EMS FencelineEMS Fenceline• Factors that will define the scope

of each NAA location’s EMS

– Physical size of your location – Research mission of your facility – Self-supporting location versus

tenant of a larger facility having its own EMS

– State and municipal agencies that have environmental regulatory oversight over your location

Step 1 Step 1 • Look at the Comprehensive Picture of Your Look at the Comprehensive Picture of Your

FacilityFacility– Research Activities– Facility Operations Activities – Construction and Demolition Activities

• Within Your “Fenceline”, Identify and List Within Your “Fenceline”, Identify and List ActivitiesActivities– Crop research– Animal research– Use hazardous chemicals– Generate hazardous waste

Characterizing Your Activities, Characterizing Your Activities, Products, and ServicesProducts, and Services

• Interviews with research and field staff (what are they doing, are they using hazardous materials, etc.)

• What are your location’s hazardous material purchases (review inventories)

• Hazardous waste records• Records from emergency planning, accident

reports, emergency incidents• Water and energy consumption records

STEP 2STEP 2

• Determine if there are environmental aspects associated with each activity on your list

• An environmental aspect is the part of an activity, product, or service that interacts with the environment. An aspect can be thought of as the actual or potential “cause” of an environmental impact.

• Aspects can be regulated or unregulated.

Example 1Example 1 Activity, Product,

or Service• Purchasing

Hazardous Chemicals

Environmental Aspects

• Depletion of natural resources in the following ways:

(a) Energy utilized in chemical manufacturing; and

(b) Energy requirements for chemical storage (e.g., use of electricity for low-temperature refrigeration or ventilation

• Generation of hazardous waste by the following activities:

(a) Duplicate purchasing of hazardous chemicals already on location inventory;

(b) Large-scale purchasing of unusable quantities of chemical; and,

(c) Chemical is not used, resulting in chemical entering hazardous waste stream due to expired use date.

Example 2Example 2

Activity, Product, or Service

• Facility Maintenance

Environmental Aspects

• Hazardous waste generation (spent fluorescent lamps, PCB containing lamp ballasts, spent solvents, paints)

• Generation of asbestos-containing waste• Generation of universal waste (used oils,

mercury-containing equipment)• Ozone depletion (repair of older refrigeration

equipment containing ozone depleting refrigerants)

• Generation of solid waste (excess furniture and equipment)

• Release of volatiles

Example 3Example 3

Activity, Product, or Service

• Vehicle maintenance

Environmental Aspect

• Hazardous waste generation• Gasoline consumption• Noise generation• Electricity consumption• Solid waste generation• Water consumption• Waste water generation• Release of volatiles

Example 4Example 4

Activity, Product, or Service

• Office work

Environmental Aspect

• Electricity consumption• Water consumption• Waste water generation• Release of ozone

depleting substances in air cooling units

• Solid waste generation• Disposal of toxics from

computer toner, etc.

Building an Aspects Register

• Assemble list of activities, products, and services

• Characterize activities, products, and services

• List aspects

• Organize and rank aspects as appropriate

Step 3Step 3• A significant environmental aspect is an

environmental aspect that has or can have a significant environmental impact.

• Significance could be tied to:– Environmental concerns– Natural resource concerns– Regulatory or legal exposure– Business or mission concerns– Concerns of interested parties

Factors That May Play a RoleFactors That May Play a Rolein Managing Aspectsin Managing Aspects

• Size, severity and duration of environmental impact

• Ease of improvement

• Regulatory or Executive Order requirement

• Cost

• Mission impact

• Community impact

• Sustainability

Determining Significant AspectsDetermining Significant Aspects

Potential factors– severity– probability/frequency– risk (environmental/

health/financial)– Mission impact

– external concerns– ability to control/

improve– duration– regulatory concern

Use reproducible methodology; e.g., rank using a formula containing factors the organization considers important

Ranking Aspects to Determine Those That Should Be Managed

Under My Location’s EMS

Severity

• 5 Catastrophic• 4 High• 3 Moderate• 2 Low• 1 Slight• 0 Positive Impact

Regulatory Importance

• 5 Current violation

• 4 Non-compliance, past 3 yrs

• 3 Non-compliance, past 5 yrs

• 2 In compliance• 1 Below regulatory cut-off• 0 Unregulated