Municipal EMS Guidebook

Environmental Management Systems

An Environmental Management System (EMS) is a systematic
approach for incorporating energy and environmental goals and
priorities (such as energy use and regulatory compliance) into
routine operations. While some sort of de facto system is
inherent to any organization that must meet energy and
environmental requirements as part of daily operations, it is
generally accepted as a valuable step to formalize the approach
by documenting it. Not only does documentation of the system
ensure consistency over time and across employees, there is a
growing body of evidence indicating that there is considerable
value in defining a systematic approach to managing energy and
environmental goals.
Please note that, while this guidebook refers to “Energy and
Environmental” in many locations, it is understood that an EMS
encompasses a wide perspective, including the consumption of
natural resources such as water, air and various energy sources,
as well as the more traditional concepts of waste generation and
disposal, pollution and use of human resources. The US EPA
defines an EMS as “a set [or system] of processes and practices
Figure 1:
that enable an organization to reduce its environmental impacts
and increase its operating efficiency.” This focus on processes Plan, Do, Check, Feedback Cycle
and practices is common to all EMSs, which are generally
founded on the “Plan, Do Check, Feedback” cycle1 of
continuous improvement (see Figure 1).

EMS Models
More than one model or conceptual framework for an EMS EMS Models
exists. Probably the most well known of EMS models is the
• ISO 14001
ISO 14001 international standard. Other models include the
following: • EMAS

• ACC Responsible Care

• European Eco-Management and Audit Scheme
(EMAS); • DOJ 7 Key Elements
• Responsible Care model developed by the American • EPA NEIC Compliance Focused
Chemical Council (ACC); EMS
• US Department of Justice (DOJ) “Seven Key • DEP College & University EMS and
Compliance Program Elements;” and Best Practices Manual
• EPA National Enforcement Investigation Center • National Biosolids Partnership EMS
(NEIC) “Compliance Focused” EMS.

1
The “Plan, Do, Check, Act” (or Feedback) Cycle was originally illustrated by Walter Shewhart for the continuous improvement of
product quality, and [most notably] implemented by W. Edwards Deming in post-WWII Japan.
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In the United States, the most commonly accepted model is that

set forth by the ISO 14001 standard. There are also variations
of the ISO 14001 model that have been developed for
organizations that do not wish to certify to the ISO 14001
standard, such as the DEP EMS for Colleges and Universities,
and the National Biosolids Partnership EMS. As noted above,
all EMS models are based on a “Plan, Do, Check, Feedback”
cycle that is primarily concerned with the process an organization
uses to incorporate environmental concerns into routine
operations and not the operations themselves.

Complementary Systems and Tools

Growing industrial and government interest in energy and
environmental management has led to the development of a
number of concepts and tools that enable organizations to
understand, evaluate and manage the environmental
implications of their operations, services and products. Some
tools are:
• Green procurement;
• Sustainable community planning;
• Life cycle management;
• Life cycle assessment; and
• Sustainable design.
In practice, many of these tools can be applied within
Environmental Management Systems as well as existing quality,
energy, or health and safety management systems such as:
• ISO 9001, QS 9000;
• ANSI/MSE 2000 - Management System for Energy;
and
• OHSAS 18001 – Occupational Health and Safety
Assessment Series.
In addition several management systems are emerging that are
more encompassing of multiple business issues such social,
ethical, stakeholder, accountability and reporting performance.
Some of these "sustainable management systems" are:
• SA8000 - Social Accountability Management System;
and
• AcountAbility 1000 Framework

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The “plan, do, check, feedback” cycle is often common to these

systems. In addition many of these systems are designed to be
compatible with ISO 9000, QS 9000 and ISO 14001. Whether
an organization adopts one of these more encompassing
systems depends largely on the nature of their organizational
activities and risks associated with specific issues. An
organization with a range of risks and issues across an number
of these areas, including environmental, may consider these
systems as a means towards more comprehensive risk
management and continuous improvement. On the other hand,
municipalities with some social, ethical or accountability risks that
overlap with their environmental issues may choose to address
these within their existing management practices or anEMS.

The ISO 14001 EMS Model

According to the international standard, ISO 14001, an
Environmental Management System (EMS) is “the part of the
overall management system that includes organizational
structure, planning activities, responsibilities, practices,
procedures, processes, and resources for developing,
implementing, achieving, reviewing and maintaining the
environmental policy.” While this is a more complex definition
than previously provided, it still implies the same cycle of “Plan,
Do, Check, Feedback.” The ISO 14001 EMS standard consists
of five sections, Environmental Policy, Planning,
Implementation & Operations, Checking and Corrective Action,
and Management Review, as presented in Figure 2 below.

Environmental
Policy

Management
Reviews
Planning

Checking &
Corrective Action
Implementation

Figure 2: The ISO 14001 EMS Model

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The boxes shown in Figure 2 are considered to be the five major

sections of the ISO 14001 EMS Model, and are described in the
standard as follows:
Environmental Policy – Establishes and communicates an
organization’s position and commitment as it relates to
energy and the environment.
Planning – Identifies energy and environmental issues and
requirements, and defines the initiatives and resources
needed to achieve the environmental policy and economic
goals.
Implementation & Operations – Describes the procedures,
programs and responsibilities necessary to implement the
key initiatives to achieve goals.
Checking and Corrective Action – Regularly monitors and assesses
the effectiveness of energy and environmental management
activities.
Management Review – High-level evaluation of the management
system as a whole to determine its overall effectiveness in
terms of driving continual improvement and achieving
business goals.

The ISO 14001 Seventeen Elements

The ISO 14001 standard then breaks the five major sections
down into seventeen elements described below:
Environmental Policy – The policy drives the commitment of the
municipality to maintain and potentially improve its
environmental performance. By documenting and
publicizing the policy, the municipality demonstrates a
commitment to the management of environmental issues
from the highest management levels.
Environmental Aspects – Environmental aspects are the municipal
activities that have the potential to interact with the
environment in some way, potentially posing a risk if they
are not managed appropriately.
Legal and Other Requirements – The legal and other requirements
are those requirements the municipality is expected to
comply with on a continual basis. Besides legal
requirements, these could be the expectations of the local
community or other local municipalities.

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Objectives and Targets – Objectives and targets form the goals of a

municipality’s EMS. Drawing on the information gained in the
Aspects study, a municipality develops goals for improving
its performance in regard to specific activities.
Environmental Management Programs – These programs define the
methods a municipality will use to achieve its objectives and
targets.
Structure and Responsibility – Much like an organizational chart, the
structure and responsibility of the municipality defines the
authority structure in place. The definition of responsibility
takes it another step further, defining who is responsible for
what within municipal operations.
Training, Awareness & Competence – This element of an EMS
defines what training and minimum competence levels are
required to ensure that environmental risks are managed
appropriately, who receives the training, and how often.
Communications – The communications element of an EMS
defines how internal and external communications with
respect to environmental issues are handled. This can be
quite useful in regards to requests for information from the
local community.
EMS Documentation – The documentation element defines the
structure of the EMS itself. This is typically only needed if a
full EMS is implemented.
Document Control – This element focuses on the maintenance and
control of EMS documents required to maintain the EMS.
Operational Control – The operational control element focuses on
the level of operation control that is applied to
environmental risks within the municipality. Many
municipalities find this element particularly useful in the
documentation of standard operating procedures that have
previously not been written down.
Emergency Preparedness and Response – This EMS element outlines
the procedures by which the municipality responds to
environmental emergencies, and the maintenance of a
minimum level of preparedness.
Monitoring and Measurement – This element describes how a
municipality monitors its environmental performance, what
procedures are used to measure the appropriate data sources,
and how often they are measured.

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Nonconformance & Corrective and Preventative Action – This EMS

element outlines how a municipality investigates and corrects
non-conformances.
Records – The EMS records element describes how the
municipality handles and controls the larger scope of
documents related to the EMS, such as training records,
compliance reports, and letters to regulators.
EMS [internal] Audit – The auditing element of the EMS
outlines how a municipality audits its environmental
performance
Management Review – This element of the EMS describes how the
municipality coordinates performance reviews by top
management and drives the process of continual
improvement.

Levels of EMS Implementation

While one of the most common levels of EMS implementation
is through third party certification, other levels of EMS
implementation exist. For example, a municipality may wish to
forego the cost of certification and self-declare that it has met
the ISO requirements without seeking certification through a
third party audit. Alternatively, a municipality may implement a
complete EMS but have a third party provide independent
verification that it has meet the ISO requirements. Finally, some
municipalities may decide that only certain elements of an EMS
need to be implemented to improve their performance or
reduce risks. It is important to recognize however, that full,
long-term benefits such as on-going risk management and
continuous improvement can only be realized if all of the EMS
elements are implemented.
These three levels of EMS implementation are described below
in more detail.

Level One - Third Party Certification to ISO 14001

In order to demonstrate conformance to the ISO 14001
standard, many organizations choose to implement and then
certify their EMS using a third-party auditor (or “registrar”).
The auditor performs an independent validation that the EMS
conforms to the ISO 14001 standard, and that it is “in place,
complete and sufficient.” A number of auditing firms provide this
service, all of which must be certified as qualified auditors.

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Information on registrars can be found on the Pennsylvania

DEP’s website.

Level Two – Complete EMS Implementation Without Certification

The second level is full EMS implementation without choosing
to certify the EMS through a third party audit. In this case, the
municipality typically chooses to self-declare that its EMS is in
conformance to the ISO standard. Self-declaration allows a
municipality to demonstrate and communicate its environmental
commitment to regulators and the public without incurring the
additional costs of certification. However, a third party might be
used to strengthen the self-declaration by providing some level
of independent verification and/or advice.
In some cases, a municipality may choose to simply implement a
complete EMS and not to publicize their efforts or benefits to
regulators or the public, but instead focus on internal
stakeholders, employees and other levels of government.
A municipality with an extremely large number of dispersed
facilities may rule out certification because the registrar costs
outweigh the benefits. However, choosing not to certify does
not reduce the internal benefits that a municipality can realize
through an EMS. It may allow for increased flexibility in
implementation. For example, some organizations may identify
priority sites or activities that require a complete EMS, while
other sites or activities only require an implementation of
specific EMS elements (e.g. training but no operational
controls). This approach allows a municipality to quickly realize
the full benefits of having an EMS for these sites or locations
where it is appropriate and giving them a longer period to assess
whether or not the other sites require additional elements.
Limiting the initial investment in EMS implementation also
makes it easier to modify plans in the future.
The major weakness of non-certification is that it removes the
confirmation inherent in the regular, biannual review and
assessment that a third party registrar provides. Many
organizations see this external review as the "boot" that kicks
them into action and guards against complacency. Non-
certification is un-common in industry because most companies
desire the additional benefits gained from certification to the
ISO standard (e.g. meeting customer expectations). However, in
a municipal setting, self-declaration or full implementation
without certification may be a desirable and cost-effective
option.

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Level Three - Partial EMS Implementation Strategies

While a complete EMS is recognized as the most effective
manner to integrate environmental concerns into daily work
activities, an organization does not always possess the resources to
implement a complete EMS. Furthermore, a complete EMS
does not always make sense for every municipality. In these
cases, partial implementation of an EMS through some of the
elements – such as training programs and/or assessment of legal
and other requirements – can be a desirable alternative for
municipalities.
Even if a municipality determines that a complete EMS is not
appropriate, it is still recommended that they consider the first
two phases of implementation that involve policy development,
management commitment, planning and information
management (described in Section 5). Municipalities may find it
particularly helpful to assess the aspects of their operations that
have the potential to impact energy use and the environment
(within Phase 2). This assessment will often indicate whether the
municipality has adequately protected the environment from any
risks presented by its operations. Often, the municipality
identifies one or two aspects of its operations that need
attention, but do not warrant the implementation of a complete
EMS. Municipalities often choose to:
• Enhance training programs around those aspects to
increase employee awareness and participation;
• Implement standard operating procedures around those
operations to ensure they are managed appropriately;
• Define the structure and responsibility of the
environmental group in order to ensure that all staff
understand the tasks they are responsible for;
• Develop an emergency response and preparedness plan
to prepare for unanticipated catastrophic events; and/or
• Define how it deals with notices of violations and
implements corrective actions in response to them.
Note that while it is recommended that a municipality perform
an analysis of its significant impacts (to determine which
activities have the biggest environmental risk), it is possible that
they already understand those risks, and can proceed directly
with implementation of the appropriate EMS element.
Historically, municipal environmental departments have been
driven by both statutory requirements and the requirements of
the local community – possibly due to the “tradition” of

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environmental law being set most broadly by the highest

(Federal) level of government and then being made increasingly
more restrictive by lower levels of government (State, County,
Township, Borough, etc.) to insure that the overall
environmental objectives of the law are achieved.
In order to develop a concrete understanding of those
requirements, the municipality may wish to develop and
maintain a register or database of all “Legal and Other
Requirements” to which it is subject. This register can then be
used as an internal auditing tool to determine if the municipality
is, in fact, maintaining compliance with all of those
requirements, and stay up to date on additional requirements
that may develop over time.

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Environmental Management Systems in

Municipalities
Since its publication in 1996, the manufacturing industry has EMS Benefits in Pennsylvania:
Lucent Technologies &
embraced the concept of Environmental Management Systems. Mott’s, Inc.
However the ISO standard was not designed specifically for
Lucent Technologies Microelectronics
implementation in manufacturing, or even just for-profit
Group (Allentown, PA) certified iits
businesses; it specifically uses the word “organization” to imply EMS to the ISO 14001 Standard in
any group of individuals that come together for a specific 1997. As a result of the EMS
purpose under a specific administrative structure. The benefits implementation, the company now
of the EMS approach – which will also be discussed in this recovers over 155,000 gallons of de-
ionized water per day, and realizes an
section – have led to its application in other locations, such as energy savings of over $500,000
local governments, with similar success. Several pilot studies annually. Lucent received the 1998
have been commissioned at the International, Federal and State Governor’s Award for Environmental
levels to demonstrate this, and the evidence is clear that Excellence for this effort.
municipalities can realize benefits at least equal to those Motts, Inc. (Aspers, PA) certified iits
achieved by business. EMS to the ISO 14001 Standard in
1998. As a result of the EMS project,
Much like businesses, municipal governments have a complex the company diverted 17,000 tons of
system of organizational management and are subject to large waste from landfill, and realized a
2.3% reduction in energy use per
number of regulatory requirements. However, unlike many cubic meter of product. Motts also
businesses, municipalities typically have a very wide scope of estimates an annual savings of
activities that encompass power generation, water and $45,000 in wastewater treatment
wastewater treatment, solid waste collection and disposal, costs.
maintenance of the local infrastructure, and enforcement of
numerous federal, state and local codes. Further, many of these
operations interact directly with the environment and have a
high potential for significant impact if a problem occurs. For Municipalities Participating in
the PA EMS Pilot Project
these reasons, an EMS may in fact be more useful for protecting
the environment in a municipal setting than in a business • Brockway Borough – Wastewater
Treatment Facility
setting.
• Crawford County – Crawford
County Correctional Facility
Municipal EMS Pilot Project
• City Of Erie – Erie-Western
The Pennsylvania Department of Environmental Protection Pennsylvania Port Authority
(DEP), in conjunction with Five Winds International, • Hampden Township – Wastewater
conducted a Municipal EMS Pilot Project with seven Treatment Facility
Pennsylvania municipalities from 2001 – 2003. The materials used • Lawrence County – Long-Term
by those municipalities form the core of this guidebook, having Care Facility
been refined based on their experiences and recommendations.
• City of Philadelphia – Solid Waste
Case studies documenting the experiences of seven of the Collection Operations and NW
municipalities are provided in Annex B; contactinformation for Transfer Station
the lead EMS team members is also provided in
• Venango County – Two Mile Run
Annex B. County Park

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Examples from these case studies are included throughout this

section to illustrate the benefits of implementing an EMS as have
been realized by Pennsylvania municipalities. Additionally, success
factors for implementation identified by pilot municipality
participants are described.

Benefits of a Municipal EMS

Multiple studies have been performed to examine the benefits
Primary EMS Benefits
of the EMS approach, The evidence indicates that the systems For Municipalities
approach to managing environmental issues that is fundamental
• Positive effect on environmental
to an EMScauses a deep, cultural shift in how the organization performance and compliance
addresses these issues. Every employee must incorporate
• Improved EHS/ emergency response
environmental considerations into their daily job functions. training, awareness, involvement &
Thus the documented benefits of implementing an EMS range competency
from improved compliance with environmental regulations (and • Increased management and
oftena reduction in fines) to increased management efficiency, operational efficiency
and even a reduction in waste production and energy
• Improved relationships with
consumption. The systematic EMS approach to the daily regulators and the community
management of energy and environmental objectives leads to
• Reduced waste production & energy
benefits that canonly be created by an integrated effort across consumption
the entire organization, and are typically difficult to foresee
• Process for inclusion of multiple
prior to the implementation of the EMS. stakeholder requirements
A particularly useful element of an EMS is the incorporation of • Increased transparency and ability
stakeholder requirements and external communications. to respond to community requests
Because municipalities are pubic entities designed to serve local for information
communities, the increased transparency and ability to respond • Demonstration of management
to the needs of the community typically improves relationships control over highly complex and
between the municipality and its various stakeholders. The varied activities.
increased management and operational efficiency gained with an
EMS also improves the ability of the municipality to provide its
services to the community inexpensively and with greater
effectiveness.
The Pennsylvania EMS Pilot Project Participants anticipate
realizing many of the benefits common to EMS
implementation, however it is still relatively early to predict
whether long-term benefits, such as improved relationships with
regulators and regulatory compliance, will be achieved. Despite
this, numerous benefits have been noted by Pilot Project
Participants, including:
• Capturing Institutional Knowledge;
• Streamlining Operations;

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• Regulatory Fine and Cost Avoidance;

• Improved Emergency Response Procedures; and
• Increased Awareness and Participation.
Each of these benefits is discussed below in more detail.

Capturing Institutional Knowledge

All municipalities involved in the Pilot Project strongly agreed that
the most significant, initial benefit they recognized from the EMS From the case studies . . .
implementation process was to capture the institutional Hampden Township was
knowledge contained in the heads of employees. By consulting ”apprehensive at first, but an EMS
is a great way to translate the old
with employees and documenting the “how-to” of routine
‘verbal’ way of doing things into
municipal operations, the participants found that the time documented written procedures. It
required training new staff decreased, and that they were forced us to organize and write
protected from the loss of critical operating knowledge when everything down, something we
senior employees retire. Additionally, the documentation of talked about doing for years but
never accomplished.”
ongoing maintenance efforts required of the EMS has allowed
many municipalities to coordinate municipal activities with
greater efficiency and improve service delivery in some
instances.

Streamlining Operations
By documenting the processes used to complete routine
From the case studies . . .
municipal duties, many Pilot Project Participants also found that
they were able to reduce the number of steps involved in the The Hampden Township EMS
effectively “caught” information
process, saving time, energy and money. Further, the
that a pump was out of service at
documents allowed them to standardize the way routine tasks a lift station and allowed corrective
were performed, improving processes and creating additional action to begin before a total loss
savings. The EMS implementation process also forced of pumping capability occurred.
participants to document training, compliance and maintenance
schedules, which helped them to stay current with these items,
plan staff schedules more effectively, and avoid schedule
conflicts with other municipal activities.

Regulatory Fine and Cost Avoidance

Pilot Project participants observed significant savings through From the case studies . . .
the avoidance of fines and costs that it could have incurred had the
The Lawrence County long-term
EMS not been in place. Specific cost savings resulted through care facility effectively reduced
reducing incidents due to improper maintenance, reducing the solid waste disposal by 1.5 tons per
need for on-the-job training, and retaining and communicating year by switching to a coffee
of critical information over time. One participant even cited a concentrate that was brewed on
demand, reducing staff time and
reduction in regulatory fines due to increased employee waste coffee sent to the
awareness from EMS training programs. wastewater collection system.

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Improved Emergency Response Procedures

Several Pilot Project participants benefited from making
improvements to their emergency preparedness and response
plans that came about as a function of the EMS implementation
process. In one case, an emergency response plan allowed a
participant to respond quickly to conditions that would have
caused a major fuel spill. The participant felt that the spill
would not have been avoided prior to the pilot project, and that
this alone justified their efforts. Besides the financial and
environmental burden to the municipality of such an event, the
damage to regulatory, public and insurance relationships would
have been significant and long lasting.

Increased Awareness and Participation

All Pilot Project participants reported an increased awareness of
environmental issues and activities that have the potential to
impact the environment within their municipality as a result of
the pilot project. In some cases, this has led individuals not
associated with the EMS implementation process within the
municipality to suggest additional improvements, generating
excitement and additional, voluntary participation in the
municipality.

Key Success Factors

Several important lessons were learned in the course of the
Key Success Factors from the
Pennsylvania EMS Pilot Project that will be useful to other Pennsylvania EMS Pilot Project
municipalities seeking to improve their environmental
performance through an EMS approach. The experience to date • Obtain clear commitment from
senior management
suggests that while there are many operations/facility-specific
factors that influence the success of EMS development and • Clearly define the project team
and dedicate a project manager
implementation, there are some key factors in determining
success that apply to almost all operations/facilities. Some of • Conduct routine meetings
these factors include: • Publicize the EMS Project
• Commitment from senior management; • Integrate existing program
elements as much as possible
• A clear project team and dedicated project manager;
• Recognize that an EMS is an
• Routine meetings; ongoing commitment that doesn’t
end with implementation
• Publication of the municipal commitment to improved
environmental performance; • Understand the resource
requirements for EMS
• Integration into existing municipal systems; development

• Recognition that an EMS is a continuous commitment

that does not end with implementation; and

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• A realistic understanding of resource requirements for

EMS development.
These key success factors are described below in more detail.

Senior Management Commitment

The commitment of senior managers to the development and
From the case studies . . .
implementation of an EMS is perhaps the most important factor
in determining the overall success of an EMS. Without high- Senior management commitment
varied across the municipalities.
level commitment, the efforts of the EMS team will be
Brockway Borough and Crawford
constrained to the point of probable failure. This commitment County received endorsement
must be based upon an understanding of the business value of from senior management in the
an effective EMS and the importance of integrating an EMS early stages of the Pilot. Hampden
into day-to-day operations. To be valuable, this commitment Township experienced initial
skepticism from senior
must also be effectively communicated so that the EMS management followed by strong
implementation team, as well as other employees, understand buy-in. Venango County’s senior
what is entailed by senior management commitment. It is managers were actively
significant that one of the first tasks in implementing the committed, and showed support,
by participating directly on the EMS
scenario is securing and documenting senior management Core Team.
commitment.
Senior management support should go beyond initial written
statements and should include identifiable activities. Senior
management can demonstrate its support by personally
participating in training sessions, actively monitoring the EMS
implementation process, ensuring that adequate resources are
available, and participating in the establishment of EMS goals
for the organization and for individuals. At the very least,
senior management is encouraged to request routine updates
from the EMS team, and the inclusion of a report on the EMS
team progress in regular senior management meetings.
Who is “senior management”? For ISO 14001 it is the
individual(s) who has/have control over all the operations that
will be covered under the certification. This could be the
County Commissioner, the City Administrator or Manager,
and/or the Township Manager.

Clearly Define the Project Team and Dedicate a Project

Manager
By clearly defining the project team and dedicating a project
manager, municipalities can ensure that the EMS project does
not fall by the wayside. A project team of at least 2-3
individuals, depending upon the size of the municipality, should be
assigned responsibility in order to make use of the benefits of
teamwork. In any case at least two individuals should participate

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in the implementation to balance workloads and to ensure

continued movement when other commitments demand an
individual’s time. A solid project manager should outline the
schedule and hold the team accountable to its stated milestones
and deliverables.

Conduct Routine Meetings

A common comment from Pilot Project participants was that
they did not meet often enough, and that this approach led to
large deliverables due at each meeting. By holding routine
meetings with smaller deliverables, the EMS team will not be
overwhelmed by the implementation process. Participants
suggested weekly meetings, at least during the first two Phases of
EMS implementation, to be effective.

Publicize the EMS Project

By publicizing the EMS project, some municipalities found that
additional benefits were gained through the interest of non-EMS
team employees. In many cases teams found that employees
were excited to work on procedures in their area, and had given
considerable thought to the development of procedures prior to
being approached by the EMS team. As an additional benefit,
managers within the organization began to monitor progress of
the EMS project, further motivating the team to follow through
on their commitment to implement the EMS.

Integration into Existing Municipal Systems

Most existing municipalities already have many of the elements From the case studies . . .
needed to meet the requirements of the ISO 14001 standard in
The City of Philadelphia Sanitation
place, although these frequently require additional development Division realized significant
and/or documentation. Therefore, it is important to identify improvement in the
existing operational practices or systems in the municipality that documentation and consolidation
the EMS element can integrate, and focus on enhancing these of Standard Operating Procedures
elements rather than recreating them. It is especially important and creation of a comprehensive
training program.
to consider opportunities to improve energy efficiency and to
include available renewable energy sources in the initial stages of The Erie-Western Pennsylvania Port
Authority EMS core team has
EMS development. Maintaining this additional focus during the recognized the need for on-going
Gap Assessment will help to facilitate the implementation commitment in order to realize the
planning that follows. full benefits of its EMS, and has
decided to continue to meet on a
It is also important to note that the EMS can be integrated into regular basis even though the pilot
existing management systems within the municipality and not project has concluded.
the reverse. Fundamental to the systems approach of
environmental management systems is the integration of

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environmental concerns into the daily activities of employees

throughout the municipality. Thus, existing procedures will
only need to be edited to add in the concerns identified by the
EMS process rather than recreated in their entirety. EMS-
specific activities that need to be developed, such as the annual
management review and evaluation of objectives, targets and
performance improvement programs, should be integrated into
the annual budgeting and planning cycle that already exists
within the municipality. Similarly, training programs identified by
the EMS can be integrated into existing training programs
already coordinated by the human resources group.

Recognition of Need for On-going Commitment

The strongest benefits of EMS implementation are typically
achieved through the continual improvement of the EMS From the case studies . . .
elements. An effective EMS should be predicated upon the Both Erie-Western Pennsylvania and
principle of continuous improvement, which is inherently an Hampden Township experienced
on-going process. Completion of the EMS involves establishing challenges in obtaining the
necessary time and human
a system that provides for continuous improvement in resources to commit to the EMS. At
environmental management, but many of the benefits that result times the EMS Core Teams were
from continuous improvement often occur after the system is caught between their regular work,
implemented. Thus, municipalities that develop an EMS must and the work necessary to
complete the Pilot.
recognize that completion of EMS implementation is an
important milestone, but it is not the end of the process. An The
integration of environmental and energy issues into the existing
municipal management system that is part of the EMSprocess
will influence the way operations are conducted from that day
forward.

Understanding of Resource Requirements

Municipal EMS:
While a well-developed EMS should save money, reduce energy Londonderry, NH
use, minimize risk and improve overall environmental A participant in the 1997 EPA EMS
performance in the long run, it requires a significant Pilot Project, the town of Londonderry,
commitment of resources during the development stage. The New Hampshire implemented an EMS
within its Public Works Department.
initial development process is an investment made to generate The EMS clarified responsibilities for
medium term and long-term benefits, although several compliance with legal requirements,
municipalities indicated that short-term benefits were realized improved communications between
even during the Pilot Project phase of EMS implementation Public Works divisions, and
documented the procedures and
Some municipalities have embarked upon EMS implementation controls in place to manage
without a realistic understanding of the resources required and environmental risks. As a result of the
EMS, the Public Works Department
have found that, two years later, they have not completed their immediately noted improved worker
EMS. Development of an EMS requires a commitment of time safety and reduced water
from a number of individuals throughout a municipality and if consumption. The entire
their managers do not recognize the need for this time implementation project cost $27,000,
the majority of which was staff time.

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commitment, implementation will be slow and arduous.

Therefore it is important to present realistic estimates of
resource requirements and the potential benefits or savings to
senior management prior to implementation.

Implementation Cost and ROI

In an effort to quantify the costs and benefits of environmental
management systems using rigorous research methods, several
long-term studies have been performed in the United States. In
1997, the US EPA sponsored the EMS Initiative for Local
Governments, a two-year pilot program intended to assess the
resources, applicability and benefits of EMSs in local
governments. Because of the success of this program, a second
pilot was conducted and a third is currently underway. The
following table illustrates level of effort for EMS
implementation based on the results of the first two pilot
programs that involved 23 municipal operations ranging in size
from 15 to 15,000 employees.
EPA Municipal Pilot Study: Level of Effort
Hours Committed Cost Municipal EMS Benefits:
(Over 2 Years) (over 2 Years) New York City Transit
Average 3,232 $ 97,062 New York City Transit (NYCT) is
Low 716 $ 27,000 responsible for moving over 6 million
passengers per day, utilizing some
High 6,267 $195,565 44,000 employees in 27 departments.
NYCT certified its Capital Program
Management Department to the ISO
In 1996, the National Database on Environmental Management 14001 Standard in 1999. This
Systems (NDEMS) was established to provide long-term, department of 1,700 employees is
responsible for an annual capital
facility-level comparative data on the performance changes expenditures budget of approximately
associated with EMS implementation. The 5-year study $2 billion. The EMS implementation
collected data from a sample of 83 facilities on a wide variety of was accomplished for $280,000. As a
performance indicators before, during, and after the result of the EMS, NYCT has noted a
significant increase in efficiency in the
implementation of an EMS. Results of the study demonstrated collection ad storage of records,
that the implementation of an EMS creates broad-based improved communication between
improvements in environmental performance, standard departments, increased employee
operating procedures, record keeping, identification and awareness and participation, and an
improved public image.
correction of non-compliance situations and other compliance-
related management practices. The study also found that
organizations did not have to certify the EMS to the ISO 14001
standard to realize these benefits. The NDEMS data illustrates
potential EMS implementation costs for government
organizations on a per employee basis:
NDEMS Government Organizations:

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Cost of Effort per Employee

Item Cost Percent
Labor $ 822 59.8 %
Consultants $ 499 36.3 %
Travel/Training $ 50 3.6 %
Equipment $ 0 0.0 %
Materials $ 1 0.1 %
ISO Registration $ 0 0.0 %
Average Cost / Employee $ 1,441 100 %

Cost of ISO 14001 Registrar

The cost of certification through the use of a third party registrar
depends on a variety of factors including the amount of time the
registrar works with a municipality. This time is usually
dependant upon:
• the size of the organization;
• the scope of the registration;
• the number of facilities being registered and their
location; and
• whether the organization already has an ISO 9000 system in
place and whether that ISO 9000 system is registered.
A list of registrars operating in Pennsylvania is provided on
DEPs website.

Return on Investment
EMS implementation within municipalities and local government
organizations has shown returns on investments that often
outweigh the costs of implementation. The US EPA EMS
Initiative for Local Government mentioned above documented some
examples of positive return on investment:

Tri-County Metropolitan Transportation District, Five

Maintenance Facilities - Over the two-year project period,
Tri-County Metropolitan Transportation District, Oregon's
largest public transit agency committed $89,241 in direct labor
costs. In just over one year into EMS implementation, Tri-Met
was able to identify $300,000 in operating savings, $66,000 of
which was directly attributable to meeting their defined EMS
energy conservation objectives and targets.

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The City of San Diego, Refuse Disposal Division - The

Division committed $213,908 in direct labor costs over two
years of implementation. With an annual operating budget of
almost $18.7 million, the Division expects an on-going annual
cost savings of approximately $868,000 from the successful
implementation of the EMS. The majority of the savings have
been achieved through more efficient use of heavy equipment,
fuel, and water. The Division was the first public refuse disposal
division in the U.S. to achieve ISO 14001 certification.

Details of these pilots are available in An Environmental

Management Systems Troubleshooter’s Guide for Local Government listedin
Section 6.

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Is An EMS Right For You?

It is recommended that a municipality follow a systematic
process when deciding whether it should implement an EMS. It
is all too easy to decide that an EMS is not required simply
because the task seems difficult or one is not familiar with the
terminology. Figure 3 proposes a step-wise process to support
this decision that involves:
1) Gather Information: Assembling the pertinent
information and aligning the decision-makers to decide
if an EMS makes sense for the municipality;
2) Assess Drivers: Discussing your municipalities internal
and external drivers for moving forward;
3) Estimate Cost & Benefits: Estimating the potential
costs and benefits of the EMS approach to managing
energy and environmental issues; and,
4) Set Goals: Establishing the level and goals for
implementation and deciding if and how the
organization wishes to publicize its efforts.

Figure 3. A decision framework for determining whether to move ahead with a complete or partial
EMS, how to publicize the completed EMS, and/or to not do anything at all

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Gather Information
As a first step in the process illustrated in Figure 3, the
following questionnaire can help you capture your
understanding of key issues as well as identify areas where you
may need more information.

EMS Implementation Questionnaire

1 Have key stakeholders of your municipality [such as regulators, county
commissioners, or local residents] required or requested that you develop an Yes / No / Don’t Know
Environmental Management System?

2 Is public perception and acceptance, i.e. relations with regulators, local

businesses and the community, of importance to your municipality (i.e., would
Yes / No / Don’t Know
it be valuable for your municipality to announce that you have an EMS)?

3 Could your municipality benefit from establishing a process to prioritize and

Yes / No / Don’t Know
incorporate stakeholder requirements into municipal operations?

4 Do you see value in developing a system and procedures to identify and

Yes / No / Don’t Know
address energy and environmental risks, liabilities and potential impacts?

5 Do you see value in developing a system and procedures to ensure

Yes / No / Don’t Know
regulatory compliance?

6 Could your municipality benefit from establishing a procedure to monitor its

operations, set objectives and targets, track its performance and evaluate Yes / No / Don’t Know
compliance with environmental laws and statewide energy goals?

7 Are other municipalities in your region pursuing an Environmental

Yes / No / Don’t Know
Management System?

8 Do you feel your municipality has sufficient resources available, in terms of

Yes / No / Don’t Know
personnel and funds, to pursue an EMS?

Answering “Yes” indicates possible drivers for EMS

implementation are in place (e.g. interest by key stakeholders) or
opportunities for support exist (e.g. sufficient resources).
Answering “No” to most of these questions can indicate that an
EMS may not be appropriate for your municipality, or identify
potential barriers to implementation. Any “Don’t Knows” may
indicate areas where more information needs to be gathered as you
move forward in making a decision.
Talking to key decision-makers within your municipality can
give you important insights into the opportunities and/or
potential challenges of EMS implementation. It can also provide

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you with an opportunity to discuss the benefits of an EMS to

align these key individuals around your efforts.
Talking to managers from other organizations and
municipalities who have already gone through an EMS
implementation can also help you gather additional information
about benefits, drivers, challenges and success factors. Contact
information for the municipalities participating in the
Pennsylvania Pilot Project is included in Annex B of this
guidebook. A number of additional EMS information sources
are also provided in Section 6.

Assess Drivers
After assembling the correct information, it is important to
decide whether there are key external or internal drivers for
EMS implementation facing the municipality. The relative
degree of importance between external and internal drivers will
help an organization determine the level of implementation (e.g.
whether to implement specific elements of an EMS or a
complete EMS). The choice will be based upon your own
business climate, culture and existing practices.
The presence of strong external drivers (e.g. stakeholder
requirement or negative media coverage) to implement an EMS
will typically be the primary determinant as to whether a
complete EMS makes sense for a municipality. The only
remaining decisions are then how to publicize the EMS and
whether or not to certify to the ISO 14001 standard. If,however,
the drivers are primarily internal, or the external drivers can be
satisfied without implementing a complete EMS,it may make
sense to implement only specific elements of an EMS (i.e.
partial implementation). Regardless of the balance between
internal and external drivers, it may be effective to include a
structured process such as a cost / benefit assessment in the
decision-making.

Estimate Costs and Benefits

By quantifying predicted direct cost savings over existing
management practices, and relating the cost savings to
implementation costs, cost / benefit assessments give objective
insight into the true value an organization will receive.
However, it is important to also consider indirect benefits,
especially if self-declaration or certification will be considered.
Such factors, while not included in the numerical cost / benefit
assessment, may still be even more important to the final

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decision. A final item to consider is the effect of continual

improvement on the benefits that are anticipated. While some
municipalities do not see significant immediate benefits from PA EMS Pilot – Levels of
Implementation
implementing an EMS in whole or in part, the continued
refinement of the EMS elements and associated culture change Of the seven municipalities involved in
the study, four chose to implement a
within municipal operations creates synergistic long-term complete EMS:
benefits that can be difficult to estimate and predict. However,
Hampden Township - wastewater
if you decide to move forward, incorporating lessons learned
treatment operations, including all
from the experiences of previous organizations can provide biosolid operations
direction and/or focus on the EMS elements that enabled
Crawford County - correctional facility,
substantial benefits. See Section 3 for a more detailed discussion focusing on solid waste management
and examples of the costs and benefits of EMS implementation. at the facility
Lawrence County - long-term care
Set Goals facility
City of Erie - Erie-Western
Once it has been established that an EMS would be beneficial to Pennsylvania Port Authority – port
your municipality, the next step is deciding the level of operations, including the shipyard, dry
implementation for your EMS: dock, marinas, maintenance and
administration offices.
• Third Party Certification to ISO 14001.
The municipalities that sought partial
• Implementation of a Complete EMS Without EMS implementation included:
Certification. Borough of Brockway utilized the EMS
pilot project to assess pollution issues
• Partial Implementation.
associated to their wastewater
If the municipality chooses to implement a complete EMS treatment facility, and developed a
program to reduce the amount of
without certification, it must then decide if and how it wishes to infiltration and inflow (I&I) to the
publicize the EMS. The most common method of publicizing a collection system, pump station and
non-certified EMS is through self-declaration, where a treatment facility.
municipality announces that it has an EMS in place that The City of Philadelphia Sanitation
conforms to the ISO 14001 standard. It is highly recommended Division utilized the EMS pilot project
that a municipality choosing not to certify their EMS self-declare to implement a comprehensive training
conformance to the ISO 14001 standard in order to obtain the and awareness program around solid
waste collection and transfer activities.
indirect benefits the EMS can have on relationships with
regulators and the public. The municipality must publicize the Venango County took quite possibly
the most innovative approach of all,
EMS in some way to demonstrate and communicate the using the EMS process as a discussion
commitment to environmental performance represented by the tool to evaluate the potential
EMS to regulators and the public. Section 2 provides a environmental risks and associated
discussion around the pros and cons for each of these options controls for operations at Two Mile
Run County Park.
for municipalities.
See Annex B Municipality Case Studies.

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REVIEW QUESTIONS:

1. What is EMS in your personal perspective?

2. Discuss briefly the benefits of EMS.
3. Brief description of ISO 14001
4. Discus The ISO 14001 EMS model
5. How EMS important in Operation Management?

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