Environmental Aspects - E2S2

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Environmental Aspects - E2S2

Improved Compliance Performance using your EMSMay 11, 2011


Goal and Agenda• Goal– Provide tips and suggestions on making the EMS program a useful mechanismfor improving compliance and not just another item on the to-do list• Agenda– Plan– Check– Act– Questions2


Benefits with EMS• Supports sustainability• Improved environmentalperformance• Reduced operational costs• Improved compliance• Improved process efficiency• Fewer overlaps and gaps betweenprograms• Maximize use of existing capabilities• Proactive versus reactiveEMSStormwaterSPCCAirHazardous WasteEMSStormwaterSPCCAirHazardous Waste3


ISO 14001 StandardEnvironmentalPolicyManagement ReviewPlanning• Environmental Aspects• Legal & Other• Objectives and Targets• Env. Mgmt. ProgramsChecking & Corrective Action• Monitoring & Measurement• Evaluation of Compliance• Non-Conformance/ Corrective & PreventiveAction• Records• EMS AuditsImplementation & Operation• Structure and Responsibility• Training, Awareness & Competence• Communication• Document Control• EMS Documentation• Operational Control• Emergency Preparedness & Response4


EMS Plan Phase• Environmental Policy• Broad statement of commitment to the environment• Environmental Aspects and Impact• Know how your operations impact the environment• Compliance Site Inventory on steroids• Prioritize the impact your operations have on the environment• Legal & Other• Knowing legal requirements• Objectives, Targets, and Programs• Setting goals & ways to achieve those goals5


Environmental Aspects & Compliance: Challenges• Seems simple to know how your operationsimpact the environment, but….• Many installations are the size of smallcities• Institutional knowledge lost inenvironmental staff turnover• Stove-piping• Mission or unit turnover• Lack of environmental knowledge by theend user• You don’t know what you don’t know– atleast with the proverbial haystack youknow to look for the needle!6


Environmental Aspects & Compliance: Opportunities• Protect institutional knowledge• Cross training• Succession planning• Turnover binders• Maximize input from boots on the ground• Inspectors (cross train them as necessary)• Internal audits• Unit environmental coordinators• Media inventories (AEIs, SPCCs, monitoring well locations,etc)• Who is out in the ‘action’ the most?• Make these folks your EMS allies• Incorporate information on upcoming projects• Have the NEPA/ Record of Environmental Considerationprocess feed into the EMS• Seek input from planners7


Environmental Aspects & Compliance: Opportunities• Create an aspect update process that utilizesthese resources• Once per year big round table with allstakeholders• Many small meetings with fewer stakeholders• Charter and empower the stakeholders to bringinformation whenever they have it• If you have the option, keep your inventory toalign with your information sources• Location• Unit• Process• Environmental Media• Periodically cross reference your aspectinventory• If organized by process, does the inventory coverall areas of the installationFrom the ISO14001:2004 Standard:The organization shall establish,implement and maintain aprocedure(s)a) to identify the environmentalaspects of its activities, productsand services taking into accountplanned or new developments, ornew or modified activities,products and services, andb) to determine those aspectsthat have or can have significantimpact(s) on the environment (i.e.significant environmentalaspects).8


Environmental Aspects & Compliance: Opportunities• How does this improve compliance performance?• Can truly assess most significant aspects• Determine if any environmental aspects present a risk to the mission• Better resource allocation• No surprises• Real life example:• Learned of ‘legacy’ public work noncompliance across the street from regulators• the process for reviewing new projects had failed to catch an old issue• Started incorporating public work engineers into environmental meetings andinventory to cover new and old projects9


ISO 14001 StandardEnvironmentalPolicyManagement ReviewPlanning• Environmental Aspects• Legal & Other• Objectives and Targets• Env. Mgmt. ProgramsChecking & Corrective Action• Monitoring & Measurement• Evaluation of Compliance• Non-Conformance/ Corrective & PreventiveAction• Records• EMS AuditsImplementation & Operation• Structure and Responsibility• Training, Awareness & Competence• Communication• Document Control• EMS Documentation• Operational Control• Emergency Preparedness & Response14


EMS Check Phase• Monitoring & Measuring• Data to track the environmental impact of significant aspects• Evaluation of Compliance• Assessing conformance to the EMS standard• Non-conformance and corrective and preventative action• Records• Process for handling mistakes and issues• Documented evidence of environmental performance• EMS Audits• Assessing conformance to the EMS standard15


Monitoring & Measuring & Compliance• Basic Monitoring & Measuring includes• Permit-prescribed conditions (air emissions, NPDES limits, etc)• Tracking progress on objectives and targets• Calibrating permit-required monitoring equipment• Broader take on monitoring and measuring can do more to improvecompliance• Leading indicators – indicate where problems might occur in the future• Lagging indicators – indicate where problems already exist“Lag” theTurtle“Lead” the HareIf you don’t monitoryour leading indicators,your lagging indicatorscould surprise you.16


Monitoring & Measuring & Compliance• Examples of Lagging Indicators• Number of non-compliance incidents and repeat incidents• Number of non-conformance audit findings• Number of active regulatory investigations• % completion of corrective actions• Examples of Leading Indicators• % of regulatory requirements without documented operational controls• % of workers trained on operational controls• # of regulatory awareness training units overdue• % of defined significant aspects with training programs• % of complete workplace observations• % of document operational controls review cycles overdue17


Monitoring & Measuring & Compliance• Analyzing Indicators• Look for trends• Improving or not?• Mine for data• Where (what location) are negative indicators occurring?• Which programs have the most negative indicators?• What are the root causes?Metric Goal Trend 2010 2009% of Regulatory Requirements WithoutDocumented Operational Controls25% Improving 30% 35%# of Env Awareness Training Units Overdue 75 Worsening 130 119# of Compliance Findings from InternalAssessments12 Stable 30 30Location of most Compliance Findings Random ConstructionSitesNew CommissaryNew HQ Building18


Monitoring & Measuring Benefits• How does this improve complianceperformance?• Total view of risk (by themselves laggingindicators only show the tip of the iceberg)• Provides enough advance notice to turn the ‘ship’around• Real life example:• 1400+ NPDES outfalls, 90% improvement incompliance!• However, monitoring and measuring not theonly key element in success…19


ISO 14001 StandardEnvironmentalPolicyManagement ReviewPlanning• Environmental Aspects• Legal & Other• Objectives and Targets• Env. Mgmt. ProgramsChecking & Corrective Action• Monitoring & Measurement• Evaluation of Compliance• Non-Conformance/ Corrective & PreventiveAction• Records• EMS AuditsImplementation & Operation• Structure and Responsibility• Training, Awareness & Competence• Communication• Document Control• EMS Documentation• Operational Control• Emergency Preparedness & Response20


Act Phase• ISO 14001:2004 management review inputs include– Results of audits,– Communication(s) from external interested parties,– Environmental performance of the organization,– The extent to which objectives and targets have been met,– Status of corrective and preventive actions,– Follow-up actions from previous management reviews,– Changing circumstances, including regulatory developments, and– Recommendations for improvement.• Outputs from management reviews include decisions and actions related tothe management system21


Act Phase & Compliance• Management Review = Environmental Risk Management– Is your EMS designed to adequately and effectively reduce compliance risks? Whatdesign changes need to be made?– Command staff are responsible for resource allocation decisions that impactcompliance• Management Review is your chance to• Inform Command staff of environmental compliance risks and consequences• Get decisions on resource allocation• Earn the support of Command Staff• Brag on your program’s successes• Be direct• Command staff do not have extra time or environmental background• Use clear and concise metrics developed in Measuring and Monitoring• Charts, scorecards, etc• Where do current and potential problems (and opportunities) exist?• How do the identified issues impact or potentially impact the mission?22


Act Phase & Benefits• How does this improve compliance?– Informed leadership = engaged leadership = better decisions– Supportive command structure can help increase buy-in through the installation– Environmental office is more likely to have support of others and viewed as apriority• Real life example• Engaging leadership through ISO14001 registration process• Registration was important and frequent topic for Command staff atmanagement reviews• Other office/ divisions/ managers saw the emphasis• ISO14001 audits became ‘big stick’ for the environmental office23


Summary• The Bad News:– EMSs take work– Reap what you sowNon compliances• The Good News:– EMSs can have all the benefits promised• Improved compliance• Cost savingsEMS• Proactive approachStormwaterSPCCAirHazardous Waste24


Questions?Charlotte PughCH2M HILL727-735-8080Charlotte.Pugh@ch2m.com25

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