designee will control all EMS documents and records from items 1 and 2
using Exhibit 10-7, Document Control Form and Exhibit 10-8, Document Index Form.
Frequency
Manual review and revision on an annual basis.
Records
Maintained as outlined in the procedure.
Module 10 - 11

September 2003
Exhibit 10-7: Sample Document Control Form

Document
Who Will Use It
Permanent Location
Periodic Review Schedule/ Who
When Can Be Destroyed
/
Contact Person:
Date Completed:
Module 10 - 12

September 2003
Exhibit 10-8: Sample Document Index Form

(Columns to be filled out with information such as the name of individual that revised document,
his/her position/department, and dates(s) of revision.)
Document
Revision Number
1
Environmental Manual
Procedure 1: Environmental Aspects
Identification
Procedure 2: Access to Laws and
Regulations
Procedure 3: Setting Objectives & Targets
Procedure 4: Environmental Training

Procedure 5: External Communications
Procedure 6: Internal Communications

Procedure 7: Document Control
Procedure 8: Emergency Preparedness
Procedure 9: Corrective Action
Procedure 10: Records Management
Procedure 11: EMS Audits
Procedure 12: Management Reviews

Procedures 13-X (list individually)
EMS Audit Checklist
Other plans & documents related to above
procedures (list separately, e.g. SPCC
Plan, Emergency Response Plan, etc.).
Other forms and checklists (list)
Module 10 - 13

September 2003

Guidance ................................................................................................................................... 11-2
Table 11-1: Partial List of Typical Operational Controls for Activities at a
Die Casting Facility .................................................................................. 11-4
Tools .......................................................................................................................................... 11-6
Exhibit 11-1: Operational Controls Worksheet ............................................................ 11-6
Exhibit 11-2: Sample Worksheet for Determining Which Operations Require
Operational Controls................................................................................ 11-7
Exhibit 11-3: Sample Worksheet for Training Plan for Operational Controls ............. 11-8
Exhibit 11-4: Sample Form for EMS Operational Control Procedures ........................ 11-9
Examples................................................................................................................................. 11-10
Example 11-1: Operational Control for New Material Purchasing........................... 11-10
Operational Control
Module 11 - 1

September 2003
GUIDANCE
Section 4.4.6 of the ISO 14001 Standard requires organizations to identify operations associated
with significant environmental aspects and to plan these activities to ensure they are controlled.
Where operations or activities are complex and/or the potential environmental impacts are
significant, controls should include documented procedures. Procedures can help your
organization to manage its significant environmental aspects (SEAs), ensure regulatory
compliance, and achieve environmental objectives. Procedures can also play a prominent role in
employee training.
Documented procedures should be established where the absence of procedures could lead to
deviations from the environmental policy or from your objectives and targets. Determining
which operations should be covered by documented procedures and how those operations should
be controlled is a critical step in designing an effective EMS. Keep in mind that you might need
operational controls to manage significant aspects or legal requirements, regardless of whether
you established objectives and targets for each of them.
For every environmental aspect your company determines to be significant, one of two actions
are taken:
x
x
Evaluating alternatives to current processes in order to reduce the potential for impact, or
Writing operational control procedures for activities or steps in a production process
where the potential impact may be well controlled.
The following are some examples of the kinds of activities that might be improved with operational
controls:
x management/disposal of wastes
x approvals for using new chemicals
x storage and handling of raw materials and chemicals
x wastewater treatment
x building and vehicle maintenance
x transport
x operation and maintenance of equipment
x management of contractors
x marketing and advertising
x acquisition or construction of property and facilities
Operational Control
Module 11 - 2

September 2003
The process of setting targets and ensuring their attainment has several steps that are discussed in
more detail below:
1. Determine the possible causes of potential impact
For all of your significant environmental aspects, you should determine the cause of the
impact. In some cases, the cause might seem obvious. However, sometimes the root
cause of the problem is not the most obvious cause. Use the root cause analysis
described in Module 14 to help your EMS team get to the cause of the impact prior to
developing your operational controls.
2. Set targets and measurements for environmental performance
As discussed in Module 5, you need to set a target for each objective and establish
measurements for environmental performance indicators. The targets should reflect
correction of the root cause identified above. Measurement indicators should document
changes in the causes identified above. Using the indicators, you can determine if your
operational controls are helping you meet your objectives.
3. Draft operational controls
Next, for each significant aspect that you have decided to address with procedures, draft
operational controls. Review each of the causes identified in your root cause analysis
that would contribute to the environmental impact of a significant aspect. Address the
causes by drafting operational controls.
Operational controls may already exist for some of the activities associated with a
significant aspect. Identify which aspects have written procedures that describe
operational controls, and which aspects will need to have procedures developed. In some
cases the procedures that you have in place to comply with environmental and health and
safety regulations may be useful to meet your EMS objectives. Table 11-1: Partial List
of Typical Operational Controls for Activities at a Die Casting Facility might help
your facility address some of the controls that might be important.
Also, it is important to involve the people who will implement the procedures in drafting
them. You can accomplish this in several ways:
x
x
x
Meet with workers and have them describe current procedures. Discuss the
environmental objective desired, and how to write operational controls (procedures)
to ensure that the objectives will be met.
Interview the workers to identify undocumented procedures; then draft (or revise)
operational controls. Have the workers and a manager review the draft.
Keep the written operational controls simple and concise. They should include the
appropriate actions, precautions, and notifications required. Focus on activities that
may lead to significant impacts and avoid getting overwhelmed by trying to control
every activity and process.
Operational Control
Module 11 - 3

September 2003
Table 11-1: Partial List of Typical Operational Controls for Activities at a Die
Casting Facility
Category of Activity
Operational Control
Purchase of Raw Materials
Subcontractor Requirements
Storage Facility for Chemicals and Hazardous

Wastes
x
x
x
x
x
x
x
x
Hazardous Waste Area Inspection

Bulk Storage and Containment
Containerized Material Storage
Drum Handling Satellite and Warehouse Storage
Hazardous Waste Operations Procedure
Control of Discharge and Disposal
Waste Manifest/Chain of Custody
Bulk Cargo Transfer Inspection
Shops and Facility Plant Maintenance
x
x
x
x
Environmental Checklist
Procedure for Pressure Washing Near Water
Maintenance and Machine Shop Checklist
Disposition of Fluorescent Bulbs, Batteries, and
Mercury Items
This EMS template provides you with Exhibit 11-2: Sample Worksheet for
Determining Which Operations Require Operational Controls to help guide the
process of establishing necessary operational controls.
4. Designate responsibility for maintaining and reviewing controls
Designate those people responsible both for maintaining the controls and for reviewing
them to ensure that procedures are followed and deviations corrected. Generally, the
workers responsible for the significant aspect under consideration will be responsible for
implementing the operational controls. The immediate line manager would most likely
be responsible for regular review of the controls. It is helpful to list those people
responsible for each set of procedures. Exhibit 11-3 helps the process of assigning
operational-control responsibilities.
5. Develop training
Achieving success in meeting environmental objectives for each significant aspect
depends upon making sure that each person responsible for maintaining or reviewing
controls has received adequate training. After operational controls are drafted, develop a
training program that ensures everyone understands both the controls and their own role
in ensuring that they are followed. Training can include on-the-job training. Exhibit
11-4 is provided to help your facility to determine training needs associated with
operational controls. It helps you to identify, plan for, and track the training needs of
your employees. This information should be combined with general environmental
Operational Control
Module 11 - 4

September 2003
training when creating an integrated training needs analysis for your EMS (See Module
8).
6. Take corrective action when objectives are not met
Take action to correct failures in operational controls as quickly as possible to meet
environmental objectives.
A sample operational control procedure is provided as Example 11-1: Operational Control for
New Material Purchasing. Sample forms for providing documented evidence that the procedure
is being implemented effectively are also included in the example.
Operational Control
Module 11 - 5

September 2003
TOOLS
Exhibit 11-1: Operational Controls Worksheet
Have we identified operations and activities associated with

significant environmental aspects, legal requirements, and
environmental objectives?
If not, how will this be accomplished? Who should be
involved?
What operations and activities are associated with significant

environmental aspects?
What operations and activities are associated with legal

requirements?
What operations and activities are associated with

environmental objectives and targets?
How are the above operations and activities controlled? (list

methods)
How do we know whether these controls are adequate (i.e., to

manage significant aspects, to ensure compliance, to achieve
objectives?
How do we train employees and contractors on relevant

operating controls?
If new controls are needed (or existing ones need to be

revised), what is our process for doing so?
Who needs to be involved in this process?
Our next step on operational control is to
Operational Control
Module 11 - 6

September 2003
Exhibit 11-2: Sample Worksheet for Determining Which Operations Require

Operational Controls
Operation
or
Activity
Operational Control
Procedure is
needed (none
exists)
Procedure exists,
but is not
documented
Procedure
exists and is
documented
No procedure is
needed
Module 11 - 7

September 2003
Exhibit 11-3: Sample Worksheet for Training Plan for Operational Controls
Aspect
Operational Control
Procedures
Person
Responsible for
Carrying Out
Training
Needs
How to Train
When/
Length
Budget
Completion
Date
Person
Responsible for
Training
Module 11 - 8

September 2003
Exhibit 11-4: Sample Form for EMS Operational Control Procedures

SEA
Contact Person:
Operational Control
Indicator(s)
Associated Job
Functions
Existing Operational
Control Procedures
Operational Control
Procedures Development/
Modification Needed
Person
Responsible/
Status
Location
Posted
Date Complete
Module 11 - 9

September 2003
EXAMPLES
Example 11-1: Operational Control for New Material Purchasing
Purpose/Scope:
This work instruction describes the procedures used to control the purchase and use of chemicals
within the XXX plant. This procedure also aids in compliance with governmental environmental
and health and safety regulations.
Responsibility:
The Purchasing Department, with assistance from the Environmental Management
representative, is responsible for ensuring that only approved materials will be purchased. All
employees are responsible for ensuring that only approved chemicals are used in the plant.
Procedure:
The Purchasing Department maintains a list of approved materials. Link to List of approved
materials.
Only those materials on the list of approved chemicals can be purchased and/or brought into the
facility (this includes samples).
To approve a new material:
Complete the top portion of Form XXX Chemical Approval Form. Submit the form and a
copy of the Material Safety Data Sheet (MSDS) for the material to the Environmental
Manager.
The Environmental Manager will evaluate the material based on the information provided
and indicate if the material is approved or not on the bottom portion of the form.
If approved, the Environmental Manager will submit the form to the Purchasing Department.
The Purchasing Department will add the material to the list of approved materials and file the
form.
If not approved, the Environmental Manager will return one copy the form to the requester
and file one copy of the form with the MSDS along with any other rejected substances.
Upon receipt of a shipment of materials/hazardous substances, the accompanying MSDS will be
forwarded to the Environmental Manager. The Environmental Manager is responsible for
maintaining MSDSs for all hazardous substances in the plant.
Reference:
List of Approved Chemicals
Records:
Completed Chemical Approval Forms - Form No. XXX
Operational Control
Module 11 - 10

September 2003

Guidance ................................................................................................................................... 12-2
Tools .......................................................................................................................................... 12-5
Exhibit 12-1: Emergency Preparedness and Response Worksheet.............................. 12-4
Exhibit 12-2: Emergency Preparedness and Response Requirements Matrix............. 12-5
Emergency Preparedness and Response
Module 12 - 1

September 2003
GUIDANCE
Despite an organizations best efforts, the possibility of accidents and other emergency situations
still exists. Effective preparation and response can reduce injuries, prevent or minimize
environmental impacts, protect employees and neighbors, reduce asset losses, and minimize
downtime. Section 4.4.7 of the ISO 14001 Standard requires organizations to establish and
maintain procedures to identify, respond to emergency situations and to prevent and mitigate the
environmental impacts that may be associated with them.
An effective emergency preparedness and response program should include provisions for:
x
x
x
x
x
assessing the potential for accidents and emergencies;

preventing incidents and their associated environmental impacts;
plans / procedures for responding to incidents;
periodic testing of emergency plans/procedures; and,
mitigating impacts associated with these incidents.
Consistent with the focus on continual improvement, it is important to review your emergency
response performance after an incident has occurred. Use this review to determine if more
training is needed or if emergency plans/procedures should be revised.
USEFUL INFORMATION SOURCES:

x
x
x
x
Material safety data sheets

Plant layout
Process flow diagrams
Engineering drawings
x
x
Design codes and standards

Specifications on safety systems
(alarms, sprinklers, etc.)
Module 12 - 2

September 2003
Getting Started:
x
x
x
Emergency Response is another area where you should not have to start from scratch.
Several environmental and health and safety regulatory programs require emergency
plans and/or procedures. First review what you have now and assess how well it satisfies
the items discussed previously.
Make sure existing plans are controlled documents (are they dated and in accordance
with your documentation procedures?)
Whether you are creating new or reviewing existing plans, keep the following in mind.
Two planning components that many organizations overlook are how they identify the
potential for accidents and emergencies and how they mitigate the impacts of such
incidents. A cross-functional team (CFT) (with representatives from engineering,
maintenance, and environmental health & safety, for example) can identify most potential
emergencies by asking a series of what if questions related to hazardous materials,
activities, and processes employed at the site. In addition to normal operations, the team
should consider start-up and shutdown of process equipment, and other abnormal
operating conditions.
Ask yourself: Does everyone (including new employees) know what to do in an
emergency? How would contractors or site visitors know what to do in an emergency
situation?
Communicate with local officials (fire department, hospital, etc.) about potential
emergencies at your site and how they can support your response efforts.
Hints
x
x
Mock drills can be an excellent way to reinforce training and get feedback on the
effectiveness of your plans / procedures.
Post copies of the plan (or at least critical contact names and phone numbers) around the
site and especially in areas where high hazards exist. Include phone numbers for your
on-site emergency coordinator, local fire department, local police, hospital, rescue squad,
and others as appropriate.
Revise and improve your plan as you learn from mock drills, training, or actual
emergencies.
Module 12 - 3

September 2003
Checklist for Emergency Preparedness and Response Plans

Does your plan describe the following:
potential emergency situations (such as fires,

explosions, spills or releases of hazardous
materials, and natural disasters)?
hazardous materials used on-site (and their
locations)?
key organizational responsibilities (including
emergency coordinator)?
arrangements with local emergency support
providers?
emergency response procedures, including
emergency communication procedures?
locations and types of emergency response

equipment?
maintenance of emergency response
equipment?
training / testing of personnel, including the
on-site emergency response team (if
applicable)?
testing of alarm / public address systems?
evacuation routes and exits (map), and
assembly points?
Exhibits 12-1 and 12-2 are worksheets to help your facility guide the process of ensuring that
its emergency preparedness and response procedures are adequate and that they are well
integrated into your EMS.
Module 12 - 4

September 2003
TOOLS
Exhibit 12-1: Emergency Preparedness and Response Worksheet

Have we reviewed our operations and activities for
potential emergency situations?
involved?
Do our existing emergency plans describe how we will

prevent incidents and associated environmental impacts?
involved?
Have we trained personnel on their roles and

responsibilities during emergencies?
What emergency equipment do we maintain? How do we

know that this equipment is adequate for our needs?
How do contractors and other visitors know what to do in

an emergency situation?
When was our last emergency drill? Is there a plan /

schedule for conducting future drills?
Have we established a feedback loop so we can learn from

our experiences?
Our next step on emergency preparedness & response

is to
Module 12 - 5

September 2003
Exhibit 12-2: Emergency Preparedness and Response Requirements Matrix

Potential Emergency
Scenario
Potential Environmental
Impact
Action Required
Procedures
Needed
Training
Needed
Module 12 - 6

September 2003

Guidance ................................................................................................................................... 13-2
Tools .......................................................................................................................................... 13-5
Exhibit 13-1:
Exhibit 13-2:
Exhibit 13-3:
Exhibit 13-4:
Monitoring and Measurement Worksheet .................................... 13-5

Sample Procedure for a Compliance Assessment......................... 13-6
Sample Form for Compliance Tracking ....................................... 13-7
Calibration Log ............................................................................. 13-8
Examples................................................................................................................................... 13-9
Example 13-1: Example of Links Between Aspects, Objectives and Targets,
Operational Controls, and Monitoring and Measurement .................. 13-9
Example 13-2: Linking Monitoring Processes to Operational Controls ................... 13-10
Monitoring and Measurement
Module 13 - 1

September 2003
GUIDANCE
Section 4.5.1 of the ISO 14001 Standard requires organizations to establish procedures to
monitor and measure key characteristics of their operations and activities that can have a
significant impact on the environment.
Monitoring and measurement enables an organization to:
x
x
x
x
x
Which operations and

activities can have
significant environmental
impacts?
evaluate environmental performance;

analyze root causes of problems;
assess compliance with legal requirements;
identify areas requiring corrective action; and,
improve performance and increase efficiency.
What are the key

characteristics of these
operations and activities?
In short, monitoring helps you manage your organization

better. Pollution prevention and other strategic opportunities
are identified more readily when current and reliable data are
available.
How do we measure
these characteristics?
Your organization should develop procedures to:

x
x
x
x
monitor key characteristics of operations and activities that can have significant
environmental impacts and/or compliance consequences;
track performance (including your progress in achieving objectives and targets);
calibrate and maintain monitoring equipment; and,
through internal audits, periodically evaluate your compliance with applicable laws and
regulations.
An illustration of how monitoring and measurement is tied to the significant aspects, objectives
and targets, and operational controls of facilitys EMS is presented in Example 13-1.
Identifying Key Characteristics

Assemble your Cross Functional Team to decide what operations need to be monitored and/or
measured in order to track progress towards meeting your objectives and targets. Exhibit 13-1
can help you with this process. Record this information in the meeting minutes. Most effective
environmental measurement systems use a combination of process and outcome measures.
Module 13 - 2

September 2003
Outcome measures look at results of a process or activity, such as the amount of waste generated
or the number of spills that took place. Process measures look at upstream factors, such as the
amount of paint used per unit of product or the number of employees trained on a topic. Select a
combination of process and outcome measures that are right for your organization. Keep
monitoring requirements limited to KEY process characteristics and focus on the things that you
can control.
Progress on Meeting Objectives

You should measure progress on achieving objectives and targets on a regular basis and
communicate the results of such measurement to top management. To measure progress in
meeting objectives, select appropriate performance indicators. Performance indicators can help
you to understand how well your EMS is working. Start by identifying a few performance
indicators that are:
x
x
x
x
simple and understandable;

objective;
measurable; and
relevant to what your organization is trying to achieve (i.e., its objectives and targets)
Data collected on performance indicators can be quite helpful during management reviews (see
Module 17). So, select indicators that will provide top management with the information it
needs to make decisions about the EMS.
Calibrating Equipment
A component of monitoring and measurement is equipment calibration. Your facility should
identify process equipment and activities that truly affect your environmental performance. As a
starting point, look at those key process characteristics you identified earlier. Some
organizations place critical monitoring equipment under a special calibration and preventive
maintenance program, or at least insure that they are part of the facilitys regular PM program.
This can help to ensure accurate monitoring and make employees aware of which instruments are
most critical for environmental monitoring purposes. Some organizations find it is more costeffective to subcontract calibration and maintenance of monitoring equipment than to perform
these functions internally.
An illustration of how calibration needs are tied to significant aspects, operational controls, key
characteristics of the operation, and monitoring and measurement methods is presented in
Example 13-2.
Module 13 - 3

September 2003
Regulatory Compliance
Determining your compliance status on a regular basis is very important. You should have a
procedure to systematically identify, correct, and prevent violations. Effectiveness of the
compliance assessment process should be considered during EMS management review.
Communicating Performance
People respond best to information that is meaningful to their world. Putting environmental
information in a form that is relevant to their function increases the likelihood they will act on
the information. Be sure to link your measurement program with your communications
program and other elements of the EMS (such as management reviews, as discussed later).
Documenting Your Monitoring and Measurement Process

Exhibit 13-2 provides a sample procedure that your facility can adopt for ensuring
environmental regulatory compliance. Exhibit 13-3 is an example of a compliance tracking
form to be used in association with the procedure. Exhibit 13-4 is an example of documenting
calibration measures. Similar to the example provided by Exhibit 13-2, Procedure for a
Compliance Assessment, your facility might want to establish written procedures for calibration
of equipment to which Exhibit 13-4 will be associated.
Hints:
x
x
x
Monitoring and measuring can be a resource-intensive effort. One of the most important
steps you can take is to clearly define your needs. While collecting meaningful
information is clearly important, resist the urge to collect data for datas sake.
Review the kinds of monitoring you do now for regulatory compliance and other
purposes (such as quality or health and safety management). How well might this serve
your EMS purposes? What additional monitoring or measuring might be needed?
Make measuring and monitoring reports applicable to the operational staff and
meaningful for management.
Monitoring and measurement procedures and work instructions should be incorporated
into as many existing work instructions as possible. Delegate these revisions to
supervisors or area managers.
You can start with a relatively simple monitoring and measurement process, then build
on it as you gain experience with your EMS.
Module 13 - 4

September 2003
TOOLS
Exhibit 13-1: Monitoring and Measurement Worksheet

Have we identified operations and activities associated with
significant environmental aspects, legal requirements and
environmental objectives? If, not how will this be
accomplished?
What type(s) of monitoring and measurement do we need to

ensure that operational controls are being implemented
correctly?

ensure that we are complying with applicable legal
requirements?

ensure that we are achieving our environmental objectives &
targets?
How do we identify the equipment used for any of the

monitoring or measurement listed above?
How will we ensure that monitoring and measurement

equipment is properly calibrated and maintained?
What process do we have to periodically evaluate compliance

with legal requirements? How effective is this process?
Our next step on monitoring and measurement is to
Module 13 - 5

September 2003
Exhibit 13-2: Sample Procedure for a Compliance Assessment

Purpose
[Your Facilitys Name] conducts a periodic compliance assessment to ensure that it complies
with all applicable local, state, and federal environmental regulations.
Procedure
1. The Environmental Management Representative (EMR) maintains copies of applicable
legal regulations (see Module 4, Exhibit 4-4). Based on these regulations, the EMR and
EMS Coordinator compile a list of questions as a compliance assessment protocol. These
questions are intended to be sufficient to determine the compliance status of [Your
Facilitys Name] with respect to applicable environmental regulations (both the
paperwork and the performance-related components).
2. The EMS Coordinator and another operations manager carry out the assessment by
determining and recording the answers to the compliance assessment protocol. When
they are done with the compliance assessment, they note any actual or potential
compliance issues on Exhibit 13-3: Compliance Tracking Log. Each actual and
potential compliance issue is immediately referred to corrective action.
Frequency
Monthly.
Records
Compliance assessment results are recorded by the Cross Functional Team (CFT) using the
compliance assessment protocol. Records are maintained by the EMS Coordinator.
Module 13 - 6

September 2003
Exhibit 13-3: Sample Form for Compliance Tracking

Person
Responsible
Regulation
Root Cause
Compliance Check
Date
Results
Corrective
Action/Date
(see: TCA-01)
Compliance
Verified/Date
Module 13 - 7

September 2003
Exhibit 13-4: Calibration Log

Indicator
Contact Person:
Measurement Method
Equipment Used
Equipment calibrated:
date/method
Date Completed:
Module 13 - 8

September 2003
EXAMPLES
Example 13-1: Example of Links Between Aspects, Objectives and Targets,
Operational Controls, and Monitoring and Measurement
Significant Aspect
Objective
Target
Anti-corrosive
paint X
C-Maintain
compliance
Ongoing
Solid waste from

unmasking
process
S-Investigate
potential for
reduction
Complete study
by January 2002
Monitoring and
Measurement
Operational Control
Coating and
thinning NESHAP
procedure
x Paint application
work instruction
(WI)
x Bulk storage WI
and containment
WI
x Solid waste
reduction EMP
x
Compliance audit
x Regulatory
reporting
x EMS audits
x
Waste reduction
x tracking metric
x EMS audits
x
Module 13 - 9

September 2003
Example 13-2: Linking Monitoring Processes to Operational Controls

Operation with
Significant
Environmental
Aspect
Liquid
Waste
Storage
Operational
Controls
Key Characteristics
of Operation
or Activity
Monitoring or
Measurement
Methods
Equipment
Calibration
Needs
x Use of proper
containers
x Segregation of
incompatibles
x Inspections of
storage area
x Inspections of
storage area
x None
x Storage area
procedure
x Availability of
spill equipment
x Inspections of
storage area
x None
x Purchasing
Approval
procedure
x EHS Manager
approval of all
new chemical
purchases
x Periodic review
of Material
Safety Data
Sheets (MSDSs)
x Inspections of
chemical storage
lockers
x None
x Generator
procedure
x None
(significant aspect is
potential for spills)
New Chemical
Purchasing
(significant aspect is
waste generation)
Module 13 - 10

September 2003
Module 14: Nonconformance and Corrective and

Preventive Action
Guidance ................................................................................................................................... 14-2
Tools .......................................................................................................................................... 14-5
Exhibit 14-1:
Exhibit 14-2:
Exhibit 14-3:
Exhibit 14-4:
Corrective & Preventive Action Worksheet .......................................... 14-5

Sample Procedure for Corrective and Preventive Action...................... 14-6
Sample Corrective and Preventive Action Notice ................................. 14-8
Sample Corrective and Preventive Action Tracking Log...................... 14-9
Nonconformance and Corrective and Preventive Action
Module 14 - 1

September 2003
GUIDANCE
Section 4.5.2 of the ISO 14001 Standard states that the organization shall establish and maintain
procedures for defining responsibility and authority for handling and investigating
nonconformance, taking corrective action to mitigate any impacts caused and for initiating and
completing corrective and preventive action.
No EMS is perfect. You will probably identify problems with your system (especially in the
early phases) through audits, measurement, or other activities. In addition, your EMS will need
to change as your organization changes and grows. To deal with system deficiencies, your
organization needs a process to ensure that:
x
x
x
x
Problems (including nonconformities) are identified and

investigated;
Root causes are identified;
Corrective and preventive actions are identified and
implemented; and,
Actions are tracked and their effectiveness is verified.
EMS nonconformities and other system deficiencies (such as legal

noncompliance) should be analyzed to detect patterns or trends.
Identifying trends allows you to anticipate and prevent future
problems.
Focus on correcting and preventing problems. Preventing
problems is generally cheaper than fixing them after they occur
(or after they reoccur). Start thinking about problems as
opportunities to improve!
Determining Causes of Problems and Identifying Corrective Actions
You will need to establish a method to determine the causes of
failing to meet a target. In some cases, the cause might not be
difficult to understand. Other times, however, the cause might not
be obvious. Make sure your actions are based on good information
and analysis of causes. While many corrective actions may be
common sense, you need to look beneath the surface to
Key Steps
;
;
;
;
;
;
;
identify the problem

investigate to identify
the root cause
come up with solution
implement solution
document solution
communicate solution
evaluate effectiveness of
solution
Why do EMS problems

occur?
Typical causes include:
;
;
;
;
;
;
;
poor communication
faulty or missing
procedures
equipment malfunction
(or lack of maintenance)
lack of training
lack of understanding
(of requirements)
failure to enforce rules
corrective actions fail to
address root causes of
problems
Module 14 - 2

September 2003
determine why problems occur. Many organizations use the term root cause in their corrective
and preventive action processes. While this term can be used to describe a very formal analysis
process, it can also mean something simpler looking past the obvious or immediate reason for a
nonconformance to determine why the nonconformance occurred.
Once you document a problem with respect to meeting targets, the company must be committed
to resolving it. Take action as quickly as possible. First, make sure assigned responsibilities for
actions and schedules are clear.
Employees in the shop may recognize the need for corrective action and provide good ideas for
solving problems. Find ways to get them involved in the improvement process. Its important to
determine whether a lapse is temporary or due to some flaw in the procedures or controls. For
this reason, communicate any findings to employees, and provide any follow-up training for
changes in the procedures that may result.
Hints
x
If your organization has an ISO 9001 management system, you should already have a
corrective and preventive action process for quality purposes. Use this as a model (or
integrate with it) for EMS purposes.
Some organizations find that they can combine some elements of their management
review and corrective action processes. These organizations use a portion of their
management review meetings to review nonconformities, discuss causes and trends,
identify corrective actions, and assign responsibilities.
The amount of planning and documentation needed for corrective & preventive actions
will vary with the severity of the problem and its potential environmental impacts.
Dont go overboard with bureaucracy simple methods often work quite effectively.
Once you document a problem, the organization must be committed to resolving it in a
timely manner. Be sure that your corrective and preventive action process specifies
responsibilities and schedules for completion. Review your progress regularly and
follow up to ensure that actions taken are effective.
Rule of thumb: Corrective actions should (1) resolve the immediate problem,
(2) consider whether the same or similar problems exist elsewhere in the organization,
and (3) prevent the problem from recurring. The corrective action process also should
define the responsibilities and schedules associated with these three steps.
Initially, most EMS problems may be identified by your internal auditors. However, over
the long run, many problems and good ideas may be identified by the people doing the
work. This should be encouraged. Find ways to get employees involved in the system
improvement process (for example, via suggestion boxes, contests, or incentive
programs).
Module 14 - 3

September 2003
Exhibit 14-1 is a worksheet to guide your facility in establishing and implementing a corrective
and preventive action program. Exhibit 14-2 provides a sample procedure for conducting
corrective and preventive action. Exhibit 14-3 is a sample form that can be used to document
the use of your procedure. Exhibit 14-4 can be used to track corrective and preventive actions.
Exhibit 14-3 could also be combined with the EMS Audit Findings, Exhibit 16-7 (see Module
16).
Module 14 - 4

September 2003
TOOLS
Exhibit 14-1: Corrective & Preventive Action Worksheet

Do we have an existing process for corrective and
preventive action?
If yes, does that process need to be revised? In what
way?

organization?
How are nonconformities and other potential system

deficiencies identified? (List methods such as audits,
employee suggestions, ongoing monitoring, etc.)
How do we determine the causes of nonconformities

and other system deficiencies? How is this
information used?
How do we track the status of our corrective and

preventive actions?
How is / can information on nonconformities and

corrective actions be used within the EMS (for
example, in management review meetings, in
employee training sessions, in review of procedures,
etc.)
How do we ensure the effectiveness of our corrective

and preventive actions?
Our next step on corrective and preventive action is

to
Module 14 - 5

September 2003
Exhibit 14-2: Sample Procedure for Corrective and Preventive Action

Purpose
The purpose of this procedure is to establish and outline the process for identifying,
documenting, analyzing, and implementing preventive and corrective actions.
Scope
Preventive or corrective actions may be initiated using this procedure for any environmental
problem affecting the organization.
General
A. Corrective action is generally a reactive process used to address problems after they have
occurred. Corrective action is initiated using the Corrective and Preventive Action Notice
(CAPAN), Exhibit 14-3, as the primary vehicle for communication. Corrective action may
be triggered by a variety of events, including internal audits and management reviews.
Other items that might result in a CAN include neighbor complaints or results of monitoring
and measurement.
B. Preventive action is generally a proactive process intended to prevent potential problems
before they occur or become more severe. Preventive action also is initiated using the
CAPAN, Exhibit 14-3. Preventive action focuses on identifying negative trends and
addressing them before they become significant. Events that might trigger a CAPAN
include monitoring and measurement, trends analysis, tracking of progress on achieving
objectives and targets, response to emergencies and near misses, and customer or neighbor
complaints, among other events.
C. CAPANs are prepared, managed, and tracked using the preventive and corrective action
database.
D. The EMR (or designee) is responsible for reviewing issues affecting the EMS, the
application and maintenance of this procedure, and any updates to EMS documents affected
by the preventive and corrective actions.
E.
The EMR is responsible for logging the CAPAN into the database, and tracking and
recording submission of solutions in the database. The requester and recipient of the
CAPAN responsible for verifying the effectiveness of the solution. The EMR is responsible
for overall tracking and reporting on preventive and corrective actions.
F.
Personnel receiving CAPANs are responsible for instituting the required corrective or
preventive action, reporting completion of the required action to the EMR, and assuring
sustained effectiveness.
G. Completed records of CAPANs are maintained in the database for at least two years after
completion of the corrective or preventive action.
Module 14 - 6

September 2003
Procedure
1.
Issuing a CAPAN
a. Any employee may request a CAPAN. The employee requesting the CAPAN is
responsible for bringing the problem to the attention of the EMR. The EMR is
responsible for determining whether a CAPAN is appropriate and enters the appropriate
information into the corrective and preventive action database. Responsibility for
resolving the problem is assigned to a specific individual (the recipient).
b. The EMR, working with the recipient, determines an appropriate due date for resolving
the CAPAN.
2.
Determining and Implementing Corrective and Preventive Actions

a. The CAPAN is issued to the recipient, who is responsible for investigation and
resolution of the problem. The recipient is also responsible for communicating the
corrective or preventive action taken.
b. If the recipient cannot resolve the problem by the specified due date, he / she is
responsible for determining an acceptable alternate due date with the EMR.
3.
Tracking CAPANs
a. Close-out of CAPANs should be tracked by the EMR or his designee using Exhibit
14-4. CAPANs whose resolution dates are overdue appear on the Overdue Solutions
report. The EMR is responsible for issuing this report on a weekly basis to the Plant
Manager and the recipients of any overdue CAPANs.
b. Records of CAPANs are maintained in the database for at least two years after
completion of the corrective or preventive action.
4.
Tracking Effectiveness of Solutions

a. The recipient of a CAPAN, in conjunction with the requester, are responsible for
verifying the effectiveness of the solution. If the solution is deemed not effective, the
CAPAN will be reissued to the original recipient.
Module 14 - 7

September 2003
Exhibit 14-3: Sample Corrective and Preventive Action Notice (CAPAN)

Issue Date:
Solution Due Date:
Requested by:
Issued to:
Problem Statement:
Most Likely Causes:
Suggested Solutions/Preventions:
Action Taken:
Measured Results:
Corrective and Preventive Action Closed by:
Date:
Contact for Notice:
Date completed:
Module 14 - 8

September 2003
Exhibit 14-4: Sample Corrective and Preventive Action Tracking Log
CAPAN
Number
Requested
By
Issued To
Plan Due
(Date)
Plan
Completed
(Date)
Corrective
and
Preventive
Action
Completed
(Date)
Effectiveness
Verified
(Date)
CAPAN
Closed
(Date)
Module 14 - 9

September 2003
Module 15: Records

Guidance ................................................................................................................................... 15-2
Tools .......................................................................................................................................... 15-4
Exhibit 15-1: Records Management Worksheet .......................................................... 15-4
Exhibit 15-2: Sample Checklist for Records of Supporting Documentation............... 15-5
Examples................................................................................................................................... 15-6
Example 15-1: Sample of Environmental Records File Organization......................... 15-6
Example 15-2: Sample EMS Records Management Table.......................................... 15-7
Records
Module 15 - 1

September 2003
GUIDANCE
Section 4.5.3 of the ISO 14001 Standard requires organizations to identify and maintain
necessary environmental records. The purpose of records management is fairly simple you
should be able to demonstrate that your organization is actually implementing the EMS as
designed. While records have value internally, over time you may need to provide evidence of
EMS implementation to external parties (such as customers, a registrar, or the public).
Records management is sometimes seen as bureaucratic, but it is difficult to imagine a system
operating consistently without accurate records.
What are records?
Records provide evidence
that the processes that
make up your EMS are
being implemented as
described.
The basics of records management are straightforward: you

need to decide what records you will keep, how you will keep
them and for how long. You should also think about how you
will dispose of records once you no longer need them.
If your organization has an ISO 9001 (or other) management
system, you should have a process in place for managing
records. This process could be adapted for EMS purposes.
Hints:
x
Records
Start by identifying what EMS records are required. Review the procedures and work
instructions you have developed for your EMS to determine what evidence is needed to
demonstrate implementation. Also consider records that are required by various legal
requirements.
Focus on records that add value avoid bureaucracy. If records have no value or are
not specifically required, dont collect them. The records you choose to keep should be
accurate and complete.
You may need to generate certain forms in order to implement your EMS. When these
forms are filled out, they become records. Forms should be simple and understandable
for the users.
Establish a records retention policy and stick to it. Make sure that your policy takes into
account records retention requirements specified in applicable environmental
regulations.
Module 15 - 2

September 2003
If your organization uses computers extensively, consider using an electronic EMS

records management system. Maintaining records electronically can provide an excellent
means for rapid retrieval of records as well as controlling access to sensitive records.
Identify which records, if any, might require additional security. Do you need to restrict
access to certain records? Should a back-up copy of critical records be maintained at
another location?
Types of Records You Might Maintain (Examples):

x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
legal, regulatory, and other code requirements

results of environmental aspects identification
reports of progress towards meeting objectives and targets
permits, licenses, and other approvals
job descriptions and performance evaluations
training records
EMS audit and regulatory compliance audit reports
reports of identified nonconformities, corrective action
plans, and corrective action tracking data
hazardous material spill / other incident reports
communications with customers, suppliers, contractors, and
other external parties
results of management reviews
sampling and monitoring data
maintenance records
equipment calibration records
Key Questions
;
;
;
;
;
what records are kept?

who keeps them?
where are they kept?
how are they kept?
how long are they
kept?
; how/when are they
accessed?
; how are they
disposed?
Exhibit 15-1 is a worksheet to guide your facility in setting up an effective record-keeping

system. Exhibit 15-2 is a checklist of some of the key records necessary to support your EMS.
There will be other records you will need to demonstrate performance of your EMS, but those in
Exhibit 15-2 are specific to the system operation. Examples 15-1 and 15-2 demonstrate the
implementation of a records management system.
Records
Module 15 - 3

September 2003
TOOLS
Exhibit 15-1: Records Management Worksheet
Have we identified what records need to be maintained?
Where is this defined?
Have we determined records retention times? Where is this

defined?
Have we established an effective storage and retrieval

system?
Our next step on records is to
Records
Module 15 - 4

September 2003
Exhibit 15-2: Sample Checklist for Records of Supporting Documentation
Records
_____
Facility organization chart
_____
Facility environmental policy and standards
_____
Staffing and organization chart for your facility
_____
Supporting documentation for reporting and communication networks such as

meeting notices, meeting minutes, memoranda, etc.
_____
Written Environmental Program performance and status reports
_____
Facility-specific environmental policies and procedures
Module 15 - 5

September 2003
EXAMPLES
Example 15-1: Sample of Environmental Records File Organization
Air Emissions Regulations
Air Emissions Fees
Air Emissions Inventories
Air Emissions Permits
Air Permit Applications
Air Permit(s): Historical
Annual Licenses & Fees
Compliance Reporting
Compliance Plans
Community Right-to-Know
EPCRA Regulations
EPCRA Reporting
Hazardous Waste Regulations
Hazardous Waste Permit/ID Number
Hazardous Waste Fees
Hazardous Waste Biennial Report
Hazardous Waste: Open Manifests
Hazardous Waste: Closed Manifests
Historical Data
Indoor Air Quality
Records
Loss Prevention Information

Other Permits & Permit Applications
Pollution Prevention (P2) Regulations
Pollution Prevention Fees
Pollution Prevention Reporting
Recycling Information
Recycling Projects
Special Wastes
Solid Waste Permit
Solid Waste Fees
Spill Reports
Spill Response Actions
Storm Water Regulations
Storm Water Permit
VOC/HAPs Reporting
VOC Annual Analysis
Wastewater Regulations
Wastewater Fees
Wastewater Permit
Wastewater: Semi-Annual Reporting
Module 15 - 6

September 2003
Example 15-2: Sample EMS Records Management Table

Title: EMS RECORDS MANAGEMENT TABLE
Revision Date: November 7, 2000
Print Date: September 30, 2003 (Uncontrolled document
if printed)
Doc. No.: EMF-4.5.3

Approval by:
Page 1 of 2
EMS Records Management Table

The following table lists records related to the Environmental Management System, in
accordance with EMP-4.5.3 (Record keeping procedure).
Record Type
Person Responsible
Location
File Method
Retention
Minimum
ADMINISTRATION
Records on costs - purchasing,
operations, and disposal
Office Manager
Admin. Office
Date order
3 years
Utility bills
Office Manager
Admin. Office
Date order
3 years
Record of annual waste quantity

received
Office Manager
Admin. Office
Date order
Life of
Company
Certificates of Insurance
Office Manager
Admin. Office
Date order
Life of
Company
Waste Analysis Sheets
Office Manager
Admin. Office
Customer
name
3 years
Waste Manifests - outgoing
Office Manager
Admin. Office
Date order
3 years
Env. Dept.
Env. Office
Date order
3 years
Env. Dept.
Env. Office
Date order
3 years
EMS Communications with

external parties
Env. Dept.
Env. Office
Issue
3 years
Decision regarding external

communication of significant
environmental aspects
Env. Dept.
Env. Office
Date order
3 years
ENVIRONMENTAL
Incident Reports
Complaint Reports
Records
Module 15 - 7

September 2003
Record Type
Person Responsible
Location
File Method
Retention
Minimum
Major Source Determination

Records
Env. Dept.
Env. Office
Date order
Life of
Company
Title V Permit Exemption
Env. Dept.
Env. Office
Date order
Life of
Company
Correspondence regarding Air

Notices
Env. Dept.
Env. Office
Date order
5 years
Odor Control System Permit
Env. Dept.
Env. Office
Date order
5 years or per
Permit
Air Emission Reports
Env. Dept.
Env. Office
Date order
5 years
Records on waste disposal sites

used
Env. Dept.
Env. Office
Site name
Life of
Company
EMS Monitoring Inspection

reports
Env. Dept.
Env. Office
Date order
5 years
Records
Module 15 - 8

September 2003

Guidance ................................................................................................................................... 16-2
Figure 16-1: Linkages Among EMS Audits, Corrective Action and
Management Reviews ................................................................... 16-5

Tools .......................................................................................................................................... 16-6
Exhibit 16-1:
Exhibit 16-2:
Exhibit 16-3:
Exhibit 16-4:
Exhibit 16-5:
Exhibit 16-6:
Exhibit 16-7:
EMS Auditing Worksheet................................................................ 16-6

Sample Procedure for EMS Audits ......................................... 16-7
Sample Audit Plan Form................................................................ 16-10
Sample Form for Communications to Audit Team........................ 16-11
Sample Form for Internal Assessment Checklist........................... 16-12
Sample EMS Audit Summary Form .............................................. 16-13
Sample Form for EMS Audit Findings.......................................... 16-14
Examples................................................................................................................................. 16-15
Example 16-1: Sample Questionnaire for EMS Audits ............................................. 16-15
Example 16-2: Sample Checklist for Top Management EMS Audits ....................... 16-24
EMS Audits
Module 16- 1

September 2003
GUIDANCE
Once your organization has established its EMS, verifying the implementation of the system will
be critical. To identify and resolve EMS deficiencies you must actively seek them out.
In a smaller organization, periodic audits can be particularly valuable. Managers are often so
close to the work performed that they may not see problems or bad habits that have developed.
Periodic EMS audits will help determine whether all of the requirements of the EMS are being
carried out in the specified manner.
For your EMS audit program to be effective, you should:
x
x
x
x
develop audit procedures and protocols;

determine an appropriate audit frequency;
select and train your auditors; and
maintain audit records.
Results of your EMS audits should be linked to the

corrective and preventive action process, as described
earlier.
Audit procedures should

describe:
; audit planning
; audit scope (areas and
activities covered)
; audit frequency
; audit methods
; key responsibilities
; reporting mechanisms
; recordkeeping
While they can be time-consuming, EMS audits are critical

to EMS effectiveness. Systematic identification and
reporting of EMS deficiencies to management provides a
great opportunity to:
x
x
x
EMS Audits
maintain management focus on the environment,

improve the EMS and its performance, and
ensure the systems cost-effectiveness.
Module 16- 2

September 2003
Getting Started:
How frequently do we need to audit?
To determine an appropriate frequency of your EMS audits, consider the following factors:
x
x
x
x
the nature of your operations and activities,

your significant environmental aspects / impacts (which you identified earlier),
the results of your monitoring processes, and
the results of previous audits.
It is recommended that all parts of the EMS should be audited at least annually. You can audit
the entire EMS at one time or break it down into discrete elements for more frequent audits.
Regularly revisiting your environmental aspects and objectives is an essential step in developing
an EMS that achieves the goal of continuous environmental improvements. The regular review
of aspects can be used to change the priorities already established, or to examine activities that
were set aside. The regular review can be part of a planned phasing in process, wherein
different parts of your companys operations are reviewed until all your companys activities are
included in your EMS. The regular review of aspects is the foundation for your companys
continuing improvement.
What do we need to audit?
As part of your audits, it is critical that you regularly review your companys environmental
aspects and objectives. Over time, you will probably add to the list of environmental aspects and
you may need to re-rank the aspects as your activities change and as new information becomes
available. Here are some things to check:
x
x
x
x
x
x
EMS Audits
New process review have any changes introduced new

environmental aspects?
Worksheets from the most recent environmental aspect identification and ranking
exercises is there new information on chemical effects? If so, update your worksheets.
Communication received from stakeholders do any comments suggest a need for reranking your aspects?
Environmental objectives and targets what new ones will your company set for this
time period?
Pollution prevention program has information become available from this effort that
would add aspects or objectives?
Audit program have your audits turned up information on where your EMS and
environmental programs could be improved? Would this information be useful in your
aspect identification process or in redesigning your objectives?
Module 16- 3

September 2003
Who will perform the audits?

You should select and train EMS auditors. Auditor training should be both initial and ongoing.
Commercial EMS auditor training is available, but it might be more cost-effective to link up with
businesses or other organizations in your area. Contact NADCA for assistance in this area.
Auditors should be trained in auditing techniques and management system concepts.
Familiarity with environmental regulations, facility operations, and environmental science can be
a big plus, and in some cases may be essential to adequately assess the EMS.
Some auditor training can be obtained on-the-job. Your organizations first few EMS audits can
be considered part of auditor training, but make sure that an experienced auditor leads or takes
part in those training audits.
Auditors should be independent of the activities being audited. This can be a challenge for
small organizations.
If your company is registered under ISO 9001, consider using your internal quality auditors as
EMS auditors. While some additional training might be needed for EMS auditing, many of the
required skills are the same.
How should management use audit results?
Management can use EMS audit results to identify trends or patterns in EMS deficiencies.
The organization also should ensure that identified system gaps or deficiencies are corrected in a
timely fashion and that corrective actions are documented.
Hints
x
EMS Audits
Your EMS audits should focus on objective evidence of conformance. During an audit,
auditors should resist the temptation to evaluate, for example, why a procedure was not
followed that step comes later.
During an audit, auditors should review identified deficiencies with people who work in
the relevant area(s). This will help the auditors verify that their audit findings are correct.
This also can reinforce employee awareness of EMS requirements.
If possible, train at least two people as internal auditors. This will allow your auditors to
work as a team. It also allows audits to take place when one auditor has a schedule
conflict, which is often unavoidable in a smaller organization!
Before you start an audit, be sure to communicate the audit scope, criteria, schedule,
and other pertinent information to the people in the affected area(s). This helps to avoid
confusion and facilitate the audit process.
Module 16- 4

September 2003
Consider integrating your EMS and regulatory compliance audit processes, but keep in
mind that these audit processes have different purposes. While you might want to
communicate the results of EMS audits widely within your organization, the results of
compliance audits might need to be communicated in a more limited fashion.
Final thought: An EMS audit is a check on how well your system meets your established
EMS requirements. An EMS audit is not an audit of how well employees do their jobs.
In addition, audits should be judged on the quality of findings, rather than on the number
of findings.
Figure 16-1:
Linkages Among EMS Audits, Corrective Action and
Management Reviews
Periodic
EMS Audits
EMS
Established
Corrective Action
Process
Management
Reviews
Exhibit 16-1 is a worksheet that will guide your facility in establishing and implementing an
EMS audit program. Exhibit 16-2 provides a sample procedure for conducting internal EMS
audits. Exhibits 16-3, 16-4, 16-5, 16-6, and 16-7 are sample forms that can be used to document
planning, implementation, reporting, and follow-up associated with your internal EMS audits.
Examples 16-1 and 16-2 are sample questionnaires/checklists that you can customize for use in
guiding the work of your internal EMS audit team.
EMS Audits
Module 16- 5

September 2003
TOOLS
Exhibit 16-1: EMS Auditing Worksheet

Have we developed an EMS audit program? If not,
how will this be accomplished?
Who need to be involved in the audit process?
Is there another audit program with which our EMS

audits could be linked (for example, our quality or
health & safety management system audits)?
Have we determined an appropriate audit frequency?

What is the basis for the existing frequency? Should the
frequency of audits be modified?
Have we selected EMS auditors? What are the

qualifications of our auditors?
What training has been conducted or is planned for our

EMS auditors?
Have we conducted EMS audits as described in the

audit program? Where are the results of such audits
described?
How are the results of EMS audits communicated to

top management?
How are the records of these audits maintained?
Our next step on EMS auditing is to
EMS Audits
Module 16- 6

September 2003
Exhibit 16-2: Sample Procedure for EMS Audits

Purpose
To define the process for conducting periodic audits of the environmental management system
(EMS). The procedure defines the process for scheduling, conducting, and reporting of EMS
audits.
Scope
This procedure applies to all internal EMS audits conducted at the site.
The scope of EMS audits may cover all activities and processes comprising the EMS or selected
elements thereof.
General
A.
Internal EMS audits help to ensure the proper implementation and maintenance of the
EMS by verifying that activities conform with documented procedures and that
corrective actions are undertaken and are effective.
B.
All audits are conducted by trained auditors. Auditor training is defined by

Procedure #______. Records of auditor training are maintained in accordance with
Procedure #_______.
C.
When a candidate for EMS auditor is assigned to an audit team, the Lead Auditor will
prepare an evaluation of the candidate auditors performance following the audit.
D.
The EMS Management Representative (EMR) is responsible for maintaining EMS

audit records, including a list of trained auditors, auditor training records, audit
schedules and protocols, and audit reports.
E.
EMS audits are scheduled to ensure that all EMS elements and plant functions are
audited at least once each year. Exhibit 16-3 shall be used to document the facilitys
audit plan.
F.
The EMR is responsible for notifying EMS auditors of any upcoming audits a
reasonable time prior to the scheduled audit date. Plant areas and functions subject to
the EMS audit will also be notified a reasonable time prior to the audit. Exhibit 16-4
shall be used to notify the facilitys EMS audit team.
G.
The Lead Auditor is responsible for ensuring that the audit, audit report and any
feedback to the plant areas or functions covered by the audit is completed per the audit
schedule. Exhibits 16-5 and 16-6 shall be submitted to the EMR in conjunction with
the audit report.
H.
The EMR, in conjunction with the Lead Auditor, is responsible for ensuring that EMS
Audit Findings Forms, Exhibit 16-7, are prepared for audit findings, as appropriate.
EMS Audits
Module 16- 7

September 2003
Procedure
1. Audit Team Selection - One or more auditors comprise an audit team. When the team
consists of more than one auditor, a Lead Auditor will be designated. The Lead Auditor is
responsible for audit team orientation, coordinating the audit process, and coordinating the
preparation of the audit report.
2. Audit Team Orientation - The Lead Auditor will assure that the team is adequately prepared
to initiate the audit. Pertinent policies, procedures, standards, regulatory requirements and
prior audit reports are made available for review by the audit team. Each auditor will have
appropriate audit training, as defined by Procedure #.
3. Written Audit Plan - The Lead Auditor is responsible for ensuring the preparation of a
written plan for the audit. The Internal EMS Audit Checklist may be used as a guide for this
plan.
4. Prior Notification - The plant areas and / or functions to be audited are to be notified a
reasonable time prior to the audit.
5. Conducting the Audit
a. A pre-audit conference is held with appropriate personnel to review the scope, plan
and schedule for the audit.
b. Auditors are at liberty to modify the audit scope and plan if conditions warrant.
c. Objective evidence is examined to verify conformance to EMS requirements,
including operating procedures. All audit findings must be documented.
d. Specific attention is given to corrective actions for audit findings from previous
audits.
e. A post-audit conference is held to present audit findings, clarify any
misunderstandings, and summarize the audit results.
6. Reporting Audit Results
a. The Team Leader prepares the audit report, which summarizes the audit scope,
identifies the audit team, describes sources of evidence used, and summarizes the
audit results.
b. Findings requiring corrective action are entered into the corrective action database.
EMS Audits
Module 16- 8

September 2003
Procedure (contd.)
7. Audit Report Distribution
a. The EMR is responsible for communicating the audit results to responsible area and /
or functional management. Copies of the audit report are made available by the
EMR.
b. The EMR is responsible for ensuring availability of audit reports for purposes of the
annual Management review (see Procedure #).
8. Audit Follow-up
a. Management in the affected areas and / or functions is responsible for any follow-up
actions needed as a result of the audit.
b. The EMR is responsible for tracking the completion and effectiveness of corrective
actions.
9. Record keeping
Audit reports are retained for at least two years from the date of audit completion. The EMR
is responsible for maintaining such records.
EMS Audits
Module 16- 9

September 2003
Exhibit 16-3: Sample Audit Plan Form

Area or Function to
be Audited
EMS Audits
Lead
Auditor
Audit Team
Members
Target
Date
Special Instructions
Module 16- 10

September 2003
Exhibit 16-4: Sample Form for Communications to Audit Team

ENVIRONMENTAL MANAGEMENT SYSTEM AUDIT
Lead Auditor:
Audit Team Members:
Audit Area:
Target Due Date:
Listed above is the area to be audited. The due date given is the target to have the entire audit completed,
including the report and follow-up meeting with the responsible area management. Listed below are the
areas of environmental management systems criteria that you are to assess. If you have any questions,
please call me. Special instructions, if any, are listed below. Thank you for your help. Effective audits
help make an effective environmental management system.
__ Policy
__ Legal and Other Requirements
__ Environmental Aspect identification
__ Objectives and Targets
__ Environmental Management Program
__ Structure and Responsibility
__ Training, Awareness, Competence
__ Communication
__ EMS Documentation
__ Document Control
__ Operational Controls
__ Emergency Preparedness
__ Monitoring and Measurement
__ Nonconformance / Corrective Action
__ Records
__ Management System Audits
__ Management Review
Special Instructions:
EMR (signature)
EMS Audits
Module 16- 11

September 2003
Exhibit 16-5: Sample Form for Internal Assessment Checklist

Internal Assessment Team:
Date of Internal Assessment:
Signed:
EMS Procedures
Check each item assessed (includes auditing of records, where applicable):
__
__
__
__
__
__
__
__
__
__
__
__
__
__
__
__
__
Environmental policy (adherence to policy commitments)

Environmental objectives (progress; implementation of action plans)
EMS responsibilities
Identification of Environmental Aspects
Identification of Legal Requirements
Identification of Significant Environmental Aspects
Development of Objectives, Targets, and Action Plans
Conducting an Alternatives Evaluation
Development of Operational Controls
Environmental Training (Awareness and Task-Specific)
Emergency Preparedness
Review of New Products and Processes
Documentation
Conducting a Compliance Assessment
Conducting an Internal Assessment
Taking Corrective Action
Management Review
EMS Performance
__
__
__
Achieved objective #1
Contact Person:
EMS Audits
Date Completed:
Module 16- 12

September 2003
Exhibit 16-6: Sample EMS Audit Summary Form
EMS AUDIT SUMMARY SHEET

Organization Audited:
Lead Auditor:
Date:
ELEMENT NUMBER AND DESCRIPTION
AUDIT RESULTS
No. of Majors / No. of Minors
4.2
4.3
4.3.1
Planning
4.3.2
4.3.3
4.3.4
Environmental Management Program(s)
4.4
A, N, or X*
Implementation and Operation
4.4.1
4.4.2
4.4.3
Communication
4.4.4
EMS Documentation
4.4.5
Document Control
4.4.6
Operational Control
4.4.7
4.5
Checking and
Corrective Action
4.5.1
4.5.2
Corrective and Preventive Action
4.5.3
Records
4.5.4
EMS Audit
4.6
Management Review
TOTAL
Legend:
A = Acceptable: Interviews and other objective
evidence indicate that the EMS meets all the
requirements of that section of the standard.
N = Not Acceptable: The auditor has made

the judgment that, based on the number and
type of nonconformances, the requirements
of that section of the EMS are not being met.
X = Not Audited
EMS Audits
Module 16- 13

September 2003
Exhibit 16-7: Sample Form for EMS Audit Findings
EMS AUDIT FINDINGS FORM

Type of Finding (circle one):
Nonconformance: Major
Minor
Positive Practice
Recommendation
Description (include where in the organization the finding was identified):

_________________________________________________________________________________
_________________________________________________________________________________
_________________________________________________________________________________
_________________________________________________________________________________
_________________________________________________________________________________
_________________________________________________________________________________
EMS 14001 (or other EMS criteria)

Reference:
Date:
Finding Number:
_______________
_______________
_________________________________
Auditor: __________________________
Auditees Rep.: ______________________
Corrective Action Plan (including time frames):

_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
Preventive Action Taken:
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
Individual Responsible for Completion of the
Corrective Action:
________________________________________
Date Corrective Action Completed:

_____________________________
Corrective Action Verified By:

______________________________________________________Date: ______________
EMS Audits
Module 16- 14

September 2003
EXAMPLES
Example 16-1: Sample Questionnaire for EMS Audits
Principle 1: Management Commitment

1-1
Has your parent company issued a formal, written statement of environmental policy? When? How was
your facility or operation made aware of this policy?
1-2
Has senior management issued a facility-specific, formal, written statement of environmental policy?
When? How were facility personnel made aware of this policy? Do new personnel receive a copy of the
policy? How?
1-3
What procedures are in place for regular review of and updates to the policy?
1-4
Has your facility established short- and long-term environmental goals? Please describe the key
objectives and targets.
1-5
How and by whom are these goals developed? Did representatives of a variety of functions and levels
within the facility work together to develop environmental objectives and targets?
EMS Audits
Module 16- 15

September 2003
Example 16-1: Sample Questionnaire for EMS Audits (Continued)
Principle 1: Management Commitment (Continued)

1-6
What is the basis for your environmental goals? Are they based on compliance with legal requirements?
Parent company directives? Environmental impacts of the facilitys mission? Pollution prevention?
Public perception? Employee initiatives?
1-7
What are your most recent environmental initiatives?
1-8
What is the approval process for new environmental initiatives at your facility?
1-9
How are funds allocated for new environmental initiatives? For the environmental program? Who is
ultimately responsible for these funding decisions?
1-10
Is staffing for the environmental program appropriate to program requirements and facility
environmental goals? What mechanisms exist to adjust staffing level or staff capabilities?
1-11
Are managers familiar with facility and operation-specific environmental policies, regulations, and
pollution prevention opportunities? Do managers participate in process reviews, assessments,
environmental committees, or other activities to improve environmental performance?
1-12
How is this facility perceived by local environmental groups and the surrounding community? Are there
any specific issues, i.e., noise, water quality, that are of particular concern?
EMS Audits
Module 16- 16

September 2003

Principle 2: Compliance Assurance And Pollution Prevention
2-1
How and how often does the facilitys environmental staff communicate with federal, state, and local
regulatory agencies? Historically, how would you characterize the facilitys relationship with these
agencies?
2-2
Has the facility taken advantage of any EPA Technical Assistance programs? Other environmental
technical assistance programs?
2-3
How does facility staff track and interpret new federal, state or local regulations, policies and programs,
or changes to existing regulations, policies, and programs?
2-4
How are programs and procedures updated to reflect these changes?
2-5
How does facility staff maintain environmental documentation and records, e.g., manifests, TRI data?
Who is responsible for reporting to federal or state agencies? Parent company?
2-6
Does the facility have an Emergency Response Plan? Spill Plan? What are the established procedures
for an environmental emergency?
EMS Audits
Module 16- 17

September 2003

Principle 2: Compliance Assurance And Pollution Prevention (Continued)
2-7
Has the facility performed a pollution prevention assessment?
2-8
Does the facility have a pollution prevention plan that addresses all environmental impacts and
compliance programs?
2-9
Does the facility have a formal plan to reduce or eliminate the purchase and use of hazardous materials
and ozone depleting chemicals? Does the facility have a hazardous materials pharmacy or similar
program?
2-10
Does the facility have an affirmative procurement program?
EMS Audits
Module 16- 18

September 2003

Principle 3: Enabling Systems
3-1
Does the facility have a formal, facility-wide environmental training program?
3-2
How are training requirements determined?
3-3
How are training records maintained?
3-4
What is the annual budget for environmental training?
3-5
Is funding available for staff development training opportunities?
3-6
What guidance is provided to staff concerning compliance with new or updated environmental
regulations or policies?
EMS Audits
Module 16- 19

September 2003

Principle 3: Enabling Systems (Continued)
3-7
How do managers communicate environmental performance issues or goals to staff?
3-8
What other mechanisms are used to increase staff environmental awareness? Newsletters? Seminars?
3-9
Is there a formal outreach effort to communicate the facilitys environmental activities and programs to
the community?
3-10
How does the facility evaluate the effectiveness of outreach efforts?
EMS Audits
Module 16- 20

September 2003

Principle 4: Performance And Accountability
4-1
What are the routine reporting relationships between the environmental management program and upper
level management?
4-2
How does the environmental staff communicate with upper management about environmental
performance and the status of specific environmental initiatives?
4-3
How does the environmental program communicate with managers and staff about environmental
performance and the status of environmental initiatives?
4-4
How do employees provide input to environmental decisions?
4-5
Are environmental duties included in staff job descriptions and performance standards?
4-6
How is excellence in environmental performance recognized and rewarded?
4-7
How do managers review and respond to poor environmental performance?
EMS Audits
Module 16- 21

September 2003

Principle 5: Measurement And Improvement
5-1
What mechanisms are used to track and measure facility environmental performance? How often is
such measurement performed?
5-2
Does the facility have a self audit or self monitoring program in place?
5-3
Does facility environmental staff conduct routine facility inspections? Tests of pollution control and
monitoring equipment?
5-4
What are the current procedures for reporting an environmental problem? How does facility
environmental staff track corrective action?
5-5
Does the parent company review facility environmental performance? How often are such reviews
conducted?
5-6
Are written protocols or guidance documents used to conduct environmental performance reviews? Are
summary reports available?
EMS Audits
Module 16- 22

September 2003

Principle 5: Measurement And Improvement (Continued)
5-7
Does this facility participate in any cooperative environmental programs with state, local or private
organizations?
5-8
Does this facility participate in any Federal voluntary initiatives such as ENERGYSTAR or Performance
Track?
5-9
What new environmental initiatives are planned for the facility?
EMS Audits
Module 16- 23

September 2003
Example 16-2: Sample Checklist for Top Management EMS Audits

Function: TOP MANAGEMENT
1.
Top Management
a.
Describe your role in the development of the environmental

policy.
b.
How do you know that your policy is appropriate for your

activities, products, and services?
c.
What is managements role in the review and revision of the

policy?
d.
How does management ensure continued adherence to the

policy throughout the company?
e.
How does the policy help guide organizational decisions?
f.
How are employees made aware of the environmental policy?
g.
How is the policy made available to the public?
Objective Evidence
[Auditor Note: Is there evidence that the policy was issued by top
management? (e.g., Is the policy signed? By whom? At what level
in the organization are they?)]
Notes:
2.
Objectives and targets
Top Management
a.
What are the environmental objectives and targets for your

organization? What is your role in approving them?
What are the relevant functions and levels within your
organization that support the attainment of each of the
objectives and targets?
b.
How are the environmental objectives linked to other

organizational goals (and vice versa)?
c.
Are the objectives/targets consistent with the goals of the

environmental policy for prevention of pollution and continual
improvement?
d.
How were the objectives and targets developed by or

communicated to management?
e.
How does management keep up with progress in meeting their

objectives and targets throughout the year?
f.
How often are you informed of the status of the objectives and
targets?
g.
On what basis are the objectives and targets reviewed and

modified?
Objective Evidence
Notes:
EMS Audits
Module 16- 24

September 2003
Example 16-2: Sample Checklist for Top Management EMS Audits (Continued)
3.
Structure and responsibility
Top Management
a.
Objective Evidence
At what level within the organization is the designated EMS

representative placed?
Auditor Note: Is the EMS representative at a level within the

organization to effectively implement an EMS for his/her
organization?]
b.
What authority does the EMS representative have to carry out

his/her responsibilities?
c.
How does the organization assess its resource needs for

environmental management? How are these factored into
operating and strategic plans (and vice-versa)?
d.
What resources (financial, technical personnel) has

management provided to develop or maintain the EMS?
e.
How are you informed on the performance of the EMS? Do

you receive routine reports?
f.
Are responsibilities for the environmental management of the

organization documented? If so, where?
Is an integrated structure in place in which accountability and
responsibility are defined, understood, and carried out?
g.
How are these responsibilities communicated to all employees

(including managers)?
Notes:
4.
Communication
Top Management
a.
How are you informed of the environmental issues within

your organization? How often does this take place? Does
this include compliance issues?
b.
How are you kept up to date with progress in meeting your

organizations environmental objectives and targets?
How is this information passed on to your managers?
c.
How do you communicate with the organization on

environmental issues?
d.
How does the organization handle inquiries from interested

parties (e.g., the public, regulators, other organizations) on
environmental matters?
Objective Evidence
How is this done? How frequently?
Who has responsibility for responding to such inquiries?
EMS Audits
Module 16- 25

September 2003
Example 16-2: Sample Checklist for Top Management EMS Audits (Continued)
4.6
Management review
Top Management
a.
Describe the organizations management review process.
b.
How often are management reviews performed? How was

this frequency determined?
c.
Who is involved in the management review process? What

are their roles in this process?
d.
What changes have been made to the EMS as a result of the

last review?
Objective Evidence
Notes:
EMS Audits
Module 16- 26

September 2003

Guidance ................................................................................................................................... 17-2
Tools .......................................................................................................................................... 17-5
Exhibit 17-1:
Exhibit 17-2:
Exhibit 17-3:
Management Review
Management Review Worksheet ........................................................ 17-5

Sample Procedure for Management Review....................................... 17-6
Sample Management Review Record................................................. 17-7
Module 17 - 1

September 2003
GUIDANCE
Management reviews are one key to continual improvement and for ensuring that the EMS will
continue to meet your organizations needs over time.
The goal of the review allows management to bring about overall improvements. The scope and
frequency of the review should depend upon the size and complexity of the organization and the
complexity and amount of activity of your EMS.
To maintain continual improvement, suitability, and effectiveness of your environmental
management system, and thereby its performance, your organizations senior management
should review and evaluate the environmental management system at defined intervals, such as
quarterly. The scope of the review should be comprehensive, though not all elements of an
environmental management system need to be reviewed at once, and the review process may
take place over a period of time. Review of the policy, objectives, and procedures should be
carried out by the level of management that define them. Following is a checklist of some of the
things that should be included in the management review:
x
results from assessment;
the extent to which objectives and targets have been met;
the continuing suitability of the environmental management system in relation to changing

conditions and information; and
concerns among relevant interested parties.
Create a continual improvement plan and check progress. Document observations, conclusions,
and recommendations for necessary action. Assign action items for follow-up, and schedule the
next regular review.
Management reviews also offer a great opportunity to keep your EMS efficient and costeffective. For example, some organizations have found that certain procedures and processes
initially put in place were not needed to achieve their environmental objectives or to control key
processes. If EMS procedures and other activities dont add value, eliminate them.
Management Review
Module 17 - 2

September 2003
Questions for Management to Consider Include

1.
2.
Is our environmental policy still relevant to what we do?

Are we making performance toward objectives, targets and EMPs? (Charts, tables
and graphs are encouraged to show results.)
3. Can we set new measurable performance objectives?
4. What are the results of our internal audits?
5. What is the status of corrective and preventive actions?
6. Are roles and responsibilities clear and do they make sense?
7. Are we applying resources appropriately?
8. Are we meeting our regulatory obligations?
9. Do changes in laws or regulations require us to change some of our approaches?
10. Are the procedures clear and adequate? Do we need others? Should we eliminate
some?
11. What effects have changes in materials, products, or services had on our EMS and
its effectiveness?
12. What stakeholder concerns have been raised since our last review?
The key question that a management review seeks to answer:
Is the system working? (i.e., is it suitable, adequate, and effective, given our needs?)
Hints
x
Two kinds of people should be involved in the management review process:

o people who have the right information / knowledge,
o people who can make decisions about the organization and its resources (top
management).
Determine management review frequency that will work best for your organization.
Some organizations combine these reviews with other meetings (such as director
meetings). Other organizations hold stand-alone reviews. At a minimum, consider
conducting management reviews at least once per year.
During management review meetings, make sure that someone records what issues were
discussed, what decisions were arrived at, and what action items were selected. Results
of management reviews should be documented.
Management reviews should assess how changing circumstances might influence the
suitability, effectiveness, or adequacy of your EMS. Changing circumstances might be
internal to your organization (such as new facilities, new raw materials, changes in
Management Review
Module 17 - 3

September 2003
x
x
products or services, new customers, etc.) or might be external factors (such as new
laws, new scientific information or changes in adjacent land use).
After documenting the action items arising from your management review, be sure that
someone follows up. Progress on action items should be tracked to completion.
As you assess potential changes to your EMS, consider other organizational plans and
goals. In this way, environmental decision-making can be integrated into your overall
management and strategy.
Exhibit 17-1 is a questionnaire to guide your facility in establishing and maintaining an EMS
Management Review element. If you desire to make a documented procedure for Management
Review of your facilitys EMS, then Exhibit 17-2 is an example of a procedure you could adapt.
Exhibit 17-3 can be used to record implementation of your procedure.
Management Review
Module 17 - 4

September 2003
TOOLS
Exhibit 17-1: Management Review Worksheet
Do we have an existing process for conducting
management reviews?
If yes, does that process need to be revised? In what
way?

organization?
When is the best time for us to implement this process?

Can this effort be linked to an existing organizational
process (such as our budget, annual planning, or auditing
cycles?)
How frequently are management reviews? What is the

basis for this frequency?
Should we conduct reviews more or less frequently?
Who is responsible for gathering the information

needed to conduct management reviews? Who is
responsible for presenting this information?
How do we ensure that changing circumstances (both

internal and external to the organization) are considered
in this process?
How do we ensure that the recommendations of

management reviews are tracked and acted upon?
Our next step on management review is to
Management Review
Module 17 - 5

September 2003
Exhibit 17-2: Sample Procedure for Management Review

Purpose
To ensure the effectiveness of the EMS and its continual improvement, [Your Facilitys Name]
top management periodically reviews the important elements and outcomes of the EMS.
General
The Management Review process is intended to provide a forum for discussion and
improvement of the EMS and to provide management with a vehicle for making any changes to
the EMS necessary to achieve the organizations goals.
Procedure
1.
In preparation for the management review, the EMS management representative (EMR)
gathers the following information and makes it available to top plant management,
including the owner and President of [your corporation] and the plant manager:
x Environmental policy
x List of the Cross Functional Team (CFT) members and others responsible for
major parts of the EMS
x List of significant environmental aspects and criteria of significance
x Update on compliance status of the plant and on any potential upcoming
regulations that might require an advance strategy
x List of environmental objectives and targets
x Environmental performance results (from monitoring and measuring Significant
Environmental Aspect indicators and indicators of progress toward environmental
objectives and targets)
x Bullet-point descriptions of other accomplishments of the EMS (e.g., number of
people trained)
x Results of most recent EMS internal assessment, compliance assessment and
corrective actions taken
x Description and documentation of feedback from stakeholders (if received)
x Analysis of the costs and benefits of the EMS (as quantitative as possible)
2.
Top plant management meets to review and discuss the information presented. The EMR
and EMS Coordinator will also be present. Depending on its review, top management
may direct specific and/or significant changes in the scale and direction of the EMS in
order to improve its effectiveness and business value. The conclusions and directives that
result from the management review are recorded in module 17 and kept by the EMS
Coordinator.
Management Review
Module 17 - 6

September 2003
Frequency
Quarterly.
Records
Results of management reviews are recorded using the form in Exhibit 17-3. Records are kept
by the EMS Coordinator.
Management Review
Module 17 - 7

September 2003
Exhibit 17-3: Sample Management Review Record

Date of review meeting
Persons present at meeting
Name
Position
Conclusions
Actions to be taken
Signed:
______________________________
Environmental Management
Representative
Management Review
Person(s) responsible
__________________________
Plant Manager
Module 17 - 8

September 2003
Appendix A
EPAs National Environmental Performance Track
The National Environmental Performance Track is designed to recognize and encourage top
environmental performers - facilities that go beyond compliance with regulatory requirements to
attain levels of environmental performance and management that benefit employees,
communities, and the environment. As top environmental performers, Performance Track
participants earn access to a unique benefits package that includes recognition, better
information, and administrative streamlining. Performance Track is open to facilities of all
types, sizes, and complexity, public or private, manufacturing or service-oriented.
To qualify for Performance Track, facilities must have:
$
$
$
$
A systematic approach to managing environmental responsibilities (an EMS);

A strong record of environmental compliance;
Demonstrated continual environmental improvement; and
A commitment to community outreach and public reporting.
Specific Environmental Management Systems (EMS) Requirements

Facilities applying to the Performance Track program must meet several EMS requirements to be
accepted.1 A facility will need to certify that it has an EMS in place by having an independent
assessment of its EMS conducted within three years prior to the date of application. The EMS
will include the elements listed below (i.e. planning, setting performance objectives, EMS
program implementation, performance evaluation, corrective action, and management review)
and will have gone through at least one full cycle of implementation. A facility that has adopted
an EMS based on the Plan-Do-Check-Act framework would meet most of these elements.
EPA recognizes that the scope and level of formality of the EMS will vary depending on the
nature, size, and complexity of the facility. EPAs experience with a variety of programs
suggests that the required EMS elements are within the capacity of small facilities and can be
met through a variety of approaches. To help small facilities implement an EMS, EPA provides
guidance documents and assistance materials.
For purposes of the Performance Track program, an EMS represents an organizations systematic efforts
to meet its environmental requirements, including maintaining compliance and achieving performance objectives
that may be related to unregulated aspects of the organizations activities.
Appendix A-1

September 2003
A facility applying to Performance Track will certify that it has implemented an EMS that
includes these elements:
Policy
$
A written environmental policy, defined by top facility management, that includes

commitments to: (1) compliance with both legal requirements and voluntary
commitments; (2) pollution prevention; (3) continuous improvement in environmental
performance, including areas not subject to regulations; and (4) sharing information on
environmental performance and the operation of the EMS with the community.
Planning
$
$
Identification of significant environmental aspects and legal requirements, including

procedures for integrating anticipated changes to the facility's requirements or
commitments into the EMS.2
Measurable objectives and targets to meet policy commitments and legal requirements, to
reduce the facility's significant environmental impacts, and to meet the performance
commitments made as part of the facility's participation in Performance Track. In setting
objectives and targets, the facility should consider the following criteria: preventing noncompliance, preventing pollution at its source, minimizing cross-media pollutant
transfers, and improving environmental performance.
Active, documented programs to achieve the objectives, targets, and commitments in the
EMS, including the means and time frames for their completion.
Implementation and Operation

$
$
Established roles and responsibilities for meeting objectives and targets of the overall
EMS and compliance with legal requirements, including a top management
representative with authority and responsibility for the EMS.
Defined procedures for: (1) achieving and maintaining compliance and meeting
performance objectives; (2) communicating relevant information regarding the EMS,
including the facility's environmental performance, throughout the organization; (3)
providing appropriate incentives for personnel to meet the EMS requirements; and (4)
document control, including where documents related to the EMS will be located and
who will maintain them.
An environmental aspect is defined as an element of an organizations activities, products, or services

that can interact with the environment. Facilities are asked to use their list of significant environmental aspects in
selecting performance commitments under this program.
Appendix A-2

September 2003
$
$
General environmental training programs for all employees, and specific training for
those whose jobs and responsibilities involve activities directly related to achieving
objectives and targets and to compliance with legal requirements.
Documentation of the key EMS elements, including the environmental policy, significant
environmental aspects, objectives and targets, top management representation,
compliance audit program, EMS audit program, and overall EMS authority.
Checking and Corrective Action

$
$
An active program for assessing performance and preventing and detecting nonconformance with legal and other requirements of the EMS, including an established
compliance audit program and an EMS audit program.
An active program for prompt, corrective action of any non-conformance with legal
requirements and other EMS requirements.
Management Review
$
Documented management review of performance against the established objectives and

targets and the effectiveness of the EMS in meeting policy commitments.
Special Consideration for Small Businesses

Any program for improving environmental performance must aim for participation by small
businesses and other small entities, such as local governments. EPA is making every effort to
make Performance Track accessible for small entities. This effort is reflected in several aspects
of the design. For example, depending on the nature and extent of a facilitys operations, the
EMS for a small facility may be simpler than one for a larger, more complex facility. In
addition, a small facility is not asked to make as many performance commitments as other
participants.
For more information about the National Environmental Performance Track, see the following:
Web: www.epa.gov/performancetrack
E-Mail - Performance Track Information Center: [email protected]
Phone - Performance Track Information Center: (888) 339-PTRK
Appendix A-3

September 2003
Appendix B
Integration of Environmental Management Systems and
Quality Management Systems
Integrating management systems has become an increasingly important competitive issue. A
growing body of information indicates that organizations that integrate their EMS and quality
management systems (QMS) can realize significant benefits, such as streamlined operations and
decision-making, simplified employee training, more efficient use of resources and reduction in
audit costs. Systems for managing health & safety and other organizational functions can be
similarly integrated.
The two most common models for QMS and EMS (ISO 9001 and ISO 14001, respectively) share
many common elements. This should be no great surprise, because ISO 9001: 1994 was one of
the source documents used by the drafters of ISO 14001. The two standards are very compatible
in their current forms. The ISO committees responsible for the development and maintenance of
these two standards continue to examine potential opportunities to increase the compatibility or
alignment of the two standards.
Organizations that choose to implement both of these standards generally find that they can use
many common processes to conform. In general, the elements of a QMS and an EMS can be
categorized as either (1) essentially the same, (2) similar or (3) unique (See Figure B-1). System
elements in both the essentially the same and similar categories can often be addressed by a
common procedure (or parallel procedures), although some customization may be needed to
address the differing overall purposes of these systems. Unique elements are typically dealt with
in separate (EMS or QMS) procedures. Some of the typical elements for integration include:
document control, corrective/preventive action, training, records management, and management
review. However, some organizations have gone much further for example, some have
developed common (quality and environmental) policies. The degree of system integration varies
widely from organization to organization.
While an EMS can be readily integrated with an existing QMS, the overall purposes of these two
systems must be kept in mind. A QMS is intended primarily to ensure that an organization
satisfies its customers by assuring the quality of its products. An EMS generally has a broader
context the relationship between an organization and the environment in which it operates.
Also, an EMS often concerns itself with a broader range of stakeholders, such as neighboring
communities, customers, and regulatory agencies.
System integration can have environmental benefits. By linking environmental management
more closely with day-to-day planning and operation, some organizations have been able to raise
the visibility of environmental management as a core organizational issue. In addition, these
organizations enhance their abilities to address environmental issues when making modifications
to products or processes for quality purposes.
Appendix B-1

September 2003
Organizations that have a QMS in place generally are better off when implementing an EMS for
several reasons. First, employees typically are already familiar with management system
concepts and are involved in making the system work. Second, many of the processes needed for
the EMS might already be in place. Finally (and perhaps most importantly), top management has
committed the use of management systems to achieve organizational goals.
Figure B-1. Relationship of EMS Elements to QMS (based on ISO 9001: 1994)
Elements that are Essentially the Same
)Training, Awareness & Competence
)Document Control
)Nonconformance, Corrective & Preventive Action
)Calibration (part of the Monitoring & Measurement element)
)Records
Elements that are Similar
)Environmental Policy
)Structure and Responsibility
)EMS Documentation
)Operational Control
)Monitoring & Measurement
)EMS Audit
)Management Review
Elements that are Unique
)Environmental Aspects
)Legal and Other Requirements
)Objectives & Targets
)Environmental Management Program(s) Communications
)Emergency Preparedness & Response
Appendix B-2

September 2003
A Few Tips on System Integration

For organizations that have an existing QMS and wish to integrate an EMS with it, some
suggestions are provided below.
)Understand the existing QMS, its effectiveness and how the workforce perceives the system.
Is the existing QMS documentation clear and workable? Do employees believe that the system is
helping the organization to achieve desired results?
)Ensure that the scope of the two systems will be consistent (i.e., that the systems will cover
the same facilities, products, activities and/or services). In particular, this will be an important
issue if third-party registration will be sought.
)Establish a cross-functional team (including, at a minimum, representatives from the
environmental and quality functions) to determine the optimal approach to system integration.
)As needed, manage resistance to change. Some employees and managers may be reluctant
to change a system that they are already familiar with and/or in which they have important roles.
)Understand how QMS and EMS differ in purpose. While there are many common
management system elements, there are elements of each system that are unique (see below). In
the case of EMS, these include for example, environmental aspects, communications, and
emergency preparedness and response. These differences must be acknowledged and
accommodated within the integrated management system.
)Modify system documentation as required. Keep procedures simple and clear for users.
Review proposed changes with affected managers and employees.
)On a procedure-by-procedure basis, consider whether to integrate procedures or keep them
separate. While integration can reduce the total number of procedures or work instructions, it
also can confuse the overall purpose of such procedures in some cases.
)Once the integrated system documentation has been prepared, train managers and
employees on the integrated system.
)Audit the integrated system and take actions as necessary.
A few final thoughts on system integration:
xCan your organization afford to have two or more separate systems?
xAre there compelling reasons to keep these systems separate?
xWhat is the optimal approach from a strategic and operational standpoint?
xWhat approach is best suited for the organizations change and growth?
Appendix B-3

September 2003
Appendix C
Health and Safety Integration Questionnaire
Tip: Remember to consider health and safety of workers, as well as people outside your plant, when evaluating known
health concerns.
1. Does your company have an Environmental, Health & Safety Policy?
x Is this policy written down?
x Where is it located?
x How many employees know about this policy?
x How did they learn of it? Is it included in a training or orientation program?
x Do employees have the opportunity to make suggestions regarding environmental
concerns?
x What points are included in this policy?
Does your company have specific environmental or health & safety goals?
x Are these documented?
x How are these communicated to employees?
x Is there a way of tracking whether goals are met?
x Are there penalties within the company for not achieving the objectives?
x Is there a way to change these goals when changes in processes, production, or activities
occur? How are these changes communicated?
Does your company have a process to identify all environmental, health & safety regulatory
requirements?
x Has your company conducted compliance audits?
x Has your company received any fines or penalties requiring corrective action?
x Has your company experienced difficulties in complying with regulations?
x Are some regulations difficult/costly to meet?
x Does your company know whom to contact at local, state, and federal regulatory
agencies in the event of environmental accidents or compliance concerns?
x Does your company have a mechanism for staying up to date on changing regulations?
How does your company evaluate risk to human health & safety and the environment caused
by your business operations? How is this information incorporated into planning for
business activities/production?
Is there a process within the company to review any changes in products or processes with
an eye toward environmental concerns?
Appendix C-1

September 2003
Tip: As you discuss these questions, it will be beneficial to write down the answers for reference as you proceed with the
following modules.
Are there policies and procedures regarding procurement and contracting that consider
environmental concerns?
What training is offered at your company that would support environmental objectives?
x Do employees receive environmental, health & safety training? What percent of
employees? Which ones?
x How is that training documented? Where are the records kept?
x Is there provision for regular training on environmental, health & safety requirements?
Tip: As you discuss these questions, it will be beneficial to write down the answers for reference as you proceed with the
following modules.
Does your company have a procedure for responding to suggestions regarding
environmental concerns that it may receive from customers, neighbors, or employees?
x Is there a process for soliciting and recording any suggestions? Where are these
records kept?
x Is there a process for following up on any of these suggestions to be sure that appropriate
action was taken?
Tip: You should review your policy statement as you complete the modules following this one to determine whether
changes need to be made.
How does your company keep track of its documents?
x Is there a filing system?
x How many people are familiar with the system?
x How many people have access to it?
x How could someone find information relating to environmental, health & safety
concerns? Are there Material Safety Data Sheets (MSDS) available? Does your company
have documented standard operating procedures for plant operations, emergencies, or
document control?
x How are decisions made about when to dispose of documents?
How does your company identify potential accidents or emergency situations?
x Are emergency procedures documented?
x How do employees find out about them? Is there regular training?
x Are these procedures periodically tested, evaluated, and revised as needed?
x Have there been failures in response to accidents or emergency situations?
x Is there a communications plan in place in the event of emergencies?
Appendix C-2

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ENVIRONMENTAL MANAGEMENT SYSTEM (EMS)

TEMPLATE FOR THE

ENVIRONMENTAL MANAGEMENT SYSTEM (EMS)

Laying the groundwork and obtaining top management commitment

Developing policy and planning elements

Developing implementation elements

Developing corrective and preventive action, management review, and continuous

More information on the Performance Track program is provided in Appendix A.

Integrated Environmental Management Systems Implementation Guide, US EPA, Office

Environmental Management Review (EMR) National Report: Lessons Learned in

Improving Environmental Performance and Compliance, 10 Elements of Effective

Die Casting- EMS Template

Die Casting- EMS Template

Index of Exhibits and Examples

Sample Worksheet for EMS Development: Participants,

Module 2: Environmental Policy

Sample Procedure for Identification of Environmental Aspects and

Module 4: Legal and Other Requirements

Legal and Other Requirements Worksheet .............................................. 4-4

Die Casting- EMS Template

Module 5: Objectives and Targets

Objectives and Targets Worksheet .......................................................... 5-5

Module 6: Environmental Management Programs

Environmental Management Program Worksheet................................... 6-4

Module 7: Structure and Responsibility

Structure & Responsibility Worksheet .................................................... 7-3

Module 8: Training, Awareness, and Competence

Training, Awareness & Competence Worksheet..................................... 8-5

Communications Worksheet.................................................................... 9-6

Die Casting- EMS Template

Module 10: EMS Documentation and Document Control

EMS Documentation Worksheet ........................................................... 10-6

Module 11: Operational Control

Operational Controls Worksheet............................................................ 11-6

Module 12: Emergency Preparedness and Response

Emergency Preparedness and Response Worksheet.............................. 12-4

Module 13: Monitoring and Measurement

Monitoring and Measurement Worksheet ............................................. 13-5

Module 14: Nonconformance and Corrective and Preventive Action

Corrective & Preventive Action Worksheet .......................................... 14-5

Die Casting- EMS Template

Module 15: Records

Records Management Worksheet .......................................................... 15-4

Module 16: EMS Audits

EMS Auditing Worksheet...................................................................... 16-6

Module 17: Management Review

Management Review Worksheet ........................................................... 17-5

Die Casting- EMS Template

Die Casting Industry - EMS Template

Module 1: Laying the Groundwork for EMS

Laying the Groundwork for EMS

Die Casting Industry - EMS Template

Laying the Groundwork for EMS

Die Casting Industry - EMS Template

EMS Planning - Gap Analysis

What standards of environmental performance does the organization hope to achieve?

Where are there gaps between objectives and performance?

Laying the Groundwork for EMS