MODULE 3

An Environmental Management System (EMS) is a set of processes and practices that enable
an organization to reduce its environmental impacts and increase its operating efficiency.

Basic Elements of an EMS include the following:

Reviewing the organization's environmental goals;

Analyzing its environmental impacts and compliance obligations (or legal and other requirements);

Setting environmental objectives and targets to reduce environmental impacts and conform with
compliance obligations;

Establishing programs to meet these objectives and targets;

Monitoring and measuring progress in achieving the objectives;

Ensuring employees' environmental awareness and competence; and,

Reviewing progress of the EMS and achieving improvements

The five main stages of an EMS, as defined by the ISO 14001 standard

1. Commitment and Policy - Top management commits to environmental improvement and

establishes the organization's environmental policy. The policy is the foundation of the EMS.
2. Planning - An organization first identifies environmental aspects of its operations.
Environmental aspects are those items, such as air pollutants or hazardous waste, that can have
negative impacts on people and/or the environment.

3. Implementation - A organization follows through with the action plan using the necessary
resources (human, financial, etc.). An important component is employee training and awareness
for all employees (including interns, contractors, etc.

4. Evaluation - A company monitors its operations to evaluate whether objectives and targets are
being met. If not, the company takes corrective action.

5. Review - Top management reviews the results of the evaluation to see if the EMS is working.
Management determines whether the original environmental policy is consistent with the
organization's values.

Top 10 Components in a Successful Environmental Management System

For maximum environmental and economic benefits from an environmental management system
and to help comply with the EMS requirement under the Toxics Use & Hazardous Waste
Reduction law, a business should include the following 10 components in its system. These
components can apply to many different EMS models, including ISO 14001. Use this checklist to
be sure your system includes all 10 and keep it on site.
1. Environmental Policy
➢ Reflects how the organization feels about the environment
➢ Identifies environmental impacts of processes and products
➢ Ensures compliance with environmental requirements
➢ Commits organization to prevent pollution, reduce environmental risks and share
information with external stakeholders
2. Environmental Requirements and Voluntary Initiatives
➢ Employees understand their roles in meeting environmental requirements
➢ Identify management and manufacturing practices that affect the organization's ability to
meet requirements
➢ Identify and work with programs that encourage preventing pollution
3. Objectives/Targets
➢ Set the following environmental objectives: comply with environmental requirements;
continuous improvement in regulated and non-regulated areas; prevent pollution
➢ Make objectives specific to the organization Set timeframes to meet objectives
➢ Update objectives as environmental requirements evolve
4. Structure, Responsibility and Resources
➢ Ensure the organization has the personnel and resources needed to meet objectives
➢ Make managers responsible for the environmental performance of their unit
➢ Develop procedures for attaining objectives
5. Operational Control
➢ Establish a procedure to ensure the proper waste management hierarchy is followed
➢ Develop simple procedures to measure and report environmental impacts of processes and
products
6. Corrective and Preventive Action and Emergency Procedures
➢ Document procedures for identifying, correcting and preventing mistakes
➢ Develop emergency procedures to minimize or eliminate adverse environmental impacts
associated with accidents or emergencies
➢ Correct causes of potential hazards to prevent pollution
7. Training, Awareness and Competence
➢ Train staff whose roles affect meeting objectives, and make certain staff are capable of
carrying out required duties
➢ Mandatory trainings include detailed pollution prevention methods
8. Organizational Decision-making and Planning
➢ Use life-cycle analysis to identify the impact products make on the environment
➢ Empower all employees to make pollution prevention improvements that do not require
significant resources
9. Document Control

➢ For future evaluation, document steps taken to meet objectives Use electronic
documentation to improve record management
➢ Document all pollution prevention suggestions
10. Continuous Evaluation and Improvement
➢ Conduct and document periodic objective-based audits of the organization's performance
➢ Use audits to assess pollution prevention efforts

WHAT IS EMAS?

The EU Eco-Management and Audit Scheme (EMAS) is a premium management instrument

developed by the European Commission for companies and other organizations to evaluate, report,
and improve their environmental performance. EMAS is open to every type of organisation eager
to improve its environmental performance. It spans all economic and service sectors and is
applicable worldwide.

ISO 14000 is a family of standards related to environmental management that exists to help
organizations

(a) minimize how their operations (processes, etc.) negatively affect the environment (i.e. cause
adverse changes to air, water, or land);

(b) comply with applicable laws, regulations, and other environmentally oriented requirements;

(c) continually improve in the above

ISO 14001 standard provides a systematic framework for integrating environmental management
practices by supporting environmental protection, pollution prevention, waste minimization, as
well as energy and materials consumption reduction.

Contents of International Standard 14001

This International Standard conforms to ISO’s requirements for management system standards.
These requirements include a high-level structure, identical core text, and common terms with core
definitions, designed to benefit users implementing multiple ISO management system standards.
This International Standard does not include requirements specific to other management systems,
such as those for quality, occupational health and safety, energy or financial management.
However, this International Standard enables an organization to use a common approach and risk-
based thinking to integrate its environmental management system with the requirements of other
management systems.
This International Standard contains the requirements used to assess conformity. An organization
that wishes to demonstrate conformity with this International Standard can do so by:
 • making a self-determination and self-declaration, or
• seeking confirmation of its conformance by parties having an interest in the organization,
such as customers, or
• seeking confirmation of its self-declaration by a party external to the organization, or
• seeking certification/registration of its environmental management system by an external
organization.

WHAT ARE THE BENEFITS OF AN ISO 14001 CERTIFICATION?

Organizations certified to ISO 14001 demonstrate their commitment to continuous improvement

and reduced environmental impact

The certificate can significantly improve your bargaining position when taking part in public and
private green procurement tenders. As consumers are becoming increasingly aware of
environmental and ecological issues, ISO 14001 certification helps your brand stand out as a
responsible provider

Companies that implement the ISO 14001 EMS aim to minimize wastage, from materials to
energy consumption, throughout the supply chain and can thereby reduce cost

Potential Benefits

Improved environmental performance

Enhanced compliance

Pollution prevention

Resource conservation

New customers/markets

Increased efficiency/reduced costs

Enhanced employee morale

Enhanced image with public, regulators, lenders, investors

Employee awareness of environmental issues and responsibilities

Barriers associated with EMSs in 1999, the Department of Enterprise, Trade and Employment
stated that the majority of companies accredited to ISO 14001 in Ireland at that time were large
indigenous organizations or the subsidiaries of large multi-national corporations. Many of these
certified companies are now examining the environmental performance of their downstream
suppliers, many of them Small Medium Enterprises (SME’s), and ultimately may require them to
become certified to ISO 14001. In many cases the SMEs themselves are anxious to demonstrate
environmental probity by adopting and implementing environmental management system
standards, but are reluctant to do so for the following reasons

• Fear of the unknown

• Lack of resources

• Lack of technical expertise

• More pressing business imperatives

• Lack of direction

• Fear of failure.

What is Pollution Prevention and Continuous Improvement? Definitions Pollution prevention

is generally defined as “the use of processes, practices, materials, products or energy that avoid or
minimize the creation of pollutants or wastes at the source.”

1 The strategic planning framework identifies an opportunity to “continuously improve air quality
by minimizing the use of polluting processes, practices, materials and products,

”2 which is the broad definition used by the project team in its work.

Pollution prevention techniques and practices focus on:

➢ Substances of concern

➢ Materials and feedstock substitution

➢ Operating efficiencies

➢ On-site reuse and recycling

➢ Training

➢ Purchasing practices

➢ Product design

➢ Equipment modifications

➢ Product reformulation

➢ Process changes

➢ Clean production

➢ Avoidance of cross-media transfer of pollutants or waste

➢ Life-cycle assessment

Examples of Pollution Prevention Techniques and Practices Materials and feedstock

substitution is a method of source elimination. Polluting materials in a production process or
embedded in a product are replaced with less polluting or nonpolluting substances.
Opportunities for materials and feedstock substitution include:

➢ Painting applications

➢ Parts cleaning

➢ Metal finishing

➢ Printing operations

➢ Building and grounds maintenance

➢ Operating efficiencies and training are examples of how normal parts of good operation
can provide effective ways to prevent pollution. Examples include:

➢ Changing production schedules to minimize equipment and feedstock changeovers

➢ Improving maintenance schedules

➢ Segregating by-products at the source

➢ Training staff to improve material handling and recognize P2 opportunities

Product design and reformulation includes methods for preventing pollution associated with the
entire life cycle. Addressing environmental concerns at an early stage can avoid environmental
impacts throughout the product life cycle in a cost-effective manner. Results of redesigning or
reformulating a product include:

➢ Reducing toxicity of a product

➢ Reducing waste material

➢ Extending the life of a product

➢ Extending the life of the materials used

➢ Reducing energy and material intensity needed to produce, use and dispose of the product

Equipment modifications and process changes involve new technologies or approaches to

existing operating systems processes and practices to improve production efficiencies and reduce
pollution and waste. An example is mechanical stripping instead of using solvents to remove paint
and varnish

The Value of Waste can also be viewed as a loss of valuable process materials that could have
economic and environmental benefits if reused or recycled. The following approaches reflect this
perspective on the value of waste

On-site reuse and recycling is considered pollution prevention because it occurs at the same
place as the original activity.4 Reuse means using materials again in their original form or in new
applications. Recycling extends the effective life of resources. Environmentally sound recycling
is usually preferable to end-of-pipe solutions. Raw materials, chemicals and treated and untreated
wastewater are examples of materials that could be reused or recycled. Some examples of reuse
and recycling are:

• Recovering metals by ion exchange or reverse osmosis

• Recycling cooling water

• Reusing trim and cuttings from plastic moulding in on-site production rather than taking them
for off-site disposal

Environmental policy is the commitment of an organization or government to the laws,

regulations, and other policy mechanisms concerning environmental issues.

These issues generally include air and water pollution, waste management, ecosystem
management, maintenance of biodiversity, the management of natural resources, wildlife and
endangered species
For example, concerning environmental policy, the implementation of an eco-energy-oriented
policy at a global level to address the issues of global warming and climate changes could be
addressed.

Policies concerning energy or regulation of toxic substances including pesticides and many types
of industrial waste are part of the topic of environmental policy. This policy can be deliberately
taken to influence human activities and thereby prevent undesirable effects on the biophysical
environment and natural resources, as well as to make sure that changes in the environment do not
have unacceptable effects on humans.

The first step in creating an EMS is to perform an Initial Environmental Review. This tells you
where you are and creates a road map for your organization. There are four main areas:

➢ Review previous environmental issues.

➢ Consider any regulations which have operational impact.
➢ Identify and evaluate possible environmental issues in your organization.
➢ Outline current operations and how are they managed; also consider indirect impacts.

What is an initial environmental review?

The IER is the first step in the implementation of an EMS - where a business considers all the
factors affecting its 'relationship' with the environment. It should form the baseline and foundation
for the other parts of your EMS.

Your IER should enable you to:

➢ Identify how existing site operations have an environmental impact - eg the impact of
normal operating conditions, abnormal conditions and emergency situations
➢ Establish which of these impacts are significant and need improvement by setting
objectives and targets
➢ Identify breaches or potential breaches of environmental legislation
➢ Identify relevant EMS documentation which needs to be put in place
➢ Quantify emissions, discharges, and material and utility use
➢ Identify opportunities for improving performance and minimizing waste
➢ Evaluate previous emergency situations and accidents
➢ Develop your environmental policy

Environmental Aspects According to of ISO 14001:2004, an environmental aspect is any

“element of an organization’s activity, products or services that can interact with the environment.”
Goetsch & Davis (2001) state: In simple terms an environmental aspect is anything resulting from
the organization’s activities, products or services that has the potential to cause an environmental
impact, even if it is presently controlled, or prevent such impact. The fact that the potential exists
(if something goes wrong, for instance) makes it an environmental aspect (p. 18). An
environmental aspect can be either negative or positive. Negative aspects include emissions to the
air or water, discharge of oil to the land or water, generation of hazardous waste, generation of
solid waste, community impact, and the generation of dust and noise. Positive aspects include
recycling of used materials such as steel, aluminum, copper, glass bottles and paper, removal of
pollutants from the air or water, and restoring land by removing decontaminated soil.

Environmental Impact
In cause and effect, if one considers an environmental aspect to be the cause, then the
environmental impact is the effect. An environmental impact is any change to the environment,
whether adverse or beneficial, wholly or partially resulting from the organization’s activities,
products or services. Essentially, the environmental impact is the result of the environmental
aspect. For example, suppose a company is discharging wastewater to a nearby stream. A potential
environmental impact of that activity is pollution to the water

What are Legal Requirements?

Relevant national, regional, and local laws and regulations

Government operating permits, licences, and approvals

Relevant international standards and conventions

Contracts and other documents that include legal obligations

Examples of “Other Requirements”

Industry codes of practice

Non-regulatory standards (e.g., ISO 14001)

Agreements with public authorities

Company policies and procedures

Voluntary compliance agreements (e.g., possible future commitment by MRC members to ISO
adoption)
What is an Objective? What is a Target?
Environmental objectives are goals that you would like to meet in the future.

Targets are the means for providing verifiable evidence that you have actually met the
objective. For example, your environmental objective may be to reduce the generation of
hazardous wastes. You may then set your target at 20 percent reduction within 12 months. In the
parlance of iso 14001,

Objectives are “documents” whereas targets are “records.” Documents can be modified while
records cannot. For example, you can modify your objectives, but you cannot change having
missed your targets.

In setting your targets, make sure you are not overly ambitious—especially during the first year
of implementation. Set a target that is realistic and reasonably easy to achieve in the first year.

You don’t want your organization to fail the first time it tries to meet an environmental
target. Failure can be very demoralizing to your team members.

It is much better to set an achievable target and meet it the first year and then set progressively
more aggressive targets in following years.

Remember that the fundamental basis of an effective environmental management program consists
of top-down support and bottom-up involvement.

Always get senior management to buy in on the objectives and targets, and make sure you
communicate the objectives clearly to the employees. After all, the employees are the ones who
are going to make it happen.

Programs:
Environmental management programs support the NIEHS Environmental Policy and the
overall goal of reducing negative environmental impacts. These programs were established to
assure compliance with federal, state, and local environmental regulations. Each program includes
specific requirements that are documented in the NIEHS EMS Manual as well as a corresponding
written plan, procedure, or instruction

1. Air Emissions

This program includes performance standards for the boilers, emergency generators and
incinerators located on the NIEHS Campus. This program also encourages and supports
alternative transportation including bus, carpool, and telework options.
2. Energy Management

This program seeks to reduce electricity consumption associated with NIEHS laboratory,
utility, office, and outdoor operations and support HHS/NIH agency wide efforts to reduce
campus building energy intensity and increase usage of renewable energy.

3. Green Purchasing

This program encourages the purchase of recycled content materials, energy-efficient

equipment, alternative fueled vehicles, bio-based products, environmentally preferable
products, and non-ozone depleting substances.

4. Hazardous Materials Management

The program provides criteria for the safe and environmentally sound storage, handling,
transportation and disposition of hazardous materials used in laboratory research, support and
maintenance operations, and construction activities.

5. Pesticides

This program follows integrated pest management (IPM) principles when controlling pests in
the animal facilities, inside campus buildings, and on campus grounds through limited
pesticide application in a manner that is effective yet safe for the environment, personnel, and
research activities.

6. Solid Waste Management

This program ensures that solid wastes are identified, classified, collected, transported, stored,
recycled, treated and/or disposed safely and in a manner protective of human health and the
environment. Maximization of the quantity of material diverted from the landfill, either by
recycling, reuse, or reduction in quantities used, is a primary objective.

7. Storm water Management

This program focuses on reducing the potential for outdoor petroleum and chemical spills, and
minimizing the impact of construction projects on the stormwater conveyance system.

8. Wastewater

This program reduces the potential for pollutants to enter the sanitary sewer system through
effective pretreatment, source reduction, proper chemical disposal, and other wastewater
management programs.
9. Water Consumption

This program seeks to reduce water consumption associated with NIEHS laboratory, utility,
facility, and domestic operations.

STRUCTURE AND RESPONSIBILITY

Organizational structure outlines the hierarchy and reporting relationships between various
functions and levels in an organization. Duties at each level of responsibility and functional area
may be summarized in a more detailed organization chart

Management’s Responsibilities Top management has the responsibility to:

➢ Define the environmental policy for the organization

➢ Lead by example in their commitments to continual improvement, prevention of pollution,

and compliance with relevant environmental legislation and regulations

➢ Authorize adequate resources to implement and maintain the EMS

➢ Reward good performance in the EMS

➢ Conduct regular management reviews of the EMS

➢ Integrate environmental management principles and practices into the organizational

culture.

Awareness and Competence

Awareness
➢ People accept responsibility more readily if they understand why their
actions are important
➢ People become self-motivated, so less reinforcement by management is required
➢ Emphasizes that environmental protection is everyone’s responsibility
➢ Helps to generate commitment by employees

Competence
➢ The application of knowledge, understanding, judgments, and skill to consistently
carry out an activity effectively and efficiently to a pre-set standard
➢ The objective of training should be to develop competence, or the means to attain
competence

ISO 14001 REQUIREMENTS FOR INTERNAL AND EXTERNAL COMMUNICATION

Effective

➢ communication is an essential foundation of an EMS. Communicating relevant information

about the EMS means sharing the power for implementing, maintaining, and improving
the EMS.
➢ Informed and knowledgeable employees can be active participants in the EMS.
Conversely, when communications are inadequate and information is missing, an EMS is
weakened

Internal Communication ISO 14001 mandates that there be clearly-defined procedures for
communicating about the EMS within and between the various levels of responsibility, and
within and between different functions (i.e., departments, areas of operation) in the
organization. There are many basic reasons for such communications; for example:

Some specific and practical requirements for internal communications in ISO 14001 are:

➢ Environmental policy ·
➢ Legal and other requirements
➢ Significant environmental aspects and impacts
➢ Environmental objectives and targets
➢ Changes to activities, products, or services that affect environmental management
programs
➢ Roles and responsibilities in the EMS
➢ Training, awareness, and competence requirements
➢ Operating and document control procedures that may affect the environment
➢ Emergency preparedness and response actions
➢ Requirements for, and results of, monitoring and measurement
➢ Environmental incidents
➢ Non-compliance with laws and regulations
➢ Non-conformance with the requirements of the EMS
➢ Corrective and preventive actions and follow-up to ensure effectiveness
➢ Results of environmental audits
➢ Information on the EMS to top management
➢ Results of management reviews of the EMS
➢ Effectiveness of the EMS.

Communication with External Interested Parties

➢ According to ISO 14001, an organization must be open to receiving communications about

their EMS, or environmental issues in general, from individuals, groups, agencies, and
other organizations outside itself.
➢ All such communications should be documented (i.e., written down), recorded (i.e., filed
for future reference), and responded to promptly and appropriately.
➢ External interested parties with whom communication is possible include:
➢ Individuals
➢ Ethnic tribes
➢ National, regional/provincial, and local government and community officials
➢ Local fishers, farmers, loggers, foresters·
➢ Customers of the organization ·
➢ Suppliers of equipment, materials, and services to the organization ·
➢ Public interest groups
➢ Tourism representatives, tourists, recreation interests, property and land owners
➢ Business associations ·
➢ Environmental and other non-government organizations (NGO)
➢ University, college, and school students and teachers
➢ Community associations
➢ Representatives of the news media – television, newspapers, radio

Definitions of document
➢ Under ISO 14001, documentation refers to all written material concerning the EMS
➢ Documents include policies, procedures, manuals, plans, diagrams, flowcharts,
correspondence, memoranda related to the EMS
➢ Records are documents, but under ISO 14001 are distinguished from documentation: »
Documentation concerns what should happen
➢ Records contain information on what has happened
Documents
 ➢ ISO 14001 Standard specifications do not require extensive documentation ! A
management system needs consistent procedures
➢ Documentation (i.e., written information) aids consistent application of procedures
➢ To ensure systematic use of documented procedures, they must be controlled Here is how
ISO 14001 deals with the issue
ISO 14001 Document Control says: The organization shall establish and maintain
procedures for controlling all documents required by this International Standard to ensure
that:
(a) they can be located
(b) they are periodically reviewed, revised as necessary, and approved for adequacy by
authorized personnel ISO 14001 Environmental Management Systems
(c) the current versions of relevant documents are available at all locations where
operations essential to the effective functioning of the EMS are performed
(d) obsolete documents are promptly removed from all points of issue and points of use,
or otherwise assured against unintended use
(e) any obsolete documents retained for legal and/or knowledge preservation purposes are
suitably identified ISO 14001 D
➢ Documentation shall be legible, dated (i.e., with dates of revision), and readily identifiable,
maintained in an orderly manner and retained for a specified period. Procedures and
responsibilities shall be established and maintained concerning the creation and
modification of the various types of documents.

How to Control Documents

Use a standard format for procedures Include:

➢ Title, author/originator
➢ Organization, department, function
➢ Purpose, scope, definitions
➢ Procedure, persons responsible
➢ Records, forms, related documents, references » authorized approval signature
➢ Initial date, and dates of revisions
➢ Identify all printed copies as ‘uncontrolled’
➢ Store controlled versions of documents electronically (e.g., networked computer files)
➢ On-line ‘read only’ access by employees
➢ Changes to documents made only by authorized personnel - restricted access
➢ Schedule regular review and revision of procedures
➢ Notify all relevant personnel when a procedure is changed
➢ Keep a register of paper copies of key documents held by individuals
➢ Educate personnel about document controls
 Definition and implementation of operational controls
The standard states that the methods defined to ensure operational control will be dependent on
the organization’s activities, legal obligations, and significant operational controls.

Therefore, an organization must decide how to construct and combine processes to ensure that
total operational control of its environmental aspects is achieved. These methods of defining and
implementing controls may include

➢ Constructing processes to ensure consistent results

➢ Considering the life cycle of a product when establishing controls
➢ Using technology to ensure results
➢ Ensuring personnel are competent
➢ Performing processes in a certain way
➢ Monitoring and measuring of results
➢ Deciding on the amount of documented information required to support the above

Monitoring and Measurement

➢ The organization must monitor, measure, analyze and evaluate its environmental
performance.
➢ It must determine what needs to be monitored and measured and as applicable the methods
for monitoring, measurement, analysis, and evaluation to ensure valid results.
➢ It must determine the criteria against which environmental performance and its
appropriate indicators will be evaluated.
➢ It must also determine when the monitoring and measuring shall be performed and when
the results from monitoring and measurement will be analyzed and evaluated.
 ➢ The organization must ensure that calibrated or verified monitoring and measurement
equipment is used and maintained, as appropriate.

The organization must also evaluate its environmental performance and the effectiveness of the
environmental management system

When determining what should be monitored and measured, In addition to progress on

environmental objectives, the organization should take into account its significant environmental
aspects, compliance obligations, and operational controls.

The methods used by the organization to monitor and measure, analyze and evaluate should be
defined in the environmental management system, in order to ensure that:

➢ The timing of monitoring and measurement is coordinated with the need for analysis and
evaluation results;

➢ The results of monitoring and measurement are reliable, reproducible and traceable;

➢ The analysis and evaluation are reliable and reproducible and enable the organization to
report trends.

Monitoring and measurement help you:

➢ Evaluate environmental performance;

➢ Analyze the root causes of problems;

➢ Assess compliance with legal requirements;

➢ Identify areas requiring corrective action, and,

Improve performance and increase efficiency. In short, monitoring and measurement help you
manage your organization better. The results of pollution prevention and other efforts are easier to
demonstrate when current and reliable data are available. These data can help you demonstrate the
value of the EMS to top management. Your organization should develop means to:

➢ 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.
Review and improve your environmental management system (EMS)
Carry out an EMS management review

Guide

A management review is the final element of the environmental management system (EMS)
process. It involves a formal evaluation of the adequacy of your business' EMS - taking into
account any new environmental issues, legislation, changing circumstances and continual
improvement.

Management review meetings should be attended by individuals with either executive or

specialist responsibility, for example:

➢ the site director

➢ the management representative

➢ line managers with specific environmental responsibilities

In these meetings, the management representative should give the results of any recent audits to
senior management and present a written report detailing audit findings.

The management review should cover:

➢ Environmental performance and progress in achieving objectives and targets

➢ Compliance with legislation

 ➢ Results of internal audits and reports

➢ Actions required as a result of non-conformances

➢ New processes and any changes to known environmental issues

Any changes in circumstances - for example changes in legislation or new technology

➢ The effectiveness of training

➢ The need for any revisions to your environmental policy, objectives and targets

➢ Follow-up actions from previous management reviews