environmental management system (ems) implementation guide for the shipbuilding … ·...

ENVIRONMENTAL MANAGEMENT SYSTEM (EMS) IMPLEMENTATION GUIDE

FOR THE SHIPBUILDING AND SHIP REPAIR INDUSTRY

November 2001 Version 3.0

Sustainable Industries

Partnership Programs

Introduction i

ENVIRONMENTAL MANAGEMENT SYSTEM (EMS) IMPLEMENTATION GUIDE FOR THE

SHIPBUILDING AND SHIP REPAIR INDUSTRY (VERSION 3.0)

Introduction & User Guide This EMS Implementation Guide (Guide) for the shipbuilding and ship repair industry has been assembled from the best and most recent guidance, examples, tools, and forms included in several U.S. Environmental Protection Agency (EPA)-sponsored EMS source documents (see annotated list at the end of the introduction). Using information collected from shipbuilding and ship repair publications, facility site visits, and telephone interviews, this Guide has been customized to address industry conditions. It is meant to assist shipbuilding and ship repair facilities in those areas that will have the most immediate impact on improving environmental performance and associated economic performance. Many shipbuilding and ship repair facilities have components of an EMS already in place. This Guide encourages the user to identify and build on existing components whenever possible. This Guide describes an EMS that is based on the elements of the ISO 14001 standard and also incorporates EPA's National Environmental Performance Track emphasis on sustained compliance, pollution prevention, and information sharing with the community. Though there are other types of EMSs that one could adopt, and EPA does not specifically endorse any individual EMS standard, the ISO 14001 EMS is the one most widely recognized across the world and one that many companies are beginning to require their suppliers to adopt. Therefore, moving in the direction of implementation and maintenance of an EMS based on the ISO 14001 standard may be a wise business decision. The choice to build an EMS that, if desired, could be certified sometime in the future, may make sense for you based on your business goals and needs. Facilities implementing an EMS which meets the requirements of the ISO 14001 standard can either self-declare conformance or seek third-party registration. To facilitate your implementation process, this Guide contains eighteen modules, each corresponding to an EMS element. These modules are grouped into four activities that correspond generally to the plan-do-check-act model that most management systems follow:

• Laying the groundwork; • Developing policy and planning elements; • Developing implementation elements; and • Developing corrective and preventive action, management review, and continual

improvement elements.

There is logical sequence in working through the modules in their numbered order for the first two activities. Once an initial round of EMS planning is complete, the modules in the second two activities can be approached in a somewhat parallel fashion. For an example, you may wish to refer to Module 1, Example 1-1: Example Schedule for EMS Implementation.

Introduction ii

There are four different types of material provided in the modules of this EMS guide. Definitions of each are provided below:

• Guidance. Guidance refers to information that describes what an EMS element represents and what you will need to develop and maintain to fully satisfy EPA’s definition of a complete EMS.

• Tools. Tools refer to worksheets or questionnaires that assist you in thinking through how to create a particular EMS element efficiently and comprehensively. Tools are important to the process of defining what in your EMS will later be documented, recorded, monitored, measured, audited, or reviewed by top management. Sample procedures that you can adopt for your own EMS are also considered tools.

• Forms. Forms are different from tools in that they can actually become part of your documented system, for instance serving as records or information that might be measured, monitored, audited, or reviewed by top management.

• Examples. These are examples of how one might use a tool or complete a form.

Definitions of EMS terms used in this Guide are provided in the text, as well as in the glossary in Appendix A. Reviewers and users should note that Version 4.0 of this Guide represents a working document and will be refined based on input from the implementation team which includes representatives of EPA, trade associations, and shipbuilding and ship repair facilities. During 2001-2002, the Guide will be tested and refined as part of an EPA-sponsored pilot project regarding EMS implementation for the shipbuilding and ship repair industry. Brief descriptions of the EPA-sponsored EMS source documents used to develop this guide are provided below:

• Integrated Environmental Management Systems Implementation Guide, EPA, Office of Pollution Prevention and Toxics, EPA 744-R-00-011, October 2000. This document represents efforts by EPA to show how Design for the Environment (DfE) technical work can be used to support the development of an EMS. It unites the EMS plan-do-check-act model with DfE approaches such as the EPA Cleaner Technologies Substitutes Assessment Methodology. It contains useful EMS guidance, tools, forms, and examples and has material especially relevant to facilities with intensive chemical use.

• Integrated Environmental Management Systems, A Company Manual Template for Small Business, EPA, Office of Pollution Prevention and Toxics, EPA 744-R-00-012, December 2000. This document represents an EMS template, including cover page, table of contents, and complete documentation, for a fictional corporation. It contains procedures and associated forms for an EMS that is designed according to the principles of the Integrated Environmental Management System implementation guide (see above).

Introduction iii

• Environmental Management Systems: An Implementation Guide for Small and Medium-Sized Organizations, NSF International, Second Edition, January, 2001. This document, supported with funding from the EPA Office of Water, explains EMS concepts, using the ISO 14001 standard guidance, tools, forms and examples that are broadly applicable to many different types of businesses.

• Implementation Guide For The Code of Environmental Management Principles for Federal Agencies (CEMP), EPA, Office of Enforcement and Compliance Assurance, EPA 315-B-97-001, March 1997. This document helps federal agencies move toward responsible and proactive environmental management. It describes five broad principles that are meant to foster environmental performance objectives that are proactive, flexible, cost-effective, integrated, and sustainable.

• Environmental Management Review (EMR) National Report: Lessons Learned in Conducting EMRs at Federal Facilities, EPA, Office of Enforcement and Compliance Assurance, EPA 315-R-99-003, November 1999. This document presents lessons learned by EPA from its review of individual facility environmental protection programs and management systems. This program is intended to ensure compliance and progress towards environmental excellence. Supplementary EMR Checklists are also included with this document.

• The EPA Environmental Management System Pilot Program for Local Government Entities, Prepared by Global Environment & Technology Foundation, Assistance Agreement No. X 825557-01-0, January 2000. This document represents a final report to EPA on a multi-year pilot program to implement EMS for local government entities. It presents lessons learned and examples that can be useful to businesses and other organizations.

• Improving Environmental Performance and Compliance, 10 Elements of Effective Environmental Management Systems, Guidance Document, Enforcement Cooperation Program of the Commission for Environmental Cooperation, June 2000. This document sets out what the three North American governments have agreed is important to address in implementing an EMS. It is intended to assist EMS users in making responsible decisions and taking actions to achieve better environmental performance by maintaining and moving beyond compliance with environmental laws. It provides a list of ten elements to ensure that what needs to be done is being done to meet environmental goals. It is intended as guidance for those organizations in the public and private sectors that seek to apply EMS in a way that will work effectively and build better relationships with customers, suppliers, lenders, investors, the local community, and the government.

Shipbuilding and Ship Repair Industry - EMS Implementation Guide Rev. 3.0 (November 2001)

Introduction iv

Table of Contents Introduction Introduction and User Guide Text Table of Contents Index of Tools, Forms, and Examples

Laying the Groundwork for EMS Module 1: Laying the Groundwork EMS Policy and Planning Module 2: Structure and Responsibility Module 3: Environmental Policy Module 4: Legal and Other Requirements Module 5: Environmental Aspects Module 6: Objectives and Targets Module 7: Environmental Management Program(s) EMS Implementation Module 8: Training, Awareness, and Competence Module 9: Communication Module 10: EMS Documentation Module 11: Document Control Module 12: Operational Control Module 13: Emergency Preparedness and Response EMS Corrective & Preventive Action, Management Review, and Continuous Improvement Module 14: Monitoring and Measurement Module 15: Nonconformance and Corrective and Preventive Action Module 16: Records Module 17: EMS Audits Module 18: Management Review Appendices A Glossary B EPA’s National Environmental Performance Track C Integration of Environmental Management Systems and Quality Management Systems D Health and Safety Integration Questionnaire E Environmental Aspect/Impact Ranking


Introduction v

Index of Tools, Forms, and Examples

MODULE 1: Laying the Groundwork

Tool 1-1: Gap Analysis Tool/Self-Assessment Checklist Tool 1-2: Sample Worksheet for Persons Responsible for EMS Development Example 1-1: Schedule for EMS Implementation

1-16 1-26 1-27

MODULE 2: Structure & Responsibility

Tool 2-1: Structure and Responsibility Worksheet Tool 2-2: Sample EMS Responsibilities Descriptions Form 2-2: EMS Responsibilities Example 2-1: Responsibility Matrix Example 2-2: Organization Chart

2-7 2-8 2-9 2-10 2-12

MODULE 3: Environmental Policy

Tool 3-1: Environmental Policy Worksheet Example 3-1: Generalized Environmental Policy Template

3-4 3-5

MODULE 4: Legal and Other Requirements

Tool 4-1: Legal and Other Requirements Worksheet Tool 4-2: Sample Worksheet for Identifying Legal Requirements Tool 4-3: Sample Procedure for Identification of Legal and Other Requirements Form 4-3: Sample Form for Legal and Other Requirements Tool 4-4: Information Resources for Legal Requirements Example 4-1: Commonly Applicable Federal Environmental Laws in the U.S. Example 4-2: Shipbuilding and Ship Repair Industry Operations: List of Applicable Environmental Legal Requirements

4-4 4-5 4-6 4-7 4-8 4-9 4-10


Introduction vi

MODULE 5: Environmental Aspects

Tool 5-1: Techniques and Data Sources for Identifying and Evaluating Environmental Impacts Tool 5-2: Sample Procedure for Identification of Environmental Aspects and Determination of Significant Aspects Tool 5-3: Worksheet for Identifying Community Issues Tool 5-4: Worksheet for Identifying Natural Resources Use/Pollution Prevention Potential Form 5-2: Identification and Significance Determination of Environmental Aspects and Setting Objectives and Targets Example 5-1: Common Activities and Processes at Shipbuilding and Ship Repair Facilities Flow Diagrams and Aspect Identification and Significance Determination Forms for: Example 5-2: Drydock Painting Example 5-3: Small Parts Coating, Outdoors Example 5-4: Gas Metal Arc Welding Example 5-5: Dry Abrasive Blasting Example 5-6: Burning and Cutting Example 5-7: Ultra High Pressure Water Jetting Example 5-8: Metal Grinding Example 5-9: Material Transport, Crane

5-9 5-10 5-15 5-15 5-14 5-17 5-18 5-22 5-26 5-29 5-31 5-35 5-38 5-41

MODULE 6: Objectives & Targets

Tool 6-1: Objectives and Targets Worksheet Tool 6-2: Sample Procedure for Identification of Objectives and Targets Example 6-1: Objectives and Targets Organized by Category Example 6-2: Identification of Objectives and Targets for Drydock Painting

6-5 6-6 6-6 6-8

MODULE 7: Environmental Management Program(s)

Tool 7-1: Environmental Management Program Workshop Tool 7-2: Sample Procedure for Environmental Review for New Purchases, Processes, and Products Form 7-1: Sample Form for Environmental Management Program(s) Form 7-2: Sample New Purchase Approval Form for Environmental Review of New Processes, Products, and Activities

7-4 7-6 7-5 7-7


Introduction vii

MODULE 7 (cont) Example 7-1: Environmental Management Program for Reduction of Fugitive VOC, HAP, and Particulate Emissions Example 7-2: Environmental Management Program for Reduction of Solid Waste from the Unmasking Activity

7-8 7-10

MODULE 8: Training, Awareness, & Competence

Tool 8-1: Training, Awareness & Competence Worksheet Tool 8-2: Sample Procedure for Environmental Training Form 8-2: Sample Training Needs Analysis Form Example 8-1: Training Needs Analysis Form

8-4 8-5 8-7 8-9

MODULE 9: Communication

Tool 9-1a: Communications Worksheet Tool 9-1b: Sample Communications Program Matrix Tool 9-2: Sample Procedure for Communication with Stakeholders Form 9-2a: Sample Form for Stakeholders and Environmental Issues Form 9-2b: Sample Form for External Stakeholder Communication Record Example 9-1: Case Study – Working with Stakeholders Example 9-2: Communications Program Matrix

9-7 9-8 9-9 9-10 9-11 9-12 9-13

MODULE 10: EMS Documentation

Tool 10-1: EMS Documentation Worksheet Tool 10-2: Sample Worksheet for Development of EMS Documentation Tool 10-3: Sample Outline for EMS Manual and Other EMS Documents Tool 10-4: Sample Procedure for EMS Documentation

10-6 10-7 10-8 10-9

MODULE 11: Document Control

Tool 11-1: Document Control Worksheet Tool 11-2: Sample Procedure for Document Control Form 11-2a: Sample Document Control Form Form 11-2b: Sample Document Index Form

11-4 11-5 11-6 11-7

MODULE 12: Operational Control

Tool 12-1: Operational Controls Worksheet Tool 12-2: Sample Worksheet for Determining Which Operations Require Operational Controls Tool 12-3: Sample Worksheet for Operational Control Responsibilities

12-7 12-8 12-9


Introduction viii

MODULE 12 (cont) Tool 12-4: Sample Worksheet for Training for Operational Controls Tool 12-5: Sample Procedure for Development of Operational Controls Form 12-5: Sample Form for EMS Operational Control Procedures Example 12-1: Operational Control for Coating and Thinner Use

12-10 12-11 12-12 12-13

MODULE 13: Emergency Preparedness & Response

Tool 13-1: Emergency Preparedness and Response Worksheet Tool 13-2: Emergency Preparedness and Response Requirements Matrix Tool 13-3: Sample Procedure for Emergency Preparedness and Response

13-4 13-5 13-6

MODULE 14: Monitoring & Measurement

Tool 14-1: Monitoring and Measurement Worksheet Tool 14-2: EMS Program Measurement Criteria Worksheet Tool 14-3: Sample Procedure for a Compliance Assessment Form 14-3: Sample Form for Compliance Tracking Tool 14-4: Pollution Prevention Tracking Log Tool 14-5: Calibration Log Tool 14-6: Tracking Environmental Measurement Indicators Example 14-1: Example of Links Between Aspects, Objectives and Targets, Operational Controls, and Monitoring and Measurement Example 14-2: Linking Operational Controls and Monitoring

14-8 14-9 14-10 14-11 14-12 14-13 14-14 14-15 14-16

MODULE 15: Nonconformance and Corrective & Preventive Action

Tool 15-1: Corrective & Preventive Action Worksheet Tool 15-2: Sample Procedure for Corrective and Preventive Action Form 15-2a: Sample Corrective and Preventive Action Notice Form 15-2b: Sample Corrective and Preventive Action Tracking Log

15-6 15-7 15-9 15-10

MODULE 16: Records

Tool 16-1: Records Management Worksheet Tool 16-2: Sample Checklist for Records of Supporting Documentation Example 16-1: Sample of Environmental Records Organizer Example 16-2: Sample EMS Records Management Table

16-4 16-5 16-6 16-7


Introduction ix

MODULE 17: EMS Audits

Tool 17-1: EMS Auditing Worksheet Tool 17-2: Sample Procedure for EMS Audits Form 17-2a: Sample Audit Plan Form Form 17-2b: Sample Form for Communications to Audit Team Form 17-2c: Sample Form for Internal Assessment Checklist Form 17-2d: Sample EMS Audit Summary Form Form 17-2e: Sample Form for EMS Audit Findings Example 17-1: Sample Questionnaire for EMS Audits Example 17-2: Sample Checklist for Top Management EMS Audits

17-7 17-8 17-11 17-12 17-13 17-14 17-15 17-16 17-25

MODULE 18: Management Review

Tool 18-1: Management Review Worksheet Tool 18-2: Sample Procedure for Management Review Form 18-2: Sample Management Review Record

18-5 18-6 18-7

Shipbuilding and Ship Repair Industry - EMS Implementation Guide Rev 3.0 (November 2001)

Laying the Groundwork for EMS

LAYING THE GROUNDWORK FOR EMS

The Laying the Groundwork section includes 1 of the 18 modules.

Ø Module 1: Laying the Groundwork


Laying the Groundwork for EMS Module 1 - 1

Module 1: Laying The Groundwork Guidance ..................................................................................................................................... 1-2

Figure 1-1: “Plan, Do, Check, Act” Model.................................................................... 1-4 Figure 1-2: EMS Model ................................................................................................. 1-7

Tools .......................................................................................................................................... 1-15

Tool 1-1: Gap Analysis Tool/Self-Assessment Checklist ............................................ 1-16 Tool 1-2: Sample Worksheet for Persons Responsible for EMS Development ........... 1-26

Examples................................................................................................................................... 1-27

Example 1-1: Schedule for EMS Implementation....................................................... 1-27



GUIDANCE

What is an EMS? An EMS is a continual cycle of planning, implementing, reviewing, and improving the processes and actions that an organization undertakes to meet its environmental obligations. Does my shipyard need an EMS? Well, ask yourself the following questions:

• Is your shipyard required to comply with environmental laws and regulations? • Are you looking for ways to improve your environmental performance? • Is the state of your shipyard’s environmental affairs a significant liability? • Does a lack of time or resources prevent your shipyard from managing its

environmental obligations effectively? • Is the relationship between your shipyard’s environmental goals and other goals

unclear?

If you answered YES to one or more of the above questions, an EMS can help your shipyard — and so will this Guide! This module provides you with the information you need to get started. It is divided into the following sections: • Frequently Asked Questions about EMS • EMS Costs and Benefits • Key EMS Concepts • Elements of an EMS • Laying the Groundwork for an EMS: Key Steps



Frequently Asked Questions about EMS

1. We already have a compliance program – why do we need an EMS? An EMS can help you comply with regulations more consistently and effectively. It also can help you identify and capitalize on environmental and business opportunities that go beyond compliance.

2. How big does an organization need to be to successfully implement an EMS? EMS has been implemented by organizations ranging in size from a couple of dozen employees to many thousands of employees. The elements of an EMS (as described in this Guide) are flexible to accommodate a wide range of organizational types and sizes.

3. To implement an EMS, do we have to start from scratch? Much of what you have in place now for environmental management probably can be incorporated into the EMS. There is no need to “start over”.

4. How will an EMS affect my existing compliance requirements? An EMS will not result in more or less stringent legal compliance requirements, but an EMS should improve your efforts to comply with legal requirements, and, in some cases, may lead to more flexibility. [See discussion of EPA’s National Environmental Performance Track (EPA’s Performance Track) in Appendix B. You may also want to contact your state environmental agency to inquire whether it has a recognition and reward program for facilities that implement an EMS.]

5. Do we need to be in 100% compliance in order to have an EMS? No. The concept of continual improvement assumes that no organization is perfect. While an EMS should help your organization improve compliance and other measures of performance, problems may still arise. However, an effective EMS should help you find and fix these problems and prevent their recurrence.



EMS Costs and Benefits

POTENTIAL COSTS

Internal • Staff time (manager and other employees)

(Note: Internal labor costs represent the bulk of the EMS resources expended by most organizations)

External • Potential consulting assistance • Potential outside training of personnel

POTENTIAL BENEFITS

• Improved environmental performance • Enhanced compliance assurance

• Prevention of pollution/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

• Reduced risk

Key EMS Concepts You have probably heard of Total Quality Management (TQM). Some shipyards may apply TQM principles to some of their operations and activities. An effective EMS is built on TQM concepts. Most EMS models (including the ISO 14001 standard) are built on the “Plan, Do, Check, Act” model introduced by Shewart and Deming for TQM. This model endorses the concept of continual improvement. To improve environmental management, your organization needs to focus not only on what things happen but also on why they happen. Over time, the systematic identification and correction of system deficiencies leads to better environmental (and overall organizational) performance.

Figure 1-1: “Plan, Do, Check, Act” Model

Plan

Do

Check

Act



Some of the keys to a successful EMS include: Top Management Commitment Applying TQM principles to the environmental area and providing adequate resources are the job of top management. To initiate and sustain the EMS effort, top management must communicate to all employees the importance of: • Making the environment an organizational priority (thinking of effective environmental

management as fundamental to the organization’s survival); • Integrating environmental management throughout the organization (thinking about the

environment as part of product/service and process development and delivery, among other activities); and

• Looking at problems as opportunities to improve (identifying problems, determining root causes and preventing problem recurrence).

Focus on Continual Improvement No organization is perfect. The concept of continual improvement recognizes that problems will occur. A committed organization learns from its mistakes and prevents similar problems from recurring. Flexibility and Simplicity An effective EMS must be dynamic to allow your organization to adapt to a quickly changing environment. For this reason, you should keep your EMS flexible and simple. This also helps make your EMS understandable for the people who must implement it — your organization’s managers and other employees. Compatibility with Organizational Culture The EMS approach and an organization’s culture should be compatible. For some organizations, this involves a choice: (1) tailoring the EMS to the culture or (2) changing the culture to be compatible with the EMS approach. Bear in mind that changing an organization’s culture can be a long-term process. Keeping this compatibility issue in mind will help you ensure that the EMS meets your organization’s needs. Employee Awareness and Involvement As you design and implement an EMS, roadblocks may be encountered. Some people may view an EMS as bureaucracy or extra expense. There also may be resistance to change or fear of new responsibilities. To overcome potential roadblocks, make sure that everyone understands why the organization needs an effective EMS, what their role will be, and how an EMS will help to control environmental impacts in a cost-effective manner. Employee involvement helps to demonstrate the organization’s commitment to the environment and helps to ensure that the EMS is realistic, practical and adds value.



Building or improving an EMS (with the help of this Guide) provides an opportunity to assess how your shipyard manages environmental obligations and to find better (and more cost-effective) solutions. While you will probably identify some areas where your current EMS can be improved, this does not mean that you should change things that are working well! By reviewing what your organization does and how well it works, you can ensure that your EMS will be viable and effective, both now and in the future. Finally, don’t get discouraged if your system has some bugs at first — the focus is on continual improvement!

A few hints to keep in mind as you build your EMS: • Pace yourself — Move quickly enough that employees stay

interested and engaged, but not so fast that those involved are overloaded or that the effort becomes superficial.

• Don’t re-invent the wheel — existing management practices

should help address many EMS requirements.

• Help is available — don’t hesitate to use it. Potential sources of help include the EPA, state & local governments, public assistance providers (such as universities), and consultants.

Consultants can help you evaluate your EMS and suggest approaches used successfully elsewhere. Explore ways to hold consulting costs down. You may be able to join forces with other organizations to hire a consultant or sponsor a training course. Remember that an EMS developed by consultants “in isolation” will not work. Your own people need to be involved in the EMS development process.



Elements of an EMS As mentioned earlier, your EMS should be built on the “Plan, Do, Check, Act” model to ensure that environmental matters are systematically identified, controlled, and monitored. Using this approach will help to ensure that performance of your EMS improves over time. This section describes the seventeen EMS elements that are common to most EMS models and notes the key linkages among these elements (see Figure 1-2). While there are several good EMS models available, this Guide uses the ISO 14001 standard as a starting point for describing EMS elements. This has been done for several reasons:

• ISO 14001 is a widely accepted international standard for EMS that focuses on continual improvement;

• Companies may be asked to demonstrate conformance with ISO 14001 as a condition of doing business in some markets; and

• The ISO 14001 standard is consistent with the key principles found in many EMS-based programs, including the EPA’s Performance Track and many state environmental programs.

Figure 1-2: EMS Model

Planning

• Environmental Aspects • Legal & Other Requirements

• Objectives & Targets • Environmental Management

Program(s)

Implementation • Structure & Responsibility

• Training, Awareness, Competence • Communication

• EMS Documentation • Document Control • Operational Control

• Emergency Preparedness / Response

Start

• Environmental Policy

Checking / Corrective Action

• Monitoring & Measurement • Nonconformance & Corrective &

Preventive Action • Records

• EMS Audits

Continual Improvement!

• Management Review

• EMS elements are indicated with a bullet.



17 Elements of an EMS: A Snapshot

• Environmental policy — Develop a statement of your organization’s commitment to the environment. Use this policy as a framework for planning and action.

• Environmental aspects — Identify environmental attributes of your products, activities and services. Determine those that could have significant impacts on the environment.

• Legal and other requirements — Identify and ensure access to relevant laws and regulations, as well as other requirements to which your organization adheres.

• Objectives and targets — Establish environmental goals for your organization, in line with your policy, environmental impacts, the views of interested parties and other factors.

• Environmental management program(s) — Plan actions necessary to achieve your objectives and targets.

• Structure and responsibility — Establish roles and responsibilities for environmental management and provide appropriate resources.

• Training, awareness and competence — Ensure that your employees are trained and capable of carrying out their environmental responsibilities.

• Communication — Establish processes for internal and external communications on environmental management issues.

• EMS documentation — Maintain information on your EMS and related documents. • Document control — Ensure effective management of procedures and other system

documents. • Operational control — Identify, plan and manage your operations and activities in line

with your policy, objectives and targets. • Emergency preparedness and response — Identify potential emergencies and

develop procedures for preventing and responding to them. • Monitoring and measurement — Monitor key activities and track performance.

Conduct periodic assessments of compliance with legal requirements. • Nonconformance and corrective and preventive action — Identify and correct

problems and prevent their recurrence. • Records — Maintain and manage records of EMS performance. • EMS audit — Periodically verify that your EMS is operating as intended. • Management review — Periodically review your EMS with an eye to continual

improvement.

Note: the next 17 modules in this Guide provide guidance, tools, forms and examples for each of these key elements of an EMS.



Integration of Quality Management System (QMS) and EMS If your organization already has, or is considering, a quality management system (based on ISO 9001: 1994, for example) -- you will find significant synergy between what you need for quality management and for environmental management (see below). A thorough discussion of quality and environmental management systems integration is provided in Appendix C.

Some Common Aspects of Quality and Environmental Management Systems

QMS • Quality Policy • Adequate Resources • Responsibilities and Authorities • Training • System Documentation • Process Controls • Document Control • System Audits • Management Review

EMS • Environmental Policy • Adequate Resources • Responsibilities and Authorities • Training • System Documentation • Operational Controls • Document Control • System Audits • Management Review

Aspects of Health & Safety in EMS Your Health and Safety (H&S) program can play a significant role in EMS because it reflects how your company currently handles human health concerns; in many areas, H&S and environmental concerns and requirements may be similar and some requirements may be addressed concurrently. Therefore, some companies find that integrating H&S and EMS efforts can achieve improved compliance or cost savings. A questionnaire regarding the integration of H&S into your EMS can be found in Appendix D.



Laying the Groundwork for an EMS: Key Steps

1. Define organization’s goals for EMS. 2. Secure top management commitment. 3. Select EMS leadership. 4. Build implementation team. 5. Hold kick-off meeting. 6. Conduct gap analysis. 7. Prepare budget and schedule. 8. Secure resources and assistance. 9. Involve employees. 10. Monitor and communicate progress.

A first step in EMS planning is to decide why you are pursuing the development of an EMS. Are you trying to improve your environmental performance (for example, reducing risk associated with regulatory non-compliance or increasing pollution prevention)? Are you trying to promote involvement throughout the organization? Write down your goals and refer to them frequently as you move forward. As you design and implement the EMS, ask: How is this task going to help us achieve our goals? This also is a good time to define your EMS scope or “fenceline” (i.e., what is the “organization” that the EMS will cover? One location? Multiple locations? Should we “pilot” the EMS at one location then implement the system at other locations later?). See Tips on Defining an Appropriate Scope at the end of this section. One of the most critical steps in the planning process is gaining top management’s commitment to support EMS development and implementation. Management must first understand the benefits of an EMS and what it will take to put an EMS in place. Explain the strengths and limitations of your current approach and how those limitations can affect your financial and business performance. Then explain how an EMS can help address these limitations. Management also has a role in ensuring that the goals for the EMS (see above) are clear and consistent with other organizational goals. Management’s commitment should be communicated across the organization.

Define

Organization's Goals for EMS

Secure Top

Management Commitment



Small organizations may only have a single EMS “champion”, but larger ones will usually have two levels of EMS leadership. An Environmental Management Representative (EMR) should be chosen from the organization’s top management group to be responsible for the functioning of the EMS (i.e. making sure that all tasks relating to the EMS are identified and completed in a timely manner). The EMR is responsible for reporting periodically to the top plant management group on the progress and results of the EMS. An EMS Coordinator should have time to commit to the EMS-building process because his or her responsibility will be to work closely with the EMR and with the cross functional team (see below) to identify, assign, schedule, provide the necessary support for, and ensure completion of all tasks relating to the EMS. A cross functional team (CFT) with representatives from key management functions (such as engineering, finance, human resources, production and/or service) can identify and assess issues, opportunities, and existing processes. Consider including contractors, suppliers or other external parties as part of the CFT, where appropriate. The CFT will need to meet regularly, especially in the early stages of your EMS efforts. A CFT can help to ensure that procedures are practical and effective and can build commitment to and “ownership” of the EMS. See Module 2 for more information. Once the team has been selected, hold a kick-off meeting to discuss the organization’s goals in implementing an EMS, the steps that need to be taken initially, and the roles of team members, among other topics. If possible, get top management to describe its commitment to the EMS at this meeting. The kick-off meeting also is a good opportunity to provide some EMS training for CFT members. Follow this meeting with a communication to all employees.

Select EMS

Leadership

Build

Implementation Team

Hold Kick-off

Meeting



The next step is for the CFT to conduct a gap analysis of your current compliance and other environmental programs/systems and to compare these against the criteria for your EMS (such as ISO 14001). Evaluate your organization’s structure, procedures, policies, environmental impacts, training programs and other factors. Determine which parts of your current EMS are in good shape and which need additional work. See Tips on Gap Analysis at the end of this section and Tool 1-1, Gap Analysis Tool/Self-Assessment Checklist. Based on the results of the preliminary review, prepare an implementation plan, with a budget and schedule. The plan should identify what key actions are needed, who will be responsible, what resources are needed, and when actions will be completed. Keep the plan flexible, but set some stretch goals. Think about how you will maintain project focus and momentum over time. Look for potential “early successes” that can help to build momentum and reinforce the benefits of the EMS. Guidance, tools, forms and examples in Module 2 will help you in planning the necessary human and financial resources. Refer to Example 1-1 for a schedule that you can customize as your EMS implementation timeline. The plan and budget should be reviewed and approved by top management. In some cases, there may be outside funding or other types of assistance available (from a trade association, a state technical assistance office, etc.). Employees are a great source of knowledge on environmental and health & safety issues related to their work areas as well as on the effectiveness of current processes and procedures. They also can help the project team in drafting procedures. Ownership of the EMS will be greatly enhanced by meaningful employee involvement in the EMS development process. As you build the EMS, be sure to regularly monitor your progress against the plan and communicate this progress within the organization. Be sure to communicate the accomplishments that have been made and describe what happens next. Build on small successes. Be sure to keep top management informed and engaged, especially if additional resources might be required.

Monitor and Communicate

Progress

Prepare Budget and Schedule

Secure Resources and

Assistance

Conduct Gap

Analysis

Involve Employees



Tips on Defining an Appropriate Scope Part of laying the groundwork for you EMS involves defining its scope. To define the scope, define boundaries around your facility’s activities and determine the areas that your management can control and over which it has influence. Your organization should consider items such as the following:

• the boundaries of environmental licenses, permits or approvals; • the extent of authority to determine how the environmental policy is implemented;

and • the extent of authority to allocate appropriate resources.

For initial development of its EMS, your organization may find that it is most effective to limit the scope of your EMS to any activities that occur within the facility’s physical property limits or that occur on adjacent property, as a direct result of your operations (for example, wastewater discharges or storm water run-off). At a later time you might wish to expand the scope to include such things as:

• transportation to and from your facility; • post consumer disposal, and other life cycle considerations; and • purchasing of resources.

Temporary activities, such as construction sites, should be covered by the EMS if the organization has management control over them. An example scope is provided below. Scope of ABC Company’s EMS The ABC Company includes three ship repair facilities located in California, Louisiana, and Virginia. The ABC Company is committed to improving environmental performance through the use of innovative techniques such as EMS. We will implement EMS in a phased approach, one facility at a time. Therefore, the ABC Company EMS presently covers only the Baton Rouge, Louisiana facility. This EMS includes all operations occurring on that facility’s property that support ship repair. In addition to this primary function, all on-site support operations are included in the scope of the EMS (for example, equipment maintenance, ship transport and storage, ship yard maintenance, administrative functions, and contractors working on our property). The EMS also addresses emissions and discharges regulated through environmental permits and other legal requirements. However, the EMS includes only those environmental aspects over which we have control or influence. The EMS addresses waste disposal, even though we are not be the final disposal facility for our waste. Through research and periodic audits of our waste transport and disposal contractors, we will influence the safe disposition of our wastes to the greatest degree possible to support environmental protection and risk reduction goals associated with the EMS.



Tips on Gap Analysis One important component of laying the groundwork for an EMS is conducting an initial review or “gap analysis” to evaluate your current program and specific needs. Although the gap analysis is very important, it can be counter-productive if you only focus on what it is missing. It is also important to recognize what your organization is already doing and to evaluate ways to improve and build on existing programs and activities. Some organizations may find that they already perform many of the suggested activities. This is good; there is no need to rebuild a program from scratch. Looking outside the environmental arena can provide inspiration. An area such as a quality management system may not be strictly environmental, but may help with your EMS. If an activity you already perform helps you manage important facility activities, it can probably help in environmental management as well. A gap analysis is designed to answer the following questions:

• How well are the organization and its environmental programs performing? • Has the organization defined the environmental goals it hopes to achieve? • What are the gaps between existing programs and the elements and criteria for an EMS? • What existing programs and activities can serve as the best foundation for improved

environmental performance? Building on existing programs becomes even more important when organizations are faced with diminishing resources and are being asked to "do more with less." Through careful analysis, organizations will probably find ways to address some EMS elements at little or no cost. For example, developing a policy statement on environmental protection does not require large investments in personnel or equipment, yet it can carry organization-wide visibility and impact. Ultimately, organizations that are able to invest in the implementation of EMS elements are likely to realize a high return on that investment through an improved "risk profile" at their facilities; this can lower costs associated with regulatory compliance, health and safety, incident response, and the cleanup of contaminated sites. Non-monetary benefits, such as improved public opinion and employee satisfaction, can also be achieved. Tool 1-1 is a Gap Analysis Tool/Self-assessment Checklist that can be used to assess current programs and specific needs of a facility.



TOOLS



Tool 1-1: Gap Analysis Tool/Self-Assessment Checklist Facility Name: Date: Assessor(s):

EMS Requirement Yes No NA Findings/Remarks Closed

Module 2: Structure & Responsibility Facility has defined the roles, responsibilities, and authorities to facilitate an effective EMS.

Facility management has appointed an EMR with defined roles and responsibilities to implement the EMS.

Facility EMR reports on the performance of the EMS to top management for review and continuous improvement.

Module 3: Environmental Policy Top management has defined the facility’s environmental policy.

Policy is specific to facility and is appropriate to the nature, scale and environmental impacts of its activities, products or services.

Policy includes a commitment to continuous improvement in environmental performance and the prevention of pollution.

Policy includes a commitment to sharing information on EMS performance with the community.

Notes: NA Not applicable CFT Cross functional team Closed Indicates completion SEA Significant environmental aspect EMS Environmental Management System EP&R Emergency Preparedness and Response EMR Environmental Management Representative CAPAN Corrective and Preventive Action Notice



EMS Requirement Yes No NA Findings/Remarks

Policy includes a commitment to comply with relevant environmental legislation and regulations.

Policy includes a commitment to meeting other requirements to which the organization subscribes.

Policy provides the framework for setting and reviewing environmental objectives and targets.

Policy is implemented and maintained. Policy is communicated to all employees. Policy is made available to the public. Module 4: Legal & Other Requirements Facility has a procedure to identify and have access to legal and other requirements.

Facility maintains access to all current federal, state, and local regulations and ordinances by either contacting the appropriate authorities or subscribing to a regulatory update service.

Module 5: Environmental Aspects Facility has established and maintains a procedure to identify the environmental aspects that it can control or over which it can be expected to have an influence, in order to determine those that have or can have significant impacts.

Facility has considered in its SEA determination, the aspects associated with on-site contractor activities.

SEAs form the basis for establishing process and management controls, environmental improvement programs, and SEAs for further investigation and study.



EMS Requirement Yes No NA Findings/Remarks Module 6: Objectives and Targets Facility has considered technological options, financial, operational, and business requirements in establishing its objectives and targets.

Facility has considering legal and other requirements in establishing objectives and targets.

Facility has considered the views of interested parties in establishing objectives and targets.

Facility objectives and targets are consistent with environmental policy and its commitment to prevention of pollution.

Module 7: Environmental Management Programs (EMPs)

Facility has established and maintained EMPs for achieving its objectives and targets.

New activities, products or services are reviewed for potential EMPs, plans and controls.

Facility has defined roles and responsibilities for environmental review of new projects.

Project originator reviews and characterizes the environmental and energy aspects of a new project.

Module 8: Training, Awareness & Competence

The organization has performed a comprehensive environmental training needs analysis.

Personnel whose work may create a significant impact, or is associated with a SEA, have received appropriate training.



EMS Requirement Yes No NA Findings/Remarks Facility has a procedure to make its employees aware of the importance of conformance with policy and procedures, the significant impacts associated with their work, and their roles and responsibilities as they pertain to the environmental policy.

Facility has a procedure to make its employees aware of: requirements of the EMS, the potential consequences of departure from operating procedures, and emergency preparedness and response.

Facility personnel performing tasks that can cause significant environmental impact are competent on the basis of education, training and/or experience.

Module 9: Communication Facility has a procedure for internal communication between the various levels and functions of the organization.

Internal communications procedures are used to facilitate implementation of regulatory, company policy and other requirements.

Facility has a procedure to log external communications and record the responses to external communications that concern environmental issues.

EMR or designee responds to inquiries from the community and regulatory agencies.

A designated person (for example, an Employee Relations Manager or Corporate Communications Officer), in consultation with the EMR, is responsible for responding to media communications.



EMS Requirement Yes No NA Findings/Remarks Where the external communication relates to an environmental incident, appropriate emergency response procedures are identified (see Module 13) and followed.

Module 10: EMS Documentation Facility has information in paper or electronic form to describe the core elements of the EMS and their interactions.

Facility has information in paper or electronic form to provide direction to related documentation.

Module 11: Document Control Facility has a procedure for controlling all documents required by the EMS.

Authorized personnel review documents and forms for adequacy before use or release.

The EMR or designee maintains a master list of documents and records.

Relevant documents are available at the locations where they are needed.

Obsolete documents are promptly removed from all points of use or otherwise assured against unintended use.

Obsolete documents retained for legal or preservation purposes are properly identified.

Facility has a procedure for defining responsibility concerning the creation and modification of documents.

Documentation is legible, dated and readily identifiable, maintained in an orderly manner, and retained for a specified period.



EMS Requirement Yes No NA Findings/Remarks

Module 12: Operational Control Facility has identified operations associated with SEAs.

Facility has planned maintenance activities in order to ensure that they are carried out under specified conditions.

Operations associated with SEAs have documented procedures to cover situations where their absence could lead to deviations from the policy, objectives and/or targets.

Procedures stipulate operating conditions. Facility has a procedure related to the identifiable SEAs of goods and services provided by contractors and vendors and communicates procedures and requirements to suppliers and contractors.

Facility or initiating activity communicates relevant facility-specific environmental procedures, work practices, and requirements to affected contractors prior to the commencement of requested work.

Facility has a procedure for the prevention of pollution and waste minimization.

Module 13: Emergency Preparedness & Response (EP&R)

Potential environmental incidents and emergencies likely to occur at the facility have been identified by the cross functional team.

Methods for preventing, mitigating and responding to potential releases that require emergency response have been established and maintained at the facility and involve the appropriate response personnel.



EMS Requirement Yes No NA Findings/Remarks Roles and responsibilities for communications within the facility and for obtaining outside support services (e.g., police, fire) have been established and are maintained at the facility.

The EP&R procedures at the facility are reviewed and revised on an annual basis or as necessary by the CFT.

EP&R methods and communications are tested on an annual basis or as necessary.

The facility emergency response leader records information necessary to determine corrective and preventive actions and any improvements to existing procedures that may be needed.

Module 14: Monitoring and Measurement Facility has documented procedures for monitoring and measuring key characteristics of operations associated with SEAs.

Facility has established metrics to track performance, relevant operational controls, and conformance with objectives and targets.

Monitoring and measuring equipment is calibrated and maintained as evidenced by appropriate records.

Facility has documented procedures for periodically evaluating compliance with relevant environmental legislation and regulations.

EMR is responsible for planning, scheduling and implementing internal environmental regulatory compliance assessments, including the identification of required resources.



EMS Requirement Yes No NA Findings/Remarks The assessment team records audit information and issues a Corrective and Preventive Action Notice (CAPAN) when appropriate. Upon completion of corrective and/or preventative actions, the responsible staff person furnishes the EMR or designee with a signed or acknowledged CAPAN (see Module 15).

Area/department/process managers and supervisors ensure that control and improvement plans are established, implemented, and monitored.

Module 15: Nonconformance and Corrective and Preventive Action

Facility has a procedure for nonconformance and corrective and preventive actions defining responsibility and authority for investigating and mitigating environmental impacts.

Each activity within the facility is responsible for identifying specific techniques to: identify the root cause(s); take appropriate corrective or preventive action; and verify effectiveness and prevent recurrence where possible.

Facility records and makes changes in documented procedures resulting from corrective and preventive actions.

Module 16: Records Facility has a procedure to identify, maintain, and dispose of environmental records.

Each activity responsible for maintaining a record has the responsibility for establishing the method for filing and indexing the records for accessibility.

The responsible activity is the generator of the record.



EMS Requirement Yes No NA Findings/Remarks Facility records procedure is consistent with corporate record retention procedures.

Module 17: EMS Audits Facility has a program and procedure for periodic EMS audits.

The EMR or designee is responsible for planning, scheduling and implementing internal EMS audits.

An EMS audit team will be formed whose membership has no responsibility within the activity to be audited.

An EMS audit schedule will be developed for each activity to be audited. Audit frequency is determined on priority basis that accounts for previous audit results and the relative importance of the activity, and is not be less than once per year for each activity.

The EMS audit team has established a checklist of questions relating to the EMS. These questions are reviewed and amended as necessary based on audit findings and other factors.

During the audit, the EMS audit team records audit observations, indicating items checked, individuals interviewed, any concerns identified and any corrective or preventive actions completed during the audit.

The audit team documents its findings using an audit findings form.

The area representatives address the corrective and preventive action sections within the specified time limit and return the information to audit team and EMR.

The EMR notifies facility management of potential regulatory non-compliance.



EMS Requirement Yes No NA Findings/Remarks The audit team reviews corrective actions and confirms proper implementation either by a subsequent check or during the next audit.

The EMR or designee submits audit summaries for management review.

Module 18: Management Review Management reviews are conducted by the EMR and the management committee.

The EMR schedules these reviews at least once each year.

The management review addresses the possible need for changes to policy, objectives, and other elements of the EMS, in light of EMS audit results, changing circumstances, and the commitment to continuous improvement.

Notes: NA Not applicable CFT Cross functional team Closed Indicates completion SEA Significant environmental aspect EMS Environmental Management System EP&R Emergency Preparedness and Response EMR Environmental Management Representative CAPAN Corrective and Preventive Action Notice



Tool 1-2: Sample Worksheet for Persons Responsible for EMS Development

Roles

Individual(s) Responsible

% of Time Designated

Budget

EMR with responsibility for implementing the EMS (in small businesses, this could be the owner).

EMS Coordinator

EMS Team Participants (CFT)

Conduct gap analysis.

Identify and determine significance of environmental aspects.

Identify and determine applicability of legal and other requirements

Address competency-based training.

Address operational controls.

Implement emergency preparedness and response.

Monitoring and measurement of “key characteristics” of operations and activities that can have significant environmental impacts (i.e., the “significant environmental aspects”).

Periodically evaluate environmental compliance.

Handle and investigate non-conformance with the EMS.

Address records management.

Implement internal EMS audits.

Contact Person: Date Completed:



EXAMPLES

Example 1-1: Schedule for EMS Implementation


EMS Policy and Planning

EMS POLICY AND PLANNING

The Policy and Planning section includes 6 of the 18 modules.

Ø Module 2: Structure and Responsibility Ø Module 3: Environmental Policy Ø Module 4: Legal and Other Requirements Ø Module 5: Environmental Aspects Ø Module 6: Objectives and Targets Ø Module 7: Environmental Management Programs


EMS Policy and Planning Module 2 - 1

Module 2: Structure and Responsibility Guidance ..................................................................................................................................... 2-2

Figure 2-1: EMS Expertise and Roles Across Facility Function................................... 2-4 Tools and Forms ......................................................................................................................... 2-7

Tool 2-1: Structure and Responsibility Worksheet ........................................................ 2-7 Tool 2-2: Sample EMS Responsibilities Descriptions ................................................... 2-8 Form 2-2: EMS Responsibilities .................................................................................... 2-9

Examples................................................................................................................................... 2-10

Example 2-1: Responsibility Matrix ............................................................................ 2-10 Example 2-2: Organization Chart ................................................................................ 2-12



GUIDANCE

One of the first tasks of EMS planning is to establish the roles and responsibilities associated with EMS leadership and technical support. The previous module (Module 1) provides guidance and a worksheet for establishing these during the EMS implementation planning and budgeting process. This module addresses the closely related task of creating an ongoing structure that ensures the organization is equipped with sufficient personnel and other resources to meet its objectives and targets and to ensure compliance with legal requirements. The organization should also provide appropriate incentives for personnel to meet the EMS requirements. Assigning Responsible Persons It is important to designate, as soon as possible, the Environmental Management Representative (EMR), the EMS Coordinator, and the Cross Functional Team (CFT), all of whom will play a role in developing and promoting your EMS. If you have a very small facility, these may all be the same person. However, it is still important to designate who will be responsible for various activities.

• The Environmental Management Representative (EMR) is the member of the organization’s top management committee who is responsible for the functioning of the EMS. An EMR ensures that all tasks relating to the EMS are identified and completed in a timely manner. An EMR is responsible for reporting periodically to the top facility management committee on the progress and results of the EMS.

• The EMS Coordinator is the member of the organization whose responsibility is to

identify, assign, schedule, provide the necessary support for, and ensure completion of all tasks relating to the EMS. The coordinator works closely with the EMR and with the CFT. The EMS Coordinator is also responsible for maintaining the EMS manual, under the leadership of the EMR. It is possible for the functions of EMS coordinator and EMR to be performed by the same person.

• The Cross Functional Team (CFT) includes members of the organization who are

responsible for representing their area or department in several facets of the EMS, e.g., identifying environmental aspects, determining significant environmental aspects, setting objectives and targets, implementing environmental management programs, reviewing and tracking EMS internal audits results, and serving as an information resource. The CFT meets to discuss the EMS on a regular basis.



In assigning EMS responsibilities and creating your EMS team, it is crucial that you explore the range of job functions and skills that make-up your organization, and select from that broad spectrum of people who will dedicate themselves to the EMS tasks. In order to do that, it is necessary to consider how your organization is structured. Once you consider the structure of your organization, you can create a list of job functions and skills that make up your organization to support your EMS planning and implementation efforts. Figure 2-1: EMS Expertise and Roles Across Facility Functions presents a sample list of facility functions and suggests the likely contribution of each to the EMS. Tool 2-2 and Form 2-2 can be used to deve lop and track responsibilities for you EMS team. The responsibility matrix presented in Example 2-1: Responsibility Matrix list EMS activities and how they might apply to the various facility personnel that perform these and other facility functions. An organization chart that presents the staffing of your EMS should be included in your EMS manual. If you do not have such an organization chart already in place for your facility, Example 2-2: Organization Chart presents an example.

Shipbuilding and Ship Repair Industry - EMS Implementation Guide Revision 3.0 (November 2001)


Figure 2-1: EMS Expertise and Roles Across Facility Functions

Facility Function Expertise Brought to Project Team How They Can Help (Possible Roles) Top Management • Capability for ensuring continual improvement Communicate importance of EMS throughout

organization; provide necessary resources; track and review EMS performance.

Environmental • System for complying with environmental regulations • Management of environmental records

Provide an organizational and functional role in establishing and maintaining the EMS.

Production • Management of environmental aspects of production Help identify significant environmental aspects; provide input to objectives and targets; participate in environmental management programs; serve as trainers and internal auditors; help carry-out corrective and preventive action.

Maintenance • Management of environmental aspects of equipment maintenance

Implement preventive maintenance program for key equipment; support identification of environmental aspects.

Facilities Engineering • Management of environmental aspects of new construction and installation/ modification of equipment

Consider environmental impacts of new or modified products and processes; identify pollution prevention opportunities.

Human Resources • Knowledge of training programs (including environmental) • Experience with the inclusion of employee incentives in

performance measurement system

Define competency requirements and job descriptions for various EMS roles; train temporary workers and contractors; maintain training records; integrate environmental management into reward, discipline, and appraisal systems.

Purchasing • Knowledge of procurement system (including screening of suppliers, material composition of components)

• Knowledge of supply chain efforts

Develop and implement controls for chemical / other material purchases and for communicating requirements to contractors and suppliers.



Facility Function Expertise Brought to Project Team How They Can Help (Possible Roles) Accounting/Finance • Systems for tracking costs of operations and evaluating

cost/benefits for new projects Track data on environmental-related costs (such as resource, material, and energy costs, waste disposal costs, etc.); prepare budgets for environmental management program(s); evaluate economic feasibility of environmental projects.

Operations Personnel/All Employees

• Thorough knowledge of processes and operations Provide first-hand knowledge of environmental aspects of their operations; support training for new employees.

Quality • Quality management system, including document control procedures

Support document control, records management and employee training efforts; support integration of environmental and quality management systems.

Shipping, Receiving, Transportation, Logistics

• Management of environmental aspects of shipping, receiving, and transportation

Help identify aspects; provide input to objectives and targets; participate in environmental management programs; serve as trainers and internal auditors; help carry-out corrective and preventive action.

Sales/Marketing • Knowledge of environment-related commitments to customers

Assist communications with external stakeholders.

Public Relations • System for communicating with public on environmental issues

Assist communications with external stakeholders.

Product or Process Design

• System for examining environmental aspects of new designs

Participate in product-related objectives, targets, and EMPs.

Storage/Inventory • Management of environmental aspects of raw material and product storage and in-facility transportation

Help identify aspects; provide input to objectives and targets; participate in environmental management programs; serve as trainers and internal auditors; help carry-out corrective and preventive action.



EMS Implementation Training The efforts of the EMS Team (the EMR, the EMS Coordinator, and the CFT) will be crucial to effective EMS implementation and the long-term success of the facility’s EMS. In-depth training on how to plan and implement an EMS and integrate it with existing facility operations is required so that the EMS Team conducts itself effectively and efficiently. Usua lly this implementation training precedes other activities such as drafting an environmental policy, reviewing environmental compliance requirements, identifying environmental aspects, and other planning and implementation tasks.



TOOLS

Tool 2-1: Structure and Responsibility Worksheet

How do we define roles, responsibilities and authorities for environmental management now? Is this process effective?

Who is / should be our Environmental Management Representative? Does this individual have the necessary authority to carry out the responsibilities of this job?

Are our key roles and responsibilities for environmental management documented in some manner? If so, how (e.g., job descriptions, organizational charts, responsibility matrix, etc.)?

How are EMS roles and responsibilities communicated within our organization?

How do we ensure that adequate resources have been allocated for environmental management? How is this process integrated with our overall budgeting process? How are environmental expenditures tracked?

How will we keep this information up-to-date?

Our next step on structure and responsibility is to …



Tool 2-2: Sample EMS Responsibilities Descriptions [Your Facility’s Name] needs to establish an Environmental Management System Team (EMS) Team. Therefore, the following members of the EMS team have been identified: an Environmental Management Representative (EMR), an EMS Coordinator, and a Cross Functional Team (CFT). Responsibilities for each are as follows:

• Environmental Management Representative. The EMR is the member of [Your Facility’s Name] top plant management group responsible for the functioning of the EMS. It is his or her job to ensure that all tasks relating to the EMS are identified and completed in a timely manner. He or she is also responsible for reporting periodically to the top plant management group on the progress and results of the EMS.

• EMS Coordinator. The EMS Coordinator’s responsibility is to identify, assign, schedule,

provide the necessary support for, and ensure completion of all tasks relating to the EMS. The EMS Coordinator works closely with the EMR representative and with the CFT. The EMS Coordinator is also responsible for maintaining this EMS manual, under the leadership of the EMR. The same person may fill the functions of EMS Coordinator and EMR.

• Cross Functional Team. The CFT is made up of members of organization who are

responsible for representing their area or department in several facets of the EMS, e.g. establishing environmental aspects, determining significant aspects, setting objectives and targets, implementing environmental management programs, reviewing and tracking EMS internal audits results, and serving as an information resource. The CFT meets to discuss the EMS on a regular basis.

Records The EMS Coordinator maintains an updated list of the EMR, the EMS coordinator, and CFT members using Form 2-2: EMS Responsibilities. A letter issued by top management that assigns the current EMR and his or her responsibilities should be maintained as part of this facility’s EMS manual and can be attached to the appropriate version of Form 2-2.



Form 2-2: EMS Responsibilities The following table lists [Your Facility’s Name] EMR, EMS Coordinator, and CFT:

EMS Function Name Regular Position Environmental Management Representative (EMR)

EMS Coordinator

Cross Functional Team (CFT)



EXAMPLES

Example 2-1: Responsibility Matrix

Responsibility

Top

Managers (Plant Mgr./

President)

Environmental

Manager (EMR and EMS

Coor.)

Production Supervisors

Maintenance Staff

Facility Engineers

Human

Resource Manager

Purchasing Staff

Accounting/ Finance Staff

Operations Personnel

Communicate importance of environmental management

L S S S

Coordinate auditing efforts L S S

Track/analyze new regulations (and maintain library)

L

Obtain permits and develop compliance plans

L S

Prepare reports required by regulations

L

Coordinate communications with interested parties (env)

L S

Train employees S L S

Legend: L=Lead Role S=Supporting



Responsibility

Top

Managers (Plant Mgr./

President)

Environmental

Manager (EMR and EMS

Coor.)

Production Supervisors

Maintenance Staff

Facility Engineers

Human

Resource Manager

Purchasing Staff

Accounting/ Finance Staff

Operations Personnel

Integrate environmental into recruiting practices

S L

Integrate environmental into performance appraisal process

S L

Communicate with contractors on environmental expectations

L

Comply with applicable regulatory requirements

L L S S S S S S S

Conform with organization's EMS requirements

L L S S S S S S S

Maintain equipment / tools to control environmental impact

L S

Monitor key processes S L S Coordinate emergency response efforts

L S

Identify environmental aspects of products, activities, or services

S L S S S S S S

Establish environmental objectives and targets

L S S

Develop budget for environmental management

S L

Maintain training records L

Maintain EMS records (non-training)

L

Coordinate EMS document control efforts

L S



ManufacturingManager


[Facility Name]Organization Chart

President

AdministrativeAssistant


Quality ControlManager


Engineering Manager

Engineering Manager

Plant Controller

Plant Controller

Mat. Plng/Logistics Mgr.Mat. Plng/

Logistics Mgr.Mfg. Planning

Mgr.

Mfg. PlanningMgr.

Paint AreaManager

Paint AreaManager

Assembly AreaManager


EMSCoordinator

EMSCoordinator

Cross-Functional

Team

Cross-Functional

Team

Director EH&S(EMR)

Director EH&S(EMR)

Human ResourcesManager


ProgramManager

ProgramManager

EMS InternalAudit Team




[Facility Name]Organization Chart

PresidentPresident





Engineering Manager

Engineering Manager

Plant Controller

Plant Controller

Mat. Plng/Logistics Mgr.Mat. Plng/

Logistics Mgr.Mfg. Planning

Mgr.

Mfg. PlanningMgr.

Paint AreaManager

Paint AreaManager



EMSCoordinator

EMSCoordinator

Cross-Functional

Team

Cross-Functional

Team

Director EH&S(EMR)

Director EH&S(EMR)



ProgramManager

ProgramManager



Example 2-2: Organization Chart



Module 3: Environmental Policy Guidance ...........................................................................................................................................3-2 Tools ..................................................................................................................................................3-4

Tool 3-1: Environmental Policy Worksheet .........................................................................3-4 Examples...........................................................................................................................................3-5

Example 3-1: Generalized Environmental Policy Template................................................3-5



GUIDANCE

Once your shipyard has its EMS Team (the EMR, EMS Coordinator, and CFT) trained and in place, the next step is to create a working draft of your shipyard’s environmental policy. As your EMS Team moves forward, the policy should serve as the foundation for your EMS and provide a unifying vision of environmental principles that will guide the actions of employees and management. This policy statement should provide the framework for setting environmental objectives and targets. The EMS policy should set out the facility’s overall commitment to a cleaner environment. Example commitments that should be stated in your EMS policy are those presented by EPA’s Performance Track program:

• Compliance with legal requirements and any voluntary commitments; • Pollution prevention; • Continuous improvement in environmental performance, including areas not subject to

regulations; and

• Sharing information about environmental performance and the operation of your EMS with the community.

Points to Consider in Developing Your Policy:

• Your organization probably has some type of environmental policy now, even if it’s not written down. For example, your organization probably is committed to complying with the law and avoiding major environmental problems, at a minimum. Document existing commitments and goals as a starting point.

• The environmental policy should relate to your activities, products and services.

• The environmental policy can be a stand-alone document or it can be integrated with your health & safety, quality, or other organizational policies.

• The environmental policy should be explicit enough to be audited. If you choose to use phrases such as “We are committed to excellence and leadership in protecting the environment”, consider how you would demonstrate that this commitment is being met.

• Keep your policy simple and understandable. Ask yourself: what are we trying to achieve and how can we best communicate this to the rest of the organization? Test simplicity and clarity by asking: “Could our employees describe the intent of our policy in twenty words or less?”



Points to Consider in Developing Your Policy: (cont.) • Before finalizing your environmental policy, consider the results of establishing your

facility’s objectives and targets (see Module 6) so that it reflects consistency with those. • Make sure top management commits to the environmental policy statement. The company

president should sign and date it. The final environmental policy statement should be posted or distributed to employees and other interested parties.

• Make sure that your employees receive and understand the policy. Options for communicating your policy internally include posting it around work sites (e.g., in lunchrooms), using paycheck stuffers, incorporating the policy into training classes and materials, and referring to the policy at staff or all-hands meetings. Test awareness and understanding from time to time by asking employees if they know there is an environmental policy, what the policy means to them, and how it affects their work.

• The policy also should be communicated externally. Some options for external communications include placing the policy on business cards, in newspaper advertisements, in annual reports, and on a company web-site (if you have one). You might choose to communicate the policy proactively or in response to external requests (or both). This decision should be factored into your overall strategy for external communication (see later discussion in Module 9).

Tool 3-1 is a worksheet of questions for you to consider in developing your EMS policy. A sample policy that could be customized to fit your needs is provided as Example 3-1.



TOOLS Tool 3-1: Environmental Policy Worksheet

Do we have an existing environmental policy? If yes, how was the policy developed? When was the policy last reviewed?

Does the policy reflect key commitments (for example, compliance, prevention of pollution and continual improvement)? What other commitments does or should our policy contain?

How does our policy take into account the environmental attributes of our activities, products, and services?

How would we demonstrate conformance to our policy?

How is the policy communicated to our employees? Do our employees understand the critical elements of our policy? How do we know?

What feedback have we received on the policy (from employees, contractors, or other interested parties)? What happens when we receive feedback on the policy?

How do we make our policy available to external parties? Is this process effective?

Our next step on environmental policy is to …



EXAMPLES

Example 3-1: Generalized Environmental Policy Template

[YOUR FACILITY’S NAME] ENVIRONMENTAL POLICY

[This is a sample policy. Please adapt as appropriate for your company.] [Your Facility’s Name] is committed to managing environmental matters as an integral part of our business planning and decisions, including design, procurement, production, facilities management, and product support. Manufacturing efficiency, and environmental protection are, and must continue to be, compatible goals. To obtain these goals, we will adhere to the following principles: Compliance with legal requirements and voluntary commitments [Your Facility’s Name] shall comply with applicable laws, regulations, and voluntary commitments, and will implement programs and procedures that ensure this compliance. Sustained compliance with legal and company environmental standards will be a key consideration in facility training and incentive programs, and in periodic performance reviews of all employees. [Your Facility’s Name] shall promote a workplace in which all employees are properly trained to comply with applicable laws, regulations, and procedures, to meet environmental program goals, and to take personal responsibility for implementation of the program. Pollution Prevention [Your Facility’s Name] shall strive to be leader in the shipbuilding and ship repair industry in improving environmental quality, by minimizing waste and emissions, reusing and recycling, reducing the use of natural resources, and promoting pollution prevention efforts throughout the facility. [Your Facility’s Name] shall employ management systems and procedures specifically designed to prevent activities and / or conditions that pose a threat to human health, safety, or the environment. We will look for ways to minimize risk and protect our employees and the communities in which we operate by adopting pollution prevention practices including employing clean technology and operating procedures, as well as being prepared for emergencies.



[Your Facility’s Name] shall strive to minimize releases to the air, land, or water through use of cleaner technologies and the safer use of chemicals. We shall minimize the amount and toxicity of waste generated and shall ensure the safe treatment and disposal of waste. [Your Facility’s Name] shall manage natural resources, such as water, energy, land, habitats, and scenic values, in an environmentally sensitive manner. Sharing Information with the Community [Your Facility’s Name] shall share information on our commitment to environmental performance improvement to our employees, vendors, customers, and external stakeholders. We will solicit their input in meeting our environmental goals and in turn will offer assistance to meet their goals. Continuous Improvement We shall measure our progress as best we can. We will review and report on our progress at least on an annual basis. We will continuously seek opportunities to improve our adherence to these principles and to improving our environmental performance, and we will periodically report progress to our stakeholders. Management at all levels of [Your Facility’s Name] is responsible for ensuring that this policy is communicated and adhered to by all employees and subcontractors, and that it is made available to interested members of the public. {Signature} President Date



Module 4: Legal And Other Requirements Guidance ..................................................................................................................................... 4-2 Tools and Forms ......................................................................................................................... 4-4

Tool 4-1: Legal and Other Requirements Worksheet ..................................................... 4-4 Tool 4-2: Sample Worksheet for Identifying Legal Requirements ................................ 4-5 Tool 4-3: Sample Procedure for Identification of Legal and Other Requirements ........ 4-6 Form 4-3: Sample Form for Legal and Other Requirements .......................................... 4-7 Tool 4-4: Information Resources for Legal Requirements ............................................. 4-8

Examples..................................................................................................................................... 4-9

Example 4-1: Commonly Applicable Federal Environmental Laws in the U.S. ........... 4-9 Example 4-2: Shipbuilding and Ship Repair Industry Operations: List of Applicable Legal and Other Requirements ...................................................................................... 4-10



GUIDANCE The Legal Framework for your EMS—Familiar Territory Most likely you already have some form of EMS and its most mature element is probably its attention to compliance with laws and regulations that relate to shipbuilding and ship repair facilities. Since you probably know most of what you need to about your legal requirements and how they affect what you do, let’s begin on this familiar territory and build from there. Compliance with legal requirements is one of the main pillars upon which your environmental policy should be based since the potential costs of non-compliance (possible damage to the environment, revenue loss and impact on public image, for example) can be very high. An effective EMS will build on what you already have and should include processes to:

• identify and communicate applicable legal and other requirements; and • ensure that these requirements are factored into the organization’s management efforts.

New or revised legal requirements might require modification of your environmental objectives or other EMS elements. By anticipating new requirements and making changes to your operations, you might avoid some future compliance obligations and their costs. Getting Started Your EMS should include a procedure for identifying, having access to, and analyzing applicable legal and other requirements.

Legal requirements include, but are not limited to: • Federal requirements • State and local requirements • Permit conditions

Other requirements might include:

• Industry codes of practice • Pledges or commitments made voluntarily by your company



Identifying applicable regulations, interpreting them, and determining their impacts on your operations can be a time-consuming task. Fortunately, there are many sources for obtaining information about applicable laws or regulations. These sources include:

• commercial services (with updates offered online, on CD-ROM, or in paper form); • regulatory agencies (federal, state and local); • trade groups / associations; • the Internet (see EPA web site at http://www.epa.gov); • public libraries; • seminars and courses; • newsletters / magazines; • consultants and attorneys; and • customers, vendors and other companies.

Contact information for resources that can aid in tracking environmental laws and regulations is presented in Tool 4-4. An example list of commonly applicable federal environmental laws in the U.S. is presented in Example 4-1. However, it is not a complete list of all environmental laws; it is an example list of commonly applicable laws. See Example 4-2 for an example list of federal environmental laws applicable to the shipbuilding and ship repair industry. Again, this is not complete but provides a starting point for considering your own legal and other requirements. Once the applicable environmental requirements have been identified and adopted into the appropriate operations, communicate these requirements (and methods for complying with them) to employees, on-site contractors and others, as needed. Communicating “other requirements” (as well as their influence on the organization) is an important but often overlooked step. Keep in mind that different people may have different information needs; for example, operational personnel may need to understand waste consolidation and accumulation requirements for different waste streams generated in their areas, while the environmental manager will need to know waste analysis, labeling, and transportation requirements for hazardous waste. As with many EMS elements, this is not a “one time” activity. Because legal and other requirements change over time, your procedure should include a means to ensure that you are working with up-to-date information.



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

Do we have an existing process for identifying applicable legal and other requirements? If yes, does that process need to be revised? In what way?

Who needs to be involved in this process within our organization? What should their responsibilities be?

What sources of information do we use to identify applicable legal and other requirements? Are these sources adequate and effective? How often do we review these sources for possible changes?

How do we ensure that we have access to legal and other requirements? (List any methods used, such as on-site library, use of web sites, commercial services, etc.)

How do we communicate information on legal and other requirements to people within the organization who need such information?

Who is responsible for analyzing new or modified legal requirements to determine how we might be affected?

How will we keep information on legal and other requirements up-to-date?

Our next step on legal and other requirements is to …



Tool 4-2: Sample Worksheet for Identifying Legal Requirements

MEDIA OR REGULATORY

ACT

PLANS/ PERMITS

SOURCES/ DISCHARGES

KNOWLEDGE OF REGULATIONS (Low, Med, High)

ASSOCIATED MANAGEMENT PROCEDURES

CAA

CWA NPDES (outfalls and/or stormwater)

RCRA Our Generator Status:

SDWA (UIC)

WETLANDS

FIFRA

EPCRA

CERCLA or State Cleanup

TSCA (PCBs)

UST

OTHERS (list as appropriate)



Tool 4-3: Sample Procedure for Identification of Legal and Other Requirements The following is a sample procedure for the identification of legal and other requirements that incorporates the principles presented in this Guide. Purpose [Your Facility’s Name] is committed to complying with all applicable environmental regulations. It also will strive to meet other commitments made in its environmental policy, such as commitments to community involvement, pollution prevention, and continuous improvement. This procedure describes how [Your Facility’s Name] identifies applicable legal and other requirements. Procedure 1. The Environmental Management Representative (EMR) is responsible for tracking

applicable environmental laws and regulations and evaluating their potential impact on the facility’s operations. He or she employs several techniques to track, identify, and evaluate applicable laws and regulations. These techniques include commercial databases, information from the trade association, direct communication with national and state regulatory agencies, and periodic refresher training on environmental laws.

2. As necessary, the EMR may call upon off-site resources such as consultants or attorneys. 3. The EMR compiles and maintains updated copies of applicable environmental laws and

regulations. 4. The EMR, working with the EMS Coordinator and cross functional team (CFT),

correlates these regulations to the business activities and environmental aspects associated with them using Form 4-3.

Frequency Ongoing. Records Form 4-3, Legal and Other Requirements, is maintained by the EMS Coordinator. The EMR maintains copies of the applicable regulations.



Form 4-3: Shipbuilding and Repair Industry Operations: Sample Form for Legal and Other Requirements

Identification

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See Example 4-2 for an example of how to fill out this form.



Tool 4-4: Information Resources for Legal Requirements This tool describes a variety of commercial and non-commercial sources of information on federal and state environmental laws and regulations. This list is not intended to be comprehensive. Appearance on this list should not be construed as an endorsement by EPA of any commercial products or services listed below.

Source Description EPA Web Site Provides a variety of information of environmental laws and

regulations as well as tools and compliance guidance. (http://www.epa.gov).

EPA RCRA/Superfund/ EPCRA Hotline (1-800-424-9346 or 703-412-9810)

Questions regarding pollution prevention, source reduction, waste management, and disposal may be directed to this hotline. It is staffed by Booz Allen & Hamilton Inc., under contract to EPA. The Hotline answers factual questions about EPA regulations and programs under RCRA, Superfund, and EPCRA.

EPA Small Business Ombudsman (1-800-368-5888)

Regulatory explanations and guidance, research, case studies, contacts for additional information. Variety of hotlines available for particular statutes (such as RCRA). Internet access also available (http://www.epa.gov/sbo).

Small Business Assistance Programs (various states) and Other State Agencies

Guidance on regulations and compliance issues. Initially these focused on Clean Air Act requirements, but they are expanding into other environmental media.

U.S. Small Business Administration

Various services available to small businesses in the U.S. (http://www.sba.gov)

U.S. Government Printing Office (202-512-1800)

Federal Register published daily with all federal proposed and final rules. (Also available on line via GPO Access, search for GPO Access)

Trade and Professional Associations

• American Shipbuilding Association (202-544-8170)

• Shipbuilders Council of

America (703-351-6734)

Trade associations provide a variety of services related to environmental laws and regulations, including regulatory updates and training. American Shipbuilding Association is a national trade association that represents America's largest shipbuilders. (http://www.americanshipbuilding.com/) The Shipbuilders Council of America is a national trade association that represents many of the U.S. commercial shipbuilding and ship repair companies. (http://www.shipbuilders.org/)

Counterpoint Publishing (1-800-998-4515)

CD-ROM and Internet dial-up access to legal / regulatory information for federal government and all 50 states, updated daily.

Bureau of National Affairs (1-800-372-1033)

Information on environmental, health and safety laws, regulations and activities at international, national and state level. Paper and electronic access available.

Thompson Publishing Group (1-800-677-3789)

Manuals on a variety of federal and state environmental programs with monthly updates and newsletters.

Business & Legal Reports, Inc. (1-800-727-5257)

Access to federal and state regulations with monthly, updates on available on CD-ROM.

Aspen Law and Business (1-800-638-8437)

Publishes compliance manuals with regular update service for Resource Conservation and Recovery Act and the Clean Air Act.



EXAMPLES Example 4-1: Commonly Applicable Federal Environmental Laws in the U.S.

Clean Air Act (CAA) [40 CFR Parts 50-99]

• Title V air permits and/or follow the standards for hazardous air pollutants under the NESHAP

• state air permits

Establishes ambient and source emission standards and permit requirements for conventional and hazardous air pollutants.

Clean Water Act (CWA) [40 CFR Parts 100-145, 220-232, 410-471]

Establishes ambient and point source effluent standards and permit requirements for water pollutants, including sources that discharge directly to a water body or to a public sewer system. Also includes storm water management requirements.

Resource Conservation and Recovery Act (RCRA) [40 CFR Parts 240-299]

Establishes regulations and permit requirements for hazardous waste management. Also, creates standards for underground storage tanks that hold oil or hazardous substances.

Toxic Subs tances Control Act (TSCA) [40 CFR Parts 700-799]

Regulates the use, development, manufacture, distribution and disposal of chemicals. Certain chemicals [such as polychlorinated biphenyls (PCBs)] are subject to specific management standards.

Comprehensive Environmental Response, Compensation and Liability Act (CERCLA, also known as “Superfund”) [40 CFR Parts 300-311]

Establishes a program for cleaning up contaminated waste sites and establishes liability for clean-up costs. Also, provides reporting requirements for releases of hazardous substances.

Emergency Planning and Community Right-To-Know Act (EPCRA) [40 CFR Parts 350-374]

Establishes a program (also known as the “Toxic Release Inventory”) to inform the public about releases of hazardous and toxic chemicals. Reporting requirements apply to companies that use, process or store specific chemicals over specified quantities.

Hazardous Materials Transportation Act (HMTA) [49 CFR Parts 100-180]

Establishes standards for the safe transportation of hazardous materials.



Example 4-2: Shipbuilding and Ship Repair Industry Operations: List of Applicable Legal and Other Requirements

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Material Use Corporate Directive

Company Strategy, Planning, and Implementation

X X X X X X X X X

Air Emissions 40CFR Part 50

NAAQS National Primary and Secondary Air Quality Standards

X X X X X


Emission of Hazardous Air Pollutants

X X X X X

Air Emissions

40CFR Part 52

Emission of Hazardous Air Pollutants

X X X X X

Air Emissions

40CFR Part 60 40CFR 60.42c and 60.43c (Boiler emission standards for sulfur dioxide and particulate matter)

Verification of Emissions X X X X X

Air Emissions

40CFR Part 61 NESHAP RACM X X X X X X





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National Emissions Standards for Hazardous Air Pollutants for Source Categories

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Chemical Accident Prevention Provisions

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40CFR Part 72 Permits (Title V)

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County Ordinances

Air permits X X X X


Stratospheric Ozone Protection-CFC Containing Equipment Requirements

Air Emissions

40CFR Part 265 part AA, BB, and CC

RCRA Emission Requirements- Hazardous Waste Storage Tanks





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State Rules and Regulations

State Air Rules (i.e. air permits, point source control for stationary sources, malfunctioning of control equipment.)

X X X X X

Energy Use Corporate Directive

Company Strategy, Planning, and Implementatio n

X X X X X X X X X

Solid/Liquid Waste

State Rules and Regulations

Liquid and Solid Waste Management

X X X X X X

Solid/Liquid Waste

40CFR Part 261-265

Hazardous Waste Requirements

X X X X X X X

Solid/Liquid Waste

40CFR Part 268

RCRA Land Disposal Restrictions

Solid/Liquid Waste

40CFR Part 279

Standards for the Management of Used Oil

X X X

Solid/Liquid Waste

40CFR parts 265, 280 USTs X X

Solid/Liquid Waste

40CFR Part 300

Hazardous Ranking System (HRS) X X X X X X X X X





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40CFR part 302

Hazardous Substances and Reportable Quantities

X X X X X X X X

Solid/Liquid Waste

40CFR Part 355

Extremely Hazardous Substances (EHS)

X X X X X X X X

Solid/Liquid Waste

40CFR 370 & 372

Community Right to Know Requirements

Solid/Liquid Waste 40CFR 710

Toxic Substances Control Act (TSCA) Requirements

X X

Solid/Liquid Waste 40CFR 413

Electroplating Point Source Category

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Requirements

Solid/Liquid Waste CERCLA 103

Release Reporting Requirements of EPCRA (facility or vessel)

X X X X X X X X

Solid/Liquid Waste

Company Directive

Requirement for Waste Minimization Plan

X X X X X X X X X

Solid/Liquid Waste

City Ordinance Sewer Permit X X X X X X X X X





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NPDES State Permit

Permit to Discharge to Local Water Bodies

X X X X X X X X


40 CFR Part 121-125

NPDES 122-Permit to Discharge Stormwater to Local Water Bodies

X X X X X X X


40CFR Part 136

Guidelines Establishing Test Procedures for the Analysis of Pollutants


40CFR Part 316

Cooling Water Intakes or Discharges

X X X


40CFR parts 400-409

Effluent Guidelines and Standards

X X X X X X X X


40CFR Part 433

Metal Finishing Point Source (proposed job shop category)





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Discharge and Transfer of Oils or Hazardous Materials From Vessels and Port Facilities

X X X X X X X

Spills 40CFR 112

Oil Spill Prevention

X X X X

Emergency Planning & Community Right to Know

State Emergency Response Commission (SERC)

Notification to SERC of storage and use of extremely hazardous substances

X X X X X X X

Emergency Planning &Community Right to Know

Local Emergency Planning Committee (LEPC)

Identification of plant emergency coordinator to participat e in LEPC process

X

Emergency Planning and Community Right to Know

29CFR part 1910.1200 and 40CFR Part 370

MSDSs on Chemicals Required by OSHA

X X X X X X X X





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40CFR Part 372

Form R Toxic substances processed or used in excess quantities

X X X X X X X X X

Medical Waste

40CFR Part 259

Generation of Medical Waste for states of CT, NY, NJ, RI, and territory of Puerto Rico

X

Medical Waste

State Regulations

State Regulat ions on Generation of Medical Waste

X

PCBs 40CFR Part 761

PCB Regulations

X

Pesticides 40CFR part 171

Pesticide Regulations X

Pesticides 40CFR Part 165

Storage of Pesticide Materials

X

Property Transfers

Environmental Cleanup Responsibilities Act (ECRA)

Environmental Cleanup Responsibilities

X





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ees

All*

Property Transfers

State Regulations

Environmental Cleanup Responsibilities

Property Transfers CERCLIS

Information pertaining to sit e

X

All 16 USC 1401

Marine Protection Research and Sanctuaries Act

X X X X X X X X X

All Company Directive

Company Strategy, Planning, and Implementations

* All indicates applicability to all components of the facility.



Module 5: Environmental Aspects Guidance ..................................................................................................................................... 5-3 Figures......................................................................................................................................... 5-8

Figure 5-1: Link between Aspects and Impacts............................................................. 5-3 Tools and Forms ......................................................................................................................... 5-8

Tool 5-1: Some Techniques and Data Sources for Identifying and Evaluating Environmental Impacts .................................................................................................... 5-9 Tool 5-2: Sample Procedure for Identification of Environmental Aspects and Determination of Significant Aspects............................................................................ 5-10 Tool 5-3: Worksheet for Identifying Community Issues.............................................. 5-15 Tool 5-4: Worksheet for Identifying Natural Resources Use/Pollution Prevention Potential ......................................................................................................................... 5-15 Form 5-2: Identification and Significance Determination of Environmental Aspects and Setting Objectives and Targets................................................................................ 5-14

Examples................................................................................................................................... 5-16

Example 5-1: A List of Common Activities and Processes at Shipbuilding and Ship Repair Facilities .............................................................................................. 5-17 Example 5-2: Flow Diagram and Aspect Identification and Significance Determination Form for Drydock Painting.................................................................... 5-18 Example 5-3: Flow Diagram and Aspect Identification and Significance Determination Form for Small Parts Coating, Outdoor ................................................. 5-22 Example 5-4: Flow Diagram and Aspect Identification and Significance Determination Form for Gas Metal Arc Welding.......................................................... 5-26 Example 5-5: Flow Diagram and Aspect Identification and Significance Determination Form for Dry Abrasive Blasting ............................................................ 5-29 Example 5-6: Flow Diagram and Aspect Identification and Significance Determination Form for Burning and Cutting ............................................................... 5-32 Example 5-7: Flow Diagram and Aspect Identification and Significance Determination Form for Ultra High Pressure Water Jetting .......................................... 5-35 Example 5-8: Flow Diagram and Aspect Identification and Significance Determination Form for Metal Grinding ....................................................................... 5-38 Example 5-9: Flow Diagram and Aspect Identification and Significance Determination Form for Material Transport, Crane ...................................................... 5-41



GUIDANCE

To plan for and control your environmental impacts, you must know what these impacts are. But knowing what the impacts are is only part of the challenge—you also should know where these impacts come from. Stated another way, how does your shipyard (i.e., its activities, products, and services) interact with the environment? In Module 4, you identified the legal requirements and voluntary commitments that apply to your facility. In this module you will use this information as you identify environmental aspects and determine which ones are significant. The systematic identification and efficient management of environmental aspects and impacts should result in positive impacts on the bottom line and significant environmental improvements. Environmental Aspects and Impacts In short, the aspect is the cause and the impact is the effect. Figure 5-1. Examples of the Link between Aspects and Impacts

Environmental Aspect ð Environmental Impact(s) Emissions of volatile organic

compounds (VOCs) ð Air pollution, smog

Discharges to stream ð Degradation of aquatic habitat and drinking water supply

Spills and leaks ð Soil and groundwater contamination Electricity use ð Air pollution, global warming

Use of recycled paper ð Conservation of natural resources

Environmental aspect: An element of a facility’s activities, products, or services that can or does interact with the environment. These interactions and their effects may be continuous in nature, periodic, or associated only with events, such as emergencies. Environmental impact: Any change to the environment, whether adverse or beneficial, resulting from a facility’s activities, products, or services.



Various approaches exist for identifying environmental aspects and determining significance. Tool 5-1 provides examples of techniques that can help you identify and prioritize your aspects. The tools presented in this Guide provide examples of approaches your shipyard might wish to customize for its use. They are not meant to be rigid prescriptions. In general, identifying and evaluating your environmental impacts will involve the following tasks:

• Define the scope within which the environmental aspects and impacts will be identified, (that is, the scope of your EMS as you addressed in Module 1);

• Identify all activities, products, and services within that scope (Module 1); • Identify the environmental aspects associated with the activities, products, and services;

and • Determine the subset of your environmental aspects that have significant impacts.

Select an approach that makes sense for your facility and then describe the approach in the form of a written procedure . You can modify Tool 5-2, Sample Procedure for Identification of Environmental Aspects and Determination of Significant Environmental Aspects, to develop that procedure. Keep the resulting information up-to-date, so that the potential aspects of new activities, products and services are factored into your targets and objectives (see Module 6) and operational controls (see Module 12).



A Recommended Approach: Creating Process Flow Diagrams There are several ways to approach identification of aspects and impacts, but regardless of the approach you use, you will need a thorough understanding of all of your processes. Process flow diagrams are a tool that allow a facility to visualize and understand how work gets accomplished. That understanding can help identify how processes can be improved. Facilities can use process flow diagrams to identify process inefficiencies and focus improvement efforts where they will have the most effect. Process flow diagrams also can help you identify environmental aspects and impacts. As an EMS tool, process flow diagrams can help a facility to: • Improve its understanding of existing processes, including the key inputs (such as

chemicals, raw materials and other resources used), outputs (including products, wastes, air emissions, etc.) and interactions with other processes.

• Identify areas for process improvement that can result in environmental performance improvements (such as pollution prevention opportunities)

• Identify environmental aspects and impacts.



Getting Started on Process Flow Diagrams • Select a process (or set of related processes) to examine. Processes might be prioritized for

review based on a number of criteria, such as their relevance or importance to the facility, prior assessments of the process, existing knowledge of the environmental significance of the process, or a history of problems with the process, among others. Also, define the process boundaries. Example 5-1: A List of Common Activities and Processes at Shipbuilding and Ship Repair Facilities, can help you in considering your processes.

• Use a team, such as a subset of your cross-functional team (CFT), to understand and diagram how these process(es) work. At a minimum, the team should include the process “owner” as well as individuals that are actively involved in carrying out the process. Many facilities use a facilitator that is independent of the process under review to manage team meetings. Don’t be surprised if team members have different opinions regarding how well the existing process works.

• As a team, determine the level of detail needed to accurately diagram your processes. Initially, you might diagram at a fairly high level, then get into more detail as improvement opportunities as identified.

• Decide on a set of symbols that the team will use to visually describe the process. For example you might use one symbol for inputs, one for processes, one for outputs, another for decision points, and another for methods used. The flow diagrams in this module (Example 5-2 through 5-9) use a set of symbols like this.

• Identify the key steps (or “unit operations”) in the process first. Then analyze each of these steps in more detail. Use lines or arrows to show the relationships among individual process steps. Use brainstorming and/or storyboarding techniques to identify the process steps and agree upon the sequence of these steps.

• First prepare an “as is” diagram that describes how the process works now, including key process inputs to and outputs. For environmental purposes, key inputs include energy and other resources consumed, and raw materials and chemicals used. Outputs include products or services, air emissions, noise, odor, radiation, wastewater discharges, solid and hazardous wastes. This “as is” diagram can be used to identify environmental aspects as well as opportunities for improvement.

Process flow diagrams of common production processes at shipbuilding and ship repair facilities are provided below as Examples 5-2 through 5- 9. For this EMS Guide, these process flow diagrams also show environmental aspects of the processes. These process flow diagrams have “inputs, processes, outputs, products” labels that correspond to a column heading of this name on the aspect identification forms (Form 5-2, Identification and Significance Determination of Environmental Aspects, and Setting Objectives and Targets). Each example includes an example Aspect Identification and Significant Determination Form, to illustrate how the process flow diagram can be used to identify and determine the significance of the aspects. You likely will need to review these examples and modify them to meet your facility’s specific conditions. The examples should provide a starting point for understanding how the aspect identification process works and for applying it at your facility.



Additional Points to Consider in Identifying Aspects In addition to process flow diagrams, your aspect identification process may benefit from consulting other sources of information such as environmental permits, EPCRA reports, Material Safety Data Sheets, and monitoring records. Tool 5-1: Some Techniques and Data Sources for Identifying and Evaluating Environmental Impacts provides a list of such techniques and data sources. Remember to look at services as well as products. While the need to examine on-site operations might be obvious, you also should consider the potential impacts of what you might do “off-site” (such as servicing equipment at customer sites). Similarly, the environmental aspects of the products, vendors, and contractors you use may be less obvious, but should still be cons idered. Aspects may also result from past activities, such as spills. You may want to refer to the defined scope of your EMS when undertaking this activity. Where appropriate, individual aspects can be grouped. For example, if energy use is listed as an environmental aspect for several processes, it may also be a facility-wide concern. The CFT could list energy on each process-specific aspect form and then record the aspect, significance determination, and objectives for that aspect on a facility-wide form to indicate it as a facility-wide concern. A facility-wide objectives and targets by category example is included as Example 6-1. Determining Significance Determining which aspects have significant impacts and therefore will be included in your EMS as significant environmental aspects (SEAs) is one of the most crucial steps in EMS planning. It can be one of the most challenging – as well as one of the most rewarding. Decisions you make in this step will affect many other system elements (such as setting objectives and targets, establishing operational controls, and defining monitoring needs). Careful planning of this activity will pay dividends later. Determining which aspects are significant involves some subjective decisions. For this reason, you will achieve more balanced results by having a CFT that represents different job functions. This will provide a cross-section of operational experience and different perspectives. Your CFT should carefully define the criteria that will be used to determine which environmental aspects are significant. The criteria presented below and in Tool 5-2: Sample Procedure for Identification of Environmental Aspects and Determination of Significant Aspects are intended to achieve a balance between structure and flexibility. They are a starting point that you can use to customize your own criteria. • An obvious initial criterion is whether or not the aspect is subject to environmental

regulations—all of these aspects, as defined by broad scientific and legis lative consensus, are significant. A closely related condition is whether an aspect is the subject of company



policy, goals, or voluntary commitments. For example, many companies have established energy-use, water-use or waste reduction goals and targets – because it also makes good business sense. If these company policy/goals apply to your facility then the associated aspects should be considered significant.

• A second criterion to consider involves the views of interested parties. One of the commitments of your environmental policy must be communication with external stakeholders. There are a variety of community concerns that might affect your designation of a particular activity as a significant aspect. These may include issues other than pollution. Some examples are the noise level or odor produced by your facility; increased traffic caused by your business; and increased light needed for your operations. Aspects that the community considers important (for example, has lodged complaints about), should be labeled as significant in your EMS. As a starting point, see Tool 5-3: Worksheet for Identifying Community Issues.

• A third criterion is whether the aspect has good technical and financial potential for pollution prevention improvements (such as the reduced use of water, energy, or hazardous materials). Pollution prevention is also included in your environmental policy. The determination that makes for a particular aspect under this criterion is highly subject to the specific circumstances and values of your facility and community. For example, a high rate of water use would be of higher concern in a desert region than in a region where water is more plentiful. The determination that your CFT makes is based on your judgment and your facility’s specific circumstances. As a starting point, see Tool 5-4: Worksheet for Identifying Natural Resources Use/Pollution Prevention Potential.

• A final criterion is one that your CFT customizes for your facility. A commonly used approach relies on scoring environmental aspects based on magnitude, frequency, toxicity, and duration. Tool 5-2: Sample Procedure for Identification of Environmental Aspects and Determination of Significant Aspects presents one example of such factors. Variations on this procedure are provided in Appendix D: Environmental Aspect/Impact Ranking.

SEAs serve as the basis for further planning of your EMS. In a subsequent step, each SEA is assigned an objective. That is, it either becomes the subjects of controls, improvements, or an investigation leading to improvements (Module 6). Controls will be ongoing. Improvements will have targets that specify how much can be achieved and by when. Investigations will have targets that indicate when study results will be issued. Each improvement (and investigation) objective will be associated with an environmental management program that specifies who is responsible for what outcomes and by when (Module 7). In addition, your facility’s SEAs will have key characteristics that are monitored and measured (Module 14), and also will be the basis for determining where operational controls are required (Module 12). Of course, all aspects that are significant as a result of being subject to environmental regulations must be managed and controlled. You must comply with the law. However, when you select improvement objectives you should consider both regulated and non-regulated significant aspects. For instance, a regulated aspect may also be the subject of pollution prevention efforts that save your company money. For example, eliminating certain constituents in, or reducing



volumes of discharges or emissions, might place your facility in a less onerous regulatory reporting bracket and reduce your environmental management and reporting costs. Remember: You don’t have to do everything at once. There may be good reasons (such as cost, availability of technology, notices of violation, or scientific uncertainty) for making environmental improvements regarding some significant aspects now while deferring action on others.



TOOLS Tool 5-1: Some Techniques and Data Sources for Identifying and Evaluating

Environmental Aspects and Impacts Process Hazard Analyses

Used to identify and assess potential impacts associated with unplanned releases of hazardous materials. Methodology in common use due to Occupational Safety and Health Act (OSHA) Process Safety Management regulations. Typically employs team approach to identify and rank hazards.

Failure Mode and Effects Analyses

Commonly used in the quality field to identify and prioritize potential equipment and process failures as well as to identify potential corrective actions. Often used as a precursor to formal root cause analyses.

Process Flow Diagrams

Process flow diagrams are a tool that allows an organization to visualize and understand how work gets accomplished and how its work processes can be improved. Process flow diagrams can help an organization understand its environmental aspects, reduce wastes and pollution, and reduce operating costs by identifying and eliminating unnecessary activities. See Example 5-2 through 5-9 of this module for examples of flow charts of shipbuilding and ship repair processes.

Environmental Impact Assessments

Used to satisfy requirements of National Environmental Policy Act (NEPA) regarding the evaluation of environmental impacts associated with proposed projects. Methodology in common use, but not typically used to assess environmental impacts associated with existing operations.

Life Cycle Assessments

Used to assess the cradle-to-grave impacts of products or processes, from raw material procurement through disposal. Life-cycle methodologies are somewhat subjective and can be resource intensive. These methodologies are described in ISO 14040-14048.

Risk Assessments Used to assess potential health and/or environment risks typically associated with chemical exposure. Variety of qualitative and quantitative methodologies in common use.

Project Safety / Hazard Reviews

Used to assess and mitigate potential safety hazards associated with new or modified projects. Methodologies in common use. Typically do not focus on environmental issues.

Emission Inventories Used to quantify emissions of pollutants to the air. Some data on emissions or chemicals of concern may already by available to you, based on EPCRA requirements and Clean Air Act (CAA) Title V permitting program data requirements.

Pollution Prevention or Waste Minimization Audits

Used to identify opportunities to reduce or eliminate pollution at the source and to identify recycling options. Requires a fairly rigorous assessment of facility operations. These audits typically do not examine off-site impacts.

Environmental Property Assessments

Used to assess potential environmental liabilities associated with facility or business acquisitions or divestitures. The scope and level of detail is variable. These assessments typically do not assess impacts associated with products or services.

Environmental Cost Accounting

Used to assess the full environmental costs associated with activities, products or services. Emerging protocols require comprehensive assessments to quantify such costs.

Environmental Compliance Audits

Used to assess compliance with federal, state, and local environmental regulations. These methodologies are in common use. Their scope and level of detail vary. These are not typically directed at examining environmental impacts (particularly for products).



Tool 5-2: Sample Procedure for Identification of Environmental Aspects and Determination of Significant Aspects

Purpose This procedure defines [Your Facility’s Name]’s method for the identification of environmental aspects of its operations and the determination of significance for aspects that have actual or potential significant impacts on the environment. Procedure for Environmental Aspect Identification

Establish Cross Functional Team

(CFT)

Determine Core Processes and

Supporting Activities

Inspect Each Process/Activity and Create Process

Flow Diagram

Identify and Record Env. Aspects

Determine Significant

Environmental Aspects

Procedure for Environmental

Aspect Identification

Responsibilities of the CFT The facility Cross Functional Team (CFT) led by the Environmental Management Representative (EMR) or designee is responsible for completing the Form 5-2 (see below) for each core process and supporting activity. If possible, members of the CFT will conduct a physical inspection when completing the form. The completed form is a process flow diagram of a process or activity and is used to identify environmental aspects. At a minimum, the CFT will review and revise the completed forms, by means of physical inspection, as necessary at issuance, annually, and before and immediately following implementation of new or modified processes/activities. All environmental aspects are evaluated for significance as defined in the section below, Procedure for Determination of Significant Environmental Aspects. Creating a Process Flow Diagram The following procedure is used to fill out the Aspect Identification portion of Form 5-2, Identification and Significance Determination of Environmental Aspects, and Setting Objectives and Targets.



Creating the process flow diagram consists of identifying all raw materials, chemicals, and utilities used as inputs and all outputs produces as products and by-products. Outputs are all products, wastes produced, recycled materials, water discharges, and air emissions known for the process(es). When identifying inputs and outputs, all modes of operation will be considered because startup, shutdown, or emergency operations might introduce additional aspects to the process. When doing the diagrams, the team will make notes of other potentially useful information such as the quantity or volume used per unit time, where available. These diagrams will be improved over time with specific data to allow material balances in the long term, if this is not possible initially. To assist with these diagrams, the CFT shall consider the following potential inputs and outputs: Inputs • Supplies: Enter the major, non-chemical supplies used in the process. • Chemical: Enter any chemical materials used in the process. • Energy Use: Enter energy type and usage. (Levels are relative to the facility.) • Water Use: Enter water type (e.g. city, well, storm, process, chilled) and usage. (Levels are

relative to the facility.) • Other Inputs: Enter inputs that are not covered clearly in other categories. Outputs • Air Emissions: List all air emissions whether they are drawn directly through a stack or are

discharged into the room and escape as fugitive emissions. • Noise/Odor/Radiation: Include noise and odor as an air emission if potentially noticeable

outside the facility and list any potential radiation emitted from the facility. • Water Discharges: Enter all wastewater streams that discharge directly to storm or sanitary

sewer systems or surface waters. Containerized wastewater should be included in the waste section.

• Solid / Residual Wastes: Wastes are any materials intended to be discarded or disposed of, whether regulated or not, and include liquids, solids, and gases. Also include recycled materials, returnable containers, and chemical by-products under this category.

• Storm Water Discharges: List all storm water discharges from all process areas. • Spills: Enter all potential spills that might occur in all process areas. Procedure for Determination of Significant Environmental Aspects (SEAs) Where appropriate, individual aspects can be grouped. (For example, if the consumption of energy is listed as an environmental aspect in several areas, the CFT can group these listings such that consumption of energy appears just once on a facility-wide form.)



The following criteria will be used to determine significance and are listed Form 5-2: 1. Legal Requirements/Voluntary Commitments/Company Policy: Subject to specifically

relevant legislation, regulation and/or permit requirements that address significant impacts to the environment. This will likely include aspects associated with processes and activities if (1) environmental regulations specify controls and conditions, (2) information must be provided to the authorities, and/or (3) there are, or may be, periodic inspections or enforcement actions taken by the authorities. Potential aspects that are subject to environmental regulations in the event of incidents will be recognized as significant when such as event occurs. A closely related condition is whether an aspect is the subject to or associated with environmentally-related company goals, directives, policies or subject to or associated with voluntary covenants to which the company had committed.

2. Community Concern: Subject to or associated with community concerns, such as those previously expressed in the form of complaints or critical inquiry. If helpful, use Tool 5-3: Worksheet for Identifying Community Issues.

3. Pollution Prevention Potential: Based on technical and business conditions, has a high potential for pollution prevention or resource-use reduction. If helpful, use Tool 5-4: Worksheet for Identifying Natural Resources Use/Pollution Prevention Potential

4. Potential Impact to the Environment: Associated with potential impact to the environment from high environmental loading due to one or more of the following:

a. Toxicity (compositional characterization of materials and wastes) b. Amounts (volumes and masses of emissions, waste, or releases) c. Amounts (consumption of renewable and non-renewable resources) d. Frequency of episodes e. Severity of actual or potential impacts

(Note: Additional examples of how to determine significance are provided in Appendix E, Environmental Aspects/Impacts Ranking). Using the Significance Determination portion of Form 5-2, the CFT or a subset thereof, shall evaluate, each identified aspect to determine whether it is significant. The environmental aspects will be considered to be “significant” if the aspect has an impact on the environment and meets one or more of the four criteria. For criteria 1 and 2, put Yes or No in the appropriate column on Form 5-2. Put Low or Yes for criteria 3. Iindicate Low, High, or “NA” for not applicable for criterion 4. Finally, evaluate the four criteria. If any of them are Yes (or High for criteria 4), indicate “S” for significant in the appropriate column. Otherwise, indicate “N” for not significant. Provide the rationale for S or N in the appropriate column on Form 5-2. Frequency This procedure will be repeated at least annually. More frequent updates will be conducted for new projects or processes that affect the list of the facility’s significant aspects. Records The originals of completed Form 5-2 are maintained by the EMR or designee.



Form 5-2: Identification and Significance Determination of Environmental Aspects and Setting Objectives and Targets Person Completing Form: Area/Process: Date:

ASPECT IDENTIFICATION SIGNIFICANCE DETERMINATION OBJECTIVES &TARGETS*

Category/Aspect Inputs, Processes, Outputs, Products Q

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or Non-significance (N)

Objective & Type C = control or maintain S = study or investigate

I = improve Target Energy Usage: Water Usage: Supplies/Disposables: Chemicals: Air Emissions: Noise/Odor/Radiation: Wastes: Water Discharges: Stormwater Discharges:

Spillage and Other: * The Objectives & Targets column is discussed in Module 6, Objectives and Targets. Completed forms can be found in the Examples 5-2 through 5-9.



Tool 5-3: Worksheet for Identifying Community Issues

Process Aspect Community Issue(s) Rank

Contact Person: _________________________________ Date: ________________________

Rank indicates Yes or No, and can be transferred to Form 5-2. Tool 5-4: Worksheet for Identifying Natural Resources Use/Pollution Prevention Potential

Process Aspect Natural Resources Used/ Pollution Prevention Potential Rank

Contact Person: _________________________________ Date: ________________________

Rank indicates Low or High and can be transferred to Form 5-2.



EXAMPLES

This module presents several examples of how to develop process flow diagrams and how to use that information on the Aspects Identification and Significance Determination Form (Form 5-2). Several common shipbuilding and ship repair process are presented as examples. The drydock painting example will be further expanded in Modules 6 and 7 to illustrate how to proceed from significant aspect determination to setting objectives and targets and establishing Environmental Management Programs (EMPs).

• Example 5-1 provides a list of common activities and processes at a shipbuilding and ship repair facility.

• Example 5-2 provides an example process flow diagram and aspect identification and significance determination form for drydock painting.

• Example 5-3 provides an example process flow diagram and aspect identification and significance determination form for small parts coating, outdoor.

• Example 5-4 provides an example process flow diagram and aspect identification and significance determination form for gas metal arc welding.

• Example 5-5 provides an example process flow diagram and aspect identification and significance determination form for dry abrasive blasting.

• Example 5-6 provides an example process flow diagram and aspect identification and significance determination form for burning and cutting.

• Example 5-7 provides an example process flow diagram and aspect identification and significance determination form for high pressure water jetting.

• Example 5-8 provides an example process flow diagram and aspect identification and significance determination form for metal grinding.

• Example 5-9 provides an example process flow diagram and aspect identification and significance determination form for material transport, crane.

These examples were prepared for EPA by DM Austin Environmental Consulting, Inc. (Austin Environmental and are included as provided with little modification. These are examples and likely will require you to further refine and modify them to fit your facility’s needs.



Example 5-1: A List of Common Activities and Processes with Functional Areas at Shipbuilding and Ship Repair Facilities

Activity and Process Functional Area Drydock Painting* Small Parts Coating, Outdoor* Gas Metal Arc Welding* Dry Abrasive Blasting* Burning and Cutting* High Pressure Water Jetting* Metal Grinding* Material Transport, Crane* Metal Working Bilge Cleaning Fiberglass Reinforced Construction Other Painting, Coating, and Plating Pipe Fabrication, Aluminum Fabrication, Steel Fabrication Metal Plating and Surface Finishing Other Machining and Metal Working

Construction and Repair

General Repairs Maintenance Storage of Materials and Waste: paint and solvents, metals, hydraulic fluids, lube oils, paint waste, blasting media, welding gases, universal waste, diesel, fuel, gasoline

Raw Materials Management and Waste Accumulation

Hazardous Waste Disposal Universal Waste Disposal Wastewater Disposal Wastewater Treatment

Waste Disposal and Treatment

Fuel Storage and Transfer Electrical Generation Compressed Air Generation Steam Generation

Maintenance and Operation

Administration General Support * Indicates activities and processes for which example flow diagrams and aspect identification and significance determination forms are provided in the remainder of this module.



Example 5-2: Flow Diagram and Aspect Identification and Significance Determination Form for Drydock Painting



Person Completing Form: John Smith, Paint Department Supervisor Area/Process: Drydock Painting Date: 5/17/01

ASPECT IDENTIFICATION SIGNIFICANCE DETERMINATION OBJECTIVES &TARGETS


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I = improve Target Energy Usage: Electricity/ Paint Mixers Mix and thin coatings

(Pro-3) 10 kw/ year No No Low Low N Does not meet significance criteria,

low volume usage Diesel Fuel/Forklift Transport coatings and

waste to dry dock (Pro-1, Pro-14, Pro-15, Pro-16, Pro-18, Pro-19, Pro-20)

1000 gallons per year

No No Low Low N Does not meet significance criteria, low volume usage

Water Usage: N/A N/A Supplies/Disposables: Rags Inp-3 No No Low Low N Does not meet significance criteria Gloves Inp-3 No No Low Low N Does not meet significance criteria Tyvek coverall Inp-3 No No Low Low N Does not meet significance criteria Filters Inp-3 No No Low Low N Does not meet significance criteria Sand Paper Inp-3 No No Low Low N Does not meet significance criteria Chemicals: VOC Content HAP Content

Virgin Coatings (Inp-1) Yes Yes Low N/A S Marine Coating Rule, Air Permit

VOC Content HAP Content

Virgin Thinners (Inp-2) Yes Yes Low N/A S Marine Coating Rule, Air Permit

Air Emissions: Fugitive VOCs Applying Coating (Pro-

7) 40 tons Yes Yes Yes N/A S Marine Coating Rule, permits of operate, toxic air emissions rule

Fugitive HAPs Applying Coating (Pro-7) 10 tons Yes Yes Yes N/A S Marine Coating Rule, permits of

operate, toxic air emissions rule

Over spray, fugitive particulate emissions

Applying Coating (Pro-7)

8 tons Yes Yes Yes N/A S Marine coating rule, coating permits to operate, toxic air emissions rule





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I = improve Target Noise/Odor/Radiation: Odor from VOCs fume Applying Coating (Pro-

7) No No Low Low N Does not meet significance criteria

Wastes: Contaminated Scrap Waste Paint Cans (Out-1) 10,000

lbs per year

No No Yes Low S Waste Reduction Program

Contaminated Waste Tyrex Suites, Rollers, Brushes, Filter Masks, Paint Stirrers, Drop Clothes, Masking Tape (Out-5), Debris (Out-6)


Waste Chemicals Waste Paint and Solvent (Out-2)

1,500 gallons Yes Yes Yes N/A S RCRA (Title C)

Solid waste, landfill Consolidate contaminate disposables (Pro-12) and debris (Pro-13)

10,000 and

5,000 lbs per year


Water Discharges: N/A Stormwater Discharge: VOC-contaminated water Yes Yes Yes N/A S Storm water permit Heavy metal contaminated water

Yes Yes Yes N/A S Storm water permit





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I = improve Target Spillage and Other:

Transport waste cans, cleaning solvents, contaminated solvents and debris to scrap yard (Pro-14, Pro-18, Pro-19, Pro-20)

5 gallons per year

No No Low Low N Does not meet significance criteria, low volume spillage

Consolidate equipment cleaning solvent into drums (Pro-16)

10 gallons per year

Yes No Low N/A S Volume exceeds “No Spill” Policy limits

Spillage

Transport coatings and thinners (Pro-1 through Pro-6)

No No Low Low N Does not meet significance criteria, low spillage volume

Spillage, contaminated scrap

Consolidate Waste (Pro-9) 5

gallons No No Low Low N Does not meet significance criteria , low volume of spillage, scrap is recycled

Consolidate waste paint and solvent (Pro-10)



Solvent Cleaning of Equipment (Pro-11)

50 gallons per year


Coating Thinner Spillage

Consolidate Contaminated Solvent into Drums (Pro-16)

10 gallons per year

Yes No Yes N/A N Does not meet significance criteria, low volume of spillage



Example 5-3: Flow Diagram and Aspect Identification and Significance Determination Form for Small Parts Coating, Outdoors



Person Completing Form: John Smith, Environmental Engineer Area/Process: Small Parts Coating, Outdoors Date: 5/17/01



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(Pro-4) 10 kw/

year No No Low Low N Does not meet significance criteria,

low volume usage

Diesel Fuel/Forklift Transport Equipment, Materials, Waste and Scrap to and from Paint Pit. (Pro-2), (Pro-5), (Pro-15), (Pro-16), (Pro-19), (Pro-20), (Pro-21)



Water Usage: N/A N/A Supplies/Disposables: Rags Inp-3 No No Low Low N Does not meet significance criteria Gloves Inp-3 No No Low Low N Does not meet significance criteria Tyvek coverall Inp-3 No No Low Low N Does not meet significance criteria Filters Inp-3 No No Low Low N Does not meet significance criteria Sand Paper Inp-3 No No Low Low N Does not meet significance criteria Chemicals: VOC Content HAP Content

Virgin Coatings (Inp-1) N/A Yes Yes Low N/A S Marine Coating Rule, Air Permit


Virgin Thinners (Inp-2) N/A Yes Yes Low N/A S Marine Coating Rule, Air Permit

Air Emissions: Fugitive VOCs Fugitive Air Emissions

(Out-1) 2 tons Yes Yes Yes N/A S Marine Coating Rule, permits of


Fugitive HAPs Fugitive Air Emissions (Out-1) 0.5 tons Yes Yes Yes N/A S Marine Coating Rule, permits of



Fugitive Air Emissions (Out-1)

8 tons Yes Yes Yes N/A S Marine coating rule, coating permits to operate, toxic air emissions rule





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I = improve Target Noise/Odor/Radiation: Odor from VOCs fume Applying Coating (Out-

1) No No Low Low N Does not meet significance criteria


lbs per year


Contaminated Waste Tyvex Suits, Rollers, Brushes, Filter Masks, Paint Stirrers, Drop Clothes, Masking Tape (Out-6), Debris (Out-7)

3,500 lbs pe year



500 gallons

Yes Yes Yes N/A S RCRA (Title C)

Solid waste, landfill Consolidate contaminated disposables (Pro-19) and debris (Pro-20)

10,000 and

5,000 lbs per year


Water Discharges: N/A Stormwater Discharges: Heavy metal contaminated water

Fugitive Air Emissions (particulates) (Out-1) Yes Yes Yes N/A S Storm water permit

Spillage and Other: Spillage Transport waste cans,

cleaning solvents, contaminated solvents and debris to scrap yard (Pro-15), (Pro-16), (Pro-21), (Pro-19), (Pro-20)

25 gallons per year






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I = improve Target Consolidate equipment cleaning solvent into drums (Pro-17)

10 gallons per year


Transport coatings and thinners (Pro-2)

10 gallons per year

No No Low Low N Does not meet significance criteria, low spillage volume


Consolidate Waste (Pro-9) 5

gallons No No Low Low N Does not meet significance criteria, low volume of spillage, scrap is recycled





50 gallons per year




10 gallons per yar

No No Low N/A N Does not meet significance criteria, low volume of spillage



Example 5-4: Flow Diagram and Aspect Identification and Significance Determination Form for Gas Metal Arc Welding



Person Completing Form: John Smith, Environmental Engineer Area/Process: Gas Metal Arc Welding Date: 5/17/01



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I = improve Target Energy Usage: Electricity Electric Arc Generator

(Inp-1) 10,000kw/ year


Diesel Fuel/Forklift Transport Equipment, Materials, Scrap and Waste to and from Work Area (Pro-2), (Pro-11), (Pro-12), (Pro-13), (Pro-14) and (Pro-15)



Water Usage: N/A N/A Supplies/Disposables: Rags Inp-4 No No Low Low N Does not meet significance criteria Gloves Inp-4 No No Low Low N Does not meet significance criteria Tyvek coverall Inp-4 No No Low Low N Does not meet significance criteria Filters Inp-4 No No Low Low N Does not meet significance criteria Chemicals: Nitrogen, Argon, Helium gases

Shielding Gases (Inp-3) N/A No No Low N/A N Does not meet significance criteria, non hazardous, inert gases

Air Emissions: Metal fumes Fugitive Air Emissions

(Out-1) 0.5 tons

Yes Yes Yes N/A S Permits of operate, Toxic air emissions rule

Noise/Odor/Radiation: Odor from welding fumes Fugitive Air Emission

(Out-1) No No Low Low N Does not meet significance criteria

Wastes: Contaminated Scrap Waste Rods/Wire (Out-

2) Waste Slag and Metal

10,000 lbs per year






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I = improve Target Chips (Out-3)

Contaminated Waste Waste Disposables (Out-5) Contaminated Debris (Out-6)



Fugitive Air Emissions (Out-1) Yes Yes Yes N/A S Storm water permit

Spillage and Other: Spillage Transport Equipment,

Materials, Scrap and Waste to and from Work Area (Pro-2), (Pro-11), (Pro-12), (Pro-13), (Pro-14) and (Pro-15)

100 lbs per year




Example 5-5: Flow Diagram and Aspect Identification and Significance Determination Form for Dry Abrasive Blasting



Person Completing Form: John Smith, Environmental Engineer Area/Process: Dry Abrasive Blasting Date: 5/17/01



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I = improve Target Energy Usage: Electricity Compress Air Supply

(Inp-4) 10,000kw/year

No No Yes Low S Pollution prevention potential.

Diesel Fuel/Forklift Transport Equipment, Materials, Scrap and Waste to and from Work Area (Pro-2), (Pro-11), (pro-12), (Pro-13), (Pro-14) and (Pro-15)



Water Usage: N/A N/A Supplies/Disposables: Rags Inp-3 No No Low Low N Does not meet significance criteria Gloves Inp-3 No No Low Low N Does not meet significance criteria Tyvek coverall Inp-3 No No Low Low N Does not meet significance criteria Filters Inp-3 No No Low Low N Does not meet significance criteria Chemicals: N/A N/A Air Emissions: Fugitive Particulates Fugitive Air Emissions

(Out-1) 10 tons Yes Yes Yes N/A S Permits to operate, Toxic air emissions rule, Nuisance rule

Noise/Odor/Radiation: Blasting Operations Conduct Blasting

Operations (Pro-4) High levels

of Noise

Yes Yes Low N/A S High noise levels effects nesting birds

Wastes: Waste Abrasive Spent Abrasive (Out-2) 6,000

tons per year

Yes Yes Yes N/A S Waste Reduction Program





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I = improve Target Contaminated Waste Contaminated

Curtains/Shrouds (Out-3) Waste Disposables (Out-4) Contaminated Debris (Out-6)

10,000 lbs per year

Yes No Yes N/A S Waste Reduction Program



Spillage and Other: Spillage Transport of materials

and wastes to and from the Work Area (Pro-2), (Pro-11), (Pro-13), (Pro-15)

1 ton per year Yes No Yes N/A S Annual amount exceeds company

“No Spillage Policy”


50 gallons per year



10 gallons per year

Yes No Yes N/A N Does not meet significance criteria, low volume of spillage



Example 5-6: Flow Diagram and Aspect Identification and Significance Determination Form for Burning and Cutting



Person Completing Form: John Smith, Environmental Engineer Area/Process: Burning and Cutting Date: 5/17/01



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I = improve Target Energy Usage: Diesel Fuel/Forklift Transport Equipment,

Materials, Scrap and Waste to and from Work Area (Pro-2), (Pro-10), (Pro-12), (Pro-13), (Pro-14)



Water Usage: N/A N/A Supplies/Disposables: Rags Inp-4 No No Low Low N Does not meet significance criteria Gloves Inp-4 No No Low Low N Does not meet significance criteria Tyvek coverall Inp-4 No No Low Low N Does not meet significance criteria Filters Inp-4 No No Low Low N Does not meet significance criteria Chemicals: Acetylene Burning Gases (Inp-1) N/A No No Low Low N Does not meet significance criteria Air Emissions: Metal fumes Fugitive Air Emissions

(Out-1) 0.5 tons Yes Yes Yes N/A S Permits of operate, Toxic air

emissions rule

Noise/Odor/Radiation: Odor from burning fumes Fugitive Air Emissions

(Out-1) No No Low Low N Does not meet significance criteria

Wastes: Scrap Metal Waste Slag and Metal

Chips (Out-2) 10,000 lbs per year


Contaminated Waste Waste Disposables (Out-4) Contaminated Debris (Out-5)






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I = improve Target Water Discharges: N/A Stormwater Discharges: Heavy metal contaminated water



Materials, Scrap and Waste to and from Work Area (Pro-2), (Pro-10), (Pro-12), (Pro-13)

100 lbs per year




Example 5-7: Flow Diagram and Aspect Identification and Significance Determination Form for Ultra High Pressure Water Jetting



Person Completing Fo rm: John Smith, Environmental Engineer Area/Process: Ultra High Pressure Water Jetting Date: 5/17/01



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I = improve Target Energy Usage: Diesel Fuel/Pumps Conduct Water Jetting

Operations (Pro-4) 5,000 gallons per year


Water Usage: Water Water (Inp-4) 100,000

gallons per year


Supplies/Disposables: Rags Inp-3 No No Low Low N Does not meet significance criteria Gloves Inp-3 No No Low Low N Does not meet significance criteria Tyvek coverall Inp-3 No No Low Low N Does not meet significance criteria Filters Inp-3 No No Low Low N Does not meet significance criteria Chemicals: N/A N/A Air Emissions: N/A N/A Noise/Odor/Radiation: Water Jetting Operations Conduct Water Jetting

Operations (Pro-4) High levels

of Noise

Yes Yes N/A Low S High noise levels effects nesting birds

Wastes: Contaminated Waste water Contaminated Waste

Water Stream (Out-1) 80,000 gallons per year

Yes No Yes N/A S NPDES discharge requirements

Solid Waste Waste Disposables and Debris (Out-2), (Out-4)

10,000 lbs per year

No No Yes Low S Waste reduction policy





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I = improve Target Water Discharges: Contaminated Waste water Contaminated Waste


Yes No Yes N/A S

NPDES discharge requirements

Stormwater Discharges: Contaminated Waste water Contaminated Waste


Yes No Yes N/A S Stormwater permit requirements

Spillage and Other: N/A N/A



Example 5-8: Flow Diagram and Aspect Identification and Significance Determination Form for Metal Grinding



Person Completing Form: John Smith, Environmental Engineer Area/Process: Metal Grinding Date: 5/17/01



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I = improve Target Energy Usage: Electricity Electric or Pneumatic

Power (Inp-4) 5,000kw

/year No No Low Low N Does not meet significance criteria,

low volume usage

Diesel Fuel/Forklift Transport Equipment, Materials, Scrap and Waste to and from Work Area (Pro-2), (Pro-11), (Pro-12), (Pro-14) and (Pro-15)



Water Usage: N/A N/A Supplies/Disposables: Grinding Discs Inp-2 No No Low Low N Does not meet significance criteria Gloves Inp-3 No No Low Low N Does not meet significance criteria Tyvex coverall Inp-3 No No Low Low N Does not meet significance criteria Filters Inp-3 No No Low Low N Does not meet significance criteria Chemicals: N/A N/A Air Emissions: Metal dust and fumes Fugitive Air Emissions

(Out-1) 1.8 tons per year

No No Yes Low S Soil and water contamination

Noise/Odor/Radiation: N/A N/A Wastes: Solid Waste Waste Grinding disks

Metal dust and chips, disposables and debris (Out-2), (Out-3), (Out-5), (Out-6)

8,000 lbs per year






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I = improve Target Water Discharges: N/A N/A Stormwater Discharges: Heavy metal contaminated water



Materials, Scrap and Waste to and from Work Area (Pro-2), (Pro-11), (Pro-12), (Pro-14) and (Pro-15)

100 lbs per year




Example 5-9: Flow Diagram and Aspect Identification and Significance Determination Form for Material Transport, Crane



Person Completing Form: John Smith, Environmental Engineer Area/Process: Material Transport, Crane Date: 5/17/01



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I = improve Target Energy Usage: Diesel Fuel Diesel Fuel (Inp-1) 10,000

gallons per year

No No No N/A N Does not meet significance criteria, high volume usage

Water Usage: N/A N/A Supplies/Disposables: N/A N/A Chemicals: N/A N/A Air Emissions: NOX, SOX, Particulates Point Source Air

Emissions (Out-1) 2.3 tons Yes Yes Yes N/A S Permits to operate

Noise/Odor/Radiation: Odor from diesel fuel combustion

Point Source Air Emissions (Out-1)

No No Low Low N Does not meet significance criteria

Wastes: N/A N/A Water Discharges: N/A Stormwater Discharges: Petroleum contaminated water

Spillage of Diesel Fuel (Pro-2), (Pro-3), (Pro-4)

Yes Yes Yes N/A S Storm water permit

Spillage and Other: Spillage Spillage of Diesel Fuel

(Pro-2), (Pro-3), (Pro-4) 250

gallons per year

Yes Yes High Yes S Annual volume exceeds criteria of “No Spill Policy”



Module 6: Objectives And Targets Guidance ..................................................................................................................................... 6-2

Figure 6-1: Considerations for Developing Objectives and Targets.............................. 6-3

Tools ............................................................................................................................................ 6-5

Tool 6-1: Objectives and Targets Worksheet ................................................................. 6-5 Tool 6-2: Sample Procedure for Identification of Objectives and Targets..................... 6-6

Examples..................................................................................................................................... 6-8

Example 6-1: Objectives and Targets Organized by Category...................................... 6-8 Example 6-2: Identification of Objectives and Targets for Drydock Painting ............ 6-10



GUIDANCE

Objectives and targets help an organization translate purpose into action. These environmental goals should be factored into your business plans. This can facilitate the integration of environmental management with your organization’s other management processes. You determine what objectives and targets are appropriate for your organization. These goals can be applied organization-wide or to individual units, departments, or functions -- depending on where the implementing actions will be needed. In setting objectives, keep your environmental policy commitments in mind. You should also consider your significant environmental aspects, (SEAs) applicable legal and other requirements, the views of interested parties, your technological options , and financial, operational, and other organizational considerations . Figure 6-1 summarizes these considerations. There are no “standard” environmental objectives that make sense for all organizations. Your objectives and targets should reflect what your organization does, how well it is performing, and what it wants to achieve.

Environmental Objective:

"Overall environmental goal, arising from the environmental policy, that an organization sets itself to achieve, and which is quantified where practicable."

Environmental Target :

"Detailed performance requirement, quantified where practicable, applicable to the organization or parts thereof,

that arises from the environmental objectives and that needs to be set and met in

order to achieve those objectives.”

Factors to consider in setting objectives and targets

þ ability to control

þ ability to track / measure

þ cost to track / measure

þ progress reporting

þ links to policy commitments

ISO 14001 Definitions



Figure 6-1. Considerations for Developing Objectives and Targets

Hints

• Setting objectives and targets should involve people in the relevant functional area(s). These people should be well positioned to establish, plan for, and achieve these goals. Involving people helps to build commitment.

• Get top management buy-in for your objectives. This should help to ensure that adequate resources are applied and that the objectives are integrated with other organizational goals.

• In communicating objectives to employees, try to link the objectives to the actual environmental improvements being sought. This should give people something tangible to work towards.

• Objectives should be consistent with your overall mission and plan and the key commitments established in your policy (pollution prevention, continual improvement, and compliance). Targets should be sufficiently clear to answer the question: “Did we achieve our objectives?”

• Be flexible in your objectives. Define a desired result, then let the people responsible determine how to achieve the result.

• Objectives can be established to maintain current levels of performance as well as to improve performance. For some SEAs you might have both maintenance and improvement objectives.

Policy

EnvironmentalAspects

Legal / Other Requirements

Views of Interested Parties

Objectives and

Targets

Technology Finance Operations Other Business Considerations

Environmental Management Program(s)



• Communicate your progress in achieving objectives and targets across the organization. Consider a regular report on this progress at staff meetings or posting key targets and progress to those targets in our plant.

• To obtain the views of interested parties, consider holding an open house or establishing a focus group with people in the community.

• How many objectives and targets should an organization have? Various EMS implementation projects indicate that it is best to start with a limited number of objectives (say, three to five) and then expand the list over time. Keep your objectives simple initially, gain some early successes, and then build on them.

• Make sure your objectives and targets are realistic. Determine how you will measure progress towards achieving them.

• Keep in mind that your suppliers (of service or materials) can help you in meeting your objectives and targets (e.g., by providing more “environmentally friendly” products).

• If an environmental aspect is not significant then it does not need an objective and target.

POLLUTION PREVENTION TOOLS As interest in pollution prevention grows and organizations look to move beyond the ‘low-hanging fruit,” it becomes increasingly important to find ways to evaluate the potential benefits of pollution prevention alternatives. Two such tools are Life Cycle Analysis (LCA) and Total Coast Assessment (TCA). Life Cycle Analysis generally focuses on the environmental aspects of a specific product (although it could be applied to processes or services) over its lifetime. LCA looks at each stage from raw material through production, use, and disposal. Inputs to the analysis include energy use, waste generation, emission, and releases from each stage. Total Cost Assessment focuses on the total costs of a project or product, including environmental costs which many assessment methods do not include. This is often done to support evaluations of process or product changes over the long term. For example, TCA might be used to assess the benefits and costs of continuing to use a VOC-based process versus those of using a water-based process for the same purpose.



TOOLS

Tool 6-1: Objectives and Targets Worksheet Do we have an existing process for setting and reviewing environmental objectives and targets? If so, does that process need to be revised? In what way(s)?

Who needs to be involved in this process within our organization? Should any outside parties be involved?

When is the best time for us to implement this process? Can it be linked to another existing organizational process (like our annual or strategic planning process?)

What are our existing environmental goals? How were these developed? Who was involved? What factors were considered in setting these goals?

Who are our interested parties? How do we obtain their views? How effective has our process been?

How can we effectively and efficiently track our progress and communicate the results? Who is in the best position to do this?

Our next step on environmental objectives and targets is to …



Tool 6-2: Sample Procedure for Identification of Objectives and Targets Purpose [Your Facility’s Name] sets objectives for environmental improvement and develops targets and action plans to meet those objectives. These objectives are directly related to the company’s significant environmental aspects (SEAs) and follow from its environmental policy commitments. Procedure 1. The cross functional team (CFT) or designee identifies objective and targets which the

plant manager reviews and approves. The environmental objectives and targets for each process are recorded using the last column of Form 5-2 for each process. They can then be summarized on a form similar to Example 6-1, Objectives and Targets Organized by Category, for the plant as a whole. For each SEA, the organization will establish an appropriate objective and target. There are three types of objectives represented as follows:

C = Control or Maintain I = Improve S = Study or Investigate

Guidance regarding use of these objectives is provided for use by the CFT: Control or Maintain – is an appropriate objective for SEAs that are the subject of environmental regulations, because the environmental policy states that we will comply with the law. In these cases, the objective will be to maintain conformance with operational controls, such as procedures and work instructions that apply to those significant aspects. The target will be ongoing. Improve – is appropriate for SEAs that our company goals commit us to improving on. For example, energy- or water-use reductions that are not required by law but fall within our commitment to pollution prevention. Improvement objectives also can be used for SEAs that have regulatory drivers and environmental improvement goals. For example, we have regulatory requirements and fugitive emission reduction goals for our VOC emissions. Copper in storm water effluent is another example because we wish to reduce discharge levels below the limits set in our permits. Thus, the objective for these will be C and I (that is, maintain compliance and reduce emissions). Study or Investigate – is appropriate in cases where the CFT thinks improvement will be feasible and beneficial, but study is needed to determine how much improvement can be achieved and timeframes that are feasible. The objective will be to study the alternatives by a target date in preparation for later setting an improvement objective (or dropping the objective if the study reveals that the changes are not financially, technologically, or logistically feasible).



2. The CFT is also responsible for developing and recommending potential new environmental objectives to top plant management. In identifying potential new objectives, the CFT considers the following:

• Environmental policy • SEAs (especially, those SEAs that pose chemical risk) • Applicable laws and regulations and potential future laws and regulations • Practical business criteria, such as the potential costs and benefits of pursuing a

particular environmental objective and our commitment to pollution prevention • The views of employees and other interested parties

3. When developing and recommending objectives, the CFT should consider the number of columns that were marked “yes” on Form 5-2. These columns relate to the significance criteria established by this EMS (legal/company requirements, community concerns, pollution prevention potential, and/or potential impact on the environment). Those SEAs with two or more Yes or High rankings will likely be good candidates for control, improvement or investigation.

4. Once environmental objectives are approved by top plant management, the Environmental Management Representative (EMR) assigns responsibility (to the manager of the process in question, where appropriate) for developing targets and action plans to realize the objectives. Sometimes, this may require an alternatives evaluation (or study) as the first target (or action item). These action plans are addressed in Module 7, Environmental Management Program(s).

Frequency Environmental objectives are reviewed at least annually. The targets and action plans are developed and revised as needed by the CFT or designee. Records Environmental objectives and targets are recorded using Form 5-2. A summary of company objectives and targets can be recorded using a form like Example 6-1. Environmental Management Programs that correspond to each objective are recorded using Tool 7-2. The EMR or designee is responsible for maintaining these records.



EXAMPLES Example 6-1: Objectives and Targets Organized by Category

Objectives Targets Supplies Increase use of non hazardous chemicals by suppliers

• Increase use of suppliers that provide alternative chemicals by 15% by January 2002

Reduce amount of supplies used • Implement recycling of supplies (abrasive media, oil, plastic, laser cartridges, metal, paint booth water) respectively by January 2004

• Implement reuse program for wooden pallets by January 2004

Chemicals Reduce usage of hazardous chemicals

• Reduce use of high-VOC paints by 25% by January 2004

• Increase use of water-soluble cutting fluids by 15% by January 2004

Energy Use Reduce energy usage • Reduce electricity use by 10% by January 2004

• Reduce natural gas use by 15% by January 2004 Water Use Reduce water use • Reduce water use by 10% by January 2002 Air Emissions Reduce air emissions • Reduce boiler emissions by 10% by January 2004

• Improve material handling practices (for example, use of paint warming cabinets) by January 2004

• Improve paint usage tracking system by January 2004 • Reduce paint overspray by 25% by January 2004 by

training personnel on correct spray painting techniques and developing maintenance program for spray painting equipment to allow maximum transfer efficiency (to be supported by paint vendor).



Objectives Targets Water Discharges Reduce VOCs in wastewater discharges

• Increase use of aqueous cleaners by 20% by January 2004

Improve habitat and water quality of estuary

• Restore fish stocks and habitat by January 2004

Solid/Liquid Wastes Reduce paint waste • Reduce paint waste by 25% by paint mixing at point of

use by January 2004 Reduce hazardous waste • To be achieved by target above and reduction of

hazardous chemicals use Stormwater Discharges Reduce metal concentration in storm water discharge

• Improve stormwater collection and filtration system by January 2004

• Investigate effectiveness of additional best management practices (BMPs) by January 2003

Spills Reduce occurrence of spills • Reduce spill occurrence by 10% by January 2004 by

training the following personnel: (1) all plant personne l will receive awareness training during 2002; (2) all raw material handling personnel will receive spill prevention training during 2003; and (3) all production personnel will receive spill control training to reduce spills that exit the plant during 2003. Also, CFT will develop a team to conduct a root-cause analysis of spills during 2002 that will be incorporated into the training program.



Example 6-2: Identification of Objectives and Targets for Drydock Painting This is an example of the use of Form 5-2, which continues from Example 5-2 in Module 5. Person Completing Form: John Smith, Environmental Engineer Area/Process: Drydock Painting Date: 5/17/01



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or Nonsignificance (N)



(Pro-3) 10 kw/ year


NA NA

Diesel Fuel/Forklift Transport coatings and waste to dry dock (Pro-1, Pro-14, Pro-15, Pro-16, Pro-18, Pro-19, Pro-20)


No No Low Low N Does not meet significance criteria, low volume usage NA NA

Water Usage: NA NA Supplies/Disposables: Rags Inp-3 No No Low Low N Does not meet significance criteria NA NA Gloves Inp-3 No No Low Low N Does not meet significance criteria NA NA Tyvek coverall Inp-3 No No Low Low N Does not meet significance criteria NA NA Filters Inp-3 No No Low Low N Does not meet significance criteria NA NA Sand Paper Inp-3 No No Low Low N Does not meet significance criteria NA NA Chemicals: VOC Content HAP Content

Virgin Coatings (Inp-1) Yes Yes Low NA S Marine Coating Rule, Air Permit C-Maintain Compliance Ongoing


Virgin Thinners (Inp-2) Yes Yes Low NA S Marine Coating Rule, Air Permit C-Maintain Compliance Ongoing





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I = improve Target Air Emissions: Fugitive VOCs Applying Coating (Pro-

7) 40 tons Yes Yes Yes NA S Marine Coating Rule, permits of operate, toxic air emissions rule

I-Reduce Fugitive VOCs, HAPs, and

particulates

10% reduction by January 2004

Fugitive HAPs Applying Coating (Pro-7) 10 tons Yes Yes Yes NA S Marine Coating Rule, permits of



particulates



Applying Coating (Pro-7) 8 tons Yes Yes Yes NA S Marine coating rule, coating permits

to operate, toxic air emissions rule


particulates


Noise/Odor/Radiation: Odor from VOCs fume Applying Coating (Pro-

7) No No Low Low N Does not meet significance criteria NA NA


lbs per year

No No Yes Low S Waste Reduction Program S-Study waste reduction strategy

Complete Study by April 2003

Contaminated Waste Tyrex Suites, Rollers, Brushes, Filter Masks, Paint Stirrers, Drop Clothes, Masking Tape (Out-5), Debris (Out-6)




1,500 gallons Yes Yes Yes NA S RCRA (Title C) C-Maintain Compliance Ongoing

Solid waste, landfill Consolidate contaminate disposables (Pro-12) and debris (Pro-13)

10,000 and

5,000 lbs per year







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I = improve Target Water Discharges: NA Stormwater Discharge: VOC-contaminated water Yes Yes Yes NA S Storm water permit C-Maintain Compliance Ongoing Heavy metal contaminated water

Yes Yes Yes NA S Storm water permit

I-Reduce heavy metal discharge via storm water runoff

Reduce quantity 50% by 2003

Spillage and Other: Transport waste cans, cleaning solvents, contaminated solvents and debris to scrap yard (Pro-14, Pro-18, Pro-19, Pro-20)

5 gallons per year


NA NA

Consolidate equipment cleaning solvent into drums (Pro-16)

10 gallons per year

Yes No Low NA S Volume exceeds “No Spill” Policy limits C-Maintain Compliance Ongoing

Spillage

Transport coatings and thinners (Pro-1 through Pro-6)

No No Low Low N Does not meet significance criteria, low spillage volume NA NA


Consolidate Waste (Pro-9)

5 gallons No No Low Low N

Does not meet significance criteria , low volume of spillage, scrap is recycled

NA NA





50 gallons per year




10 gallons per year

Yes No Yes NA N Does not meet significance criteria, low volume of spillage NA NA

Shipbuilding and Ship Repair In dustry - EMS Implementation Guide Revision 3.0 (November 2001)


Module 7: Environmental Management Program(s) Guidance ..................................................................................................................................... 7-2 Tools and Forms ......................................................................................................................... 7-4

Tool 7-1: Environmental Management Program(s) Worksheet ..................................... 7-4 Form 7-1: Sample Form for Environmental Management Program(s).......................... 7-5 Tool 7-2: Sample Procedure for Environmental Review for New Purchases, Processes, and Products ................................................................................................... 7-6 Form 7-2: Sample New Purchase Approval Form for Environmental Review of New Processes, Products, and Activities ......................................................................... 7-7

Examples..................................................................................................................................... 7-8

Example 7-1: Environmental Management Program for Reduction of Fugitive VOC, HAP, and Particulate Emissions ............................................................. 7-8 Example 7-2: Environmental Management Program for Reduction of Solid Waste from the Unmasking Activity.................................................................... 7-11



GUIDANCE

You will ensure the success of your EMS by developing support mechanisms to achieve your environmental policy, objectives, and targets. This module will cover planning for and setting up Environmental Management Programs which are the support mechanisms you will use to help met objectives. Environmental Management Programs (EMPs) EMPs consist of action plans that are necessary to achieve environmental objectives and targets. Therefore, your EMPs should be linked directly to your objectives and targets — that is, each EMP should describe how you will translate your goals and policy commitments into concrete actions so that environmental objectives and targets are achieved. To ensure its effectiveness, each EMP should define:

• the responsibilities for achieving objectives (who will do it?)

• the means for achieving objectives (how will they do it?) • the time frame for achieving those objectives (when?)

Keep in mind that your EMP should be dynamic. For example, consider modifying an EMP when:

• objectives and targets are modified or added; • relevant legal requirements are introduced or changed; • substantial progress in achieving your objectives and targets has been made (or has not

been made); or • your activities, products, services, processes, or facilities change or other issues arise.

Your EMP need not be compiled into a single document. A “road map” to several action plans is an acceptable alternative, as long as the key responsibilities, tactical steps, resource needs, and schedules are defined adequately in these other documents.

Objectives and Targets Established

Environmental Management Program(s)

Defined

Monitoring and Measurement



EMPs should not be developed in a vacuum — they should be coordinated or integrated with other organizational plans, strategies, and budgets. For example, if you are planning for a major expansion in one of your service operations, then it makes sense to look at the possible environmental issues associated with this operational expansion at the same time. Hints:

• Build on the plans and programs you have now for compliance, health & safety, or quality management.

• Involve your employees early in establishing and carrying out the program. • Clearly communicate the expectations and responsibilities defined in the EMP to those

who need to know. • In some cases, an EMP may encompass a number of existing operating procedures or

work instructions for particular operations or activities. In other cases, new operating procedures or work instructions might be required to implement the program.

• Re-evaluate your EMP when you are considering changes to your activities, products, services, processes, facilities or materials. Make this re-evaluation part of your change management process.

• Keep EMPs simple and focus on continual improvement over time. There may be real opportunities here! Coordinating your EMP(s) with your overall plans and strategies may position your organization to exploit some significant cost-saving opportunities. Environmental Review for New Products, Processes, and Activities Change is an important part of business survival for most companies. Products, technologies, and ways of doing things are updated regularly. To avoid creating new “significant environmental aspects” that must be addressed later, it is helpful to integrate new processes, products, and activities into the environmental efforts that you are developing for the rest of your company. You can do so by setting up a procedure for reviewing new processes, products, or activities while they are in the planning stage (see Tool 7-2, Sample Procedure for Environmental Review for New Purchases, Processes, and Products). The procedure can include a form that must be circulated among the people responsible for, or affected by, the new process or product, including those responsible for the area of the company where the new process or activity will be implemented. This form will then be signed by the appropriate parties to indicate that the environmental review has been completed in accordance with your procedure.



TOOLS This section provides worksheets and tools to develop an effective environmental management programs and EMS tracking systems for an environmental review process for new processes, purchases, and products. Tool 7-1: Environmental Management Program(s) Worksheet

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

What environmental management programs do we have in place now?

What is the basis for our environmental management programs (for example, do they consider our environmental objectives, our environmental policy commitments and other organizational priorities)?

Who needs to be involved in the design and implementation of these programs within our organization?

When is the best time for us to establish and review such programs? Can this effort be linked to an existing organization process (such as our budget, planning or auditing cycles?)

How do we ensure that changes to products, processes, equipment and infrastructure are considered in our programs?

How will we otherwise keep our programs up-to-date?

Our next step on environmental management programs is to …



Form 7-1: Sample Form for Environmental Management Program(s) Area/Department(s): Process: Significant Aspect: Legal & Regulatory Requirement: Action Plan:

Task/Action Items

Responsible Party

Responsibilities Resources Needed

Project Start Date

Project Completion Date Comments/Deliverables

Examples 7-1 and 7-2 provided completed examples of this form for SEAs identified in earlier modules.

Objective: Target: Category : Control/Maintain Improve Study or Investigate



Tool 7-2: Sample Procedure for Environmental Review for New Purchases, Processes, and Products

[Note: This procedure will almost certainly need to be substantially modified in order to fit the situation of your company. Smaller companies may not have a formal new product design or facilities engineering group, for example. The key is to find a way (that can be documented and verified, if possible) of ensuring that when new chemicals are being purchased, when new products are being developed, or when a facility is being substantially modified, environmental considerations are taken into account. Purpose When purchasing new chemical supplies, modifying its processes, and making new products, [Your Facility’s Name] strives to ensure that environmental considerations, particularly those related to significant environmental aspects (SEAs), are taken into account. Procedure 1. When processing an order for a new chemical or other potentially harmful input, the purchasing

manager clears the purchase with a member of the Cross Functional Team (CFT). The CFT member initials the box marked “environmental approval” in the New Purchase Approval Form (Form 7-2) to signify his or her approval of the purchase.

2. [Your Facility’s Name] has a product development group (PDG) and a facilities engineering

group. The PDG develops potential new products that [Your Facility’s Name] could offer (sometimes these are identified by the sales and marketing group, sometimes they are identified internally). The facilities engineering group is responsible for reconfiguring (or, in some cases, expanding) the facility’s production lines to produce new products.

3. The PDG notifies a member of the CFTe before final approval of a new product design. The CFT

member reviews the design in light of the facility’s SEAs and environmental objectives and targets. When the CFT member is satisfied that the new design is in accordance with the plant’s environmental goals, he or she initials the appropriate box in the Design Approval Form that is sent to the president for approval.

4. The facilities engineering group is responsible for notifying a member of the CFT before final

approval of any Facility Modification or Expansion Plan. (The Facility Modification or Expansion Plan is required for any facilities engineering job that costs more than $20,000.) The CFT member reviews the plan in light of the facility’s SEAs and environmental objectives and targets. When the CFT member is satisfied that the new design is in accordance with the plant’s environmental management goals, he or she initials the appropriate box in the Facility Modification or Expansion Plan form that is sent to the operations manager for ultimate approval.

Frequency As new chemicals are purchased, new products are developed, and/or production lines are modified. Records The New Purchase Approval Forms (Form 7-2) are maintained by the purchasing manager. The Design Approval Forms are maintained by the product development group. The Facility Modification or Expansion Plans are maintained by the facilities engineering group.



Form 7-2: Sample New Purchase Approval Form for Environmental Review of New Processes, Products, and Activities This is an example of a sign-off form that can be used for such reviews. It is a model that should be modified to reflect your company’s activities and environmental policy.

Functional

New Process, Product, or Activity

Environmental Review by

Environmental Effects

Pollution Prevention Opportunities

Manager/Date

Contact for form: Date Completed:



EXAMPLES

Example 7-1: EMP for Reduction of Fugitive VOC, HAP, and Particulate Emissions Note: This example continues drydock evaluation from Example 5-2, Identification of Aspects and Significance Determination and Example 6-2, Objectives and Targets. Area/Department(s): Construction and Repair (see Example 5-1) - Painting Process: Drydock Painting. Significant Environmental Aspect: Fugitive VOCs, HAPs, and particulates Legal & Regulatory Requirement: Marine Coating Rule, permits to operate, toxic air emissions rule No. 1 Action Plan: Substitution of Raw Materials

Task/Action Items Responsible Party Resources Needed

Project Start Date

Project Completion Date Comments (C)/Deliverables (D)

Identify list of suitable vendors that supply low VOCs paint

John Smith, Environmental

Manager

MSDS Paint Mfg. Assoc,

March 1, 2002

April 1, 2002 D – List of potential vendors of low-VOC paint

Objective: Reduce Fugitive VOC, HAP, and particulate emissions Target: 10% Reduction by January 2004 (relative to year 2000 baseline) Category: Control/Maintain Improve Study or Investigate

X X




Project Start Date


Develop evaluation of technical feasibility and cost effectiveness of select paint products.

Cross Functional Team

Testing by paint personnel, customer approval

May 1, 2002 July 1, 2002 D – Comparative cost analysis of select low-VOC paint application D – Technical feasibility analysis of select low-VOC paint application

No. 2 Action Plan: Process Modification


Project Start Date


Identify process modification that can be done to reduce emissions of VOCs, HAPs, and particualtes

John Smith, Environmental Manager

Eng. Dept, vendor proposals

August 1, 2002

August 31, 2002 D – List of potential process modification

Develop preliminary evaluation on technical feasibility and cost effectiveness of process modification alternatives

John Smith, Environmental Manager

Vendor quotes, est. of reductions from support agency

September 1, 2002

September 30, 2002

D – Technical feasibility report of process modification alternatives D – Comparative cost analysis of process modification alternatives

Conduct pilot test of the preferred alternative of process modification

Kim Weinstein, Environmental Department

Process and eng. dept.

October 1, 2002

January 1, 2003

D – Workplan of the pilot test D – Weekly progress report of the pilot test D – Final report and recommendation

Full scale implementation

John Smith and Will Gibson (Paint Department)

Training by vendor, testing

February 2003

D – Quarterly progress and performance report



Example 7-2: Environmental Management Program for Solid Waste Reduction from the Unmasking Activity Area/Department(s): Painting Process: Block painting process Significant Aspect: Solid waste from the unmasking activity Legal & Regulatory Requirement: Yes (40CFR, State rules and regulations, Company Directive) No. 1 Action Plan: Study of Potential Waste Reduction

Task/Action Items Responsible Party

Resources Needed

Project Start Date


Identify potential waste reduction initiatives

John Smith, Environmental

Manger

Web sites on poll. Prevention

August 1, 2001

October 1, 2001 D – List of steps to be taken to fulfill initiative and responsibilities

Identify list of suitable technology to achieve volume reduction

Cross-Functional

Team

Vendors October 1, 2001

October 31,, 2001 D – List of potential technology

Identify list of suitable vendors to supply technology for volume reduction

Cross-Functional

Team

Vendors, testing with plant personnel

November 1, 2001

November 31, 2001 D – list of potential vendors of compactors and waste compaction technology

Develop evaluation on technical feasibility and cost effectiveness of select

Cross- Functional

Team

Acctg. Dept. input, data from env.

December 1, 2001

February 1, 2002 D – Comparative cost analysis of compactor technology D – Technical feasibility analysis of select

Objective: Study Waste Reduction Target: Complete study by April 2003 Category: Control/Maintain Improve Study or Investigate

X



Task/Action Items Responsible Party

Resources Needed

Project Start Date


compacting products (continued from previous page)

dept on current masking waste volume

compactor technology

Present recommendation to management for waste reduction

Cross-Functional

Team

Slide presentation, mtg time

March 1, 2002

March 31, 2002 D – list of evaluations and recommendations for waste reduction


EMS Implementation

EMS IMPLEMENTATION

The EMS Implementation section includes 6 of the 18 modules. Ø Module 8: Training, Awareness, and Competence Ø Module 9: Communications Ø Module 10: EMS Documentation Ø Module 11: Document Control Ø Module 12: Operational Control Ø Module 13: Emergency Preparedness and Response


EMS Implementation Module 8 - 1

Module 8: Training, Awareness, And Competence Guidance ..................................................................................................................................... 8-2

Figure 8-1: Two Areas of EMS Training ....................................................................... 8-2 Tools and Forms ......................................................................................................................... 8-4

Tool 8-1: Training, Awareness & Competence Worksheet............................................ 8-4 Tool 8-2: Sample Procedure for Environmental Training .............................................. 8-5 Form 8-2: Sample Training Needs Analysis Form......................................................... 8-7

Examples..................................................................................................................................... 8-8

Example 8-1: Training Needs Analysis Form................................................................ 8-9



GUIDANCE

Here are two excellent reasons for training employees about environmental management and your EMS:

• Every employee can have potential impacts on the environment, and • Any employee can have good ideas about how to improve environmental management

efforts. Each person and function within your organization can play a role in environmental management. For this reason, your training program should cast a wide net. Every employee and manager should be aware of the environmental policy, the significant environmental aspects (SEAs) of their work activities, key EMS roles and responsibilities, procedures that apply to their work, and the importance of conformance with EMS requirements. Employees also should understand the potential consequences of not following EMS requirements (such as spills, releases, and fines or other penalties). All personnel should receive appropriate training and support to be competent at their work. Training should be tailored to the different needs of various levels or functions in the organization. However, training is just one element of establishing competence, which is typically based on a combination of education, training, and experience. For certain jobs (particularly tasks that can cause significant environmental aspects), you should establish criteria to measure the competence of individuals performing those tasks. Training is needed both in technical work and for general awareness on the part of all employees.

Figure 8-1. Two Areas of EMS Training

AWARENESS (All employees)

TASK-SPECIFIC (For employees associated with

SEAs)



Getting Started Go through the Action Steps listed below and use Tool 8-1 to help you identify, plan for, and track the training needed to assist in developing and implementing your EMS. You can probably identify some general training needs now, but will need to return to this module to add specific technical training needs that may be identified as you proceed with the EMS. (For example, you will have specific training requirements associated with operational controls for SEAs. Training plans developed during completion of Module 12: Operational Controls should be integrated with the training identified in this module.)

Action Steps

1. Identify all job functions that affect the environment. Small companies may wish to identify individuals. Identify who is responsible for employee health and safety.

2. Identify the training and type of training these people currently receive that relates to

environmental and health and safety concerns.

3. Determine if EMS education could be integrated with existing training or whether there should be special EMS training, at least in the beginning.

4. Identify training materials or programs available outside your company. Some places

to check include:

< Trade Associations < Small Business Administration < EPA < State Departments of Environmental Protection < Suppliers < Certified Contractors < Navy (Note: Materials from the Navy’s Occupational Safety, Health, and

Environmental Training Program can be found on the internet at http://www.oshelink.com)

L Tip Don’t overlook the need for on-going training when experiencing employee turnover. Be sure that new employees are trained soon after they arrive. Tool 8-2 provides a sample procedure for environmental training and Form 8-2 is a sample Training Needs Analysis Form.



TOOLS Tool 8-1: Training, Awareness & Competence Worksheet Do we have an existing process for environmental training? If so, does that process need to be revised? In what way(s)?

What types of training do we provide now (e.g., new employee orientation, contractor training, safety training)? How would EMS-related training fit with our existing training program?

Who is responsible for training now? Who else might need to be involved within our organization?

How do we determine training needs now? (List methods used). Are these processes effective?

Who is responsible for ensuring that employees receive appropriate training? How do we track training to ensure we are on target?

How do we evaluate training effectiveness? (List methods used, such as course evaluation, post-training testing, behavior observation, etc).

How do we establish competency, where needed? (List methods used, such as professional certifications). What are the key job functions and activities where we need to ensure environmental competency?

Our next step on training, awareness & competence is to …



Tool 8-2: Sample Procedure for Environmental Training (Awareness and Task-Specific)

Purpose To ensure that its employees carry out their duties in as environmentally responsible a manner as possible, [Your Facility’s Name] provides all employees with environmental awareness training on environmental issues and provides task-specific training to those employees whose jobs are associated with significant environmental aspects. Form 8-2 will be used to document [Your Facility’s Name]’s training needs analysis. Procedure Awareness Training: 1. All new employees receive a 15-minute introduction to the [Your Facility’s Name]’s

EMS, specifically its environmental policy, significant environmental aspects (SEAs), and environmental objectives. This introduction, which includes an opportunity for the new employees to ask questions about the EMS, is given by the human resources (HR) manager as part of his or her general orientation for new employees. Records of employees who have received this introduction are maintained by the HR department.

2. Each year employees are invited to a company picnic. One of the scheduled events for

this picnic is a 15 minute talk by a member of [Your Facility’s Name]’s EMS cross functional team (CFT). This person speaks about the environmental accomplishments of [Your Facility’s Name], the state of its EMS, and the goals for the coming year. These remarks provide an update to the initial EMS awareness training received by employees.

Task-Specific Training: 3. Using root cause analysis as a tool, the CFT, working in coordination with the

appropriate operations managers, identifies the job functions that are associated significantly with each SEA.

4. The CFT, in conjunction with the relevant operations manager, then determines what

training employees performing each of these job functions should receive in order to control actual environmental impacts to the greatest possible extent.

5. Operations managers are responsible for ensuring that their employees receive the

appropriate task-specific environmental training. Where possible, environmental training is integrated with other types of training (e.g., operational) that employees receive. The HR manager keeps records of the training received by each employee.



Frequency Awareness training is given to new employees during their first week at [Your Facility’s Name]. Task-specific training is given to relevant employees as they take on a new function that is associated with a SEA. Task-specific training is updated, as necessary. Records Records of the awareness and task-specific training received by each employee are kept by the Human Resource manager. Form 8-2 documenting the training needs analysis shall also be maintained by the Human Resource manager.



Form 8-2: Sample Training Needs Analysis Form

[FACILITY NAME]

Date:

Course Employees Requiring Training

Source of Training

Duration (Hours)

Frequency Schedule/ Status

Form No.: Issue Date: Revision Date: See Example 8-1 for an example of how to fill out this form.



EXAMPLES


EMS Implementation Module 8 -9

Example 8-1: Training Needs Analysis Form [FACILITY NAME]

Date:

Course Employees Requiring Training Source of Training

Duration (Hours)

Frequency Schedule/ Status

A/C Refrigeration Servicing (Stationary) Central Maint. Specific ABC Training Institute

4 + Pre-study pack Once As needed based upon new assignments

HAZWOPER: First Responder Operations Level

Security Team CDF University 8 Annual 3rd qtr 2002

Stormwater Poll. Pre. Plan – Certified Operator Env. Engineer Your State DEQ Approx. 8, MI program

Once Req’t has been meet

Environmental Awareness (Addresses awareness requirement of: Air Episode Plan, Asbestos Mgt., Bulk Materials, RCRA -Hazardous Waste: LQG, HAZWOPER 1 st Responder Awareness, PCB Mgt., SPCC, Stormwater Poll. Prev. Plan, Integrated Emergency Response Plan, Toxic Organic Mgt. Plan, Waste Management)

Central Maint. (inc. Cleaners) Central Maint. Specific WWTP Operators Security Env. Engineer Paint Salaried Paint Hourly Medical Material Salaried Material Hourly

{Facility Name} Training Department

2 Annually 3rd qtr 2002

Material Management – Function Specific (Addresses more detailed function-specific training requirements of: Bulk Materials, RCRA – Hazardous Waste: LQG, SPCC, Stormwater Poll. Prev. Plan, Integrated Emergency Response Plan, Toxic Organic Mgt. Plan, Waste Management)

Central Maint. (inc. Cleaners) Central Maint. Specific WWTP Operators Security Env. Engineer Paint Salaried Paint Hourly Material Salaried Material Hourly

Integrated Waste Manager

2 Annual 4th qtr 2002

EMS Awareness Training Facility Wide {Facility Name} Training Department

Approx. 30 min. Initially, new hires and when changes in

system occur

Jan. 2001 May 1, 2001, then ongoing

EMS Work Instruction (WI) Training Facility personnel whose work requires use of WIs (determined by Department Supervisor)

{Facility Name} Training Department

1 hour Initially, when WIs change new hires

Mar. – May 2001

EMS Department Supervisor Training Department Supervisors {Facility Name} Training Department

Approx. 1 hour Initially, new hires April 20 01

ISO 14001 Lead Assessor Training EMS Coordinator (Env. Engineer) ABC Training Institute

40 hours Initially Completed

ISO 14001 Internal Auditor Training EMS Audit Team CDF University 24 hours Initially, new auditors Initial training done Form No.: Issue Date: Revision Date:



Module 9: Communication Guidance ..................................................................................................................................... 9-2

Figure 9-1: Levels of Stakeholder Interest..................................................................... 9-4 Tools and Forms ......................................................................................................................... 9-7

Tool 9-1a: Communications Worksheet........................................................................ 9-7 Tool 9-1b: Sample Communications Program Matrix .................................................. 9-8 Tool 9-2: Sample Procedure for Communication with Stakeholders .......................... 9-9 Form 9-2a: Sample Form for Stakeholders and Environmental Issues ....................... 9-10 Form 9-2b: Sample Form for External Stakeholder Communication Record ............. 9-11

Examples................................................................................................................................... 9-12

Example 9-1: Case Study – Working with Stakeholders ............................................. 9-12 Example 9-2: Communications Program Matrix ......................................................... 9-13



GUIDANCE

An EMS should provide a means for internal and external communication. Internal communication should identify, explain, and communicate environmental requirements and voluntary undertakings to all employees, on-site service providers, and contractors whose work could affect your ability to meet those requirements and undertakings. Environmental requirements include statutes, regulations, permits, and enforceable agreements. Voluntary undertakings include any environmental principles or industry norms that an organization may choose to adopt. Examples of voluntary undertakings include voluntary codes of practice for safety, risk management, and energy efficiency issues, or sectoral and international environmental principles such as the Coalition for Environmentally Responsible Economies (CERES) principles or the International Chamber of Commerce Business Charter for Sustainable Development, among others. External communication can provide other stakeholders with information on your environmental programs and accomplishments and provide a means for external parties to comment or provide input to you. Working with Stakeholders Stakeholders include anyone who has a stake in your company’s environmental performance. Internal and external stakeholders can play an important role in helping your company develop an EMS. Employees have a strong stakeholder interest in your company and can provide strong support for EMS development. Customers, suppliers, and neighbors also can provide useful inputs. In addition, establishing partnerships with trade associations, suppliers, professional associations, and universities can be very helpful in developing parts of your EMS. This module will help you identify the kinds of stakeholders you may wish to include in the process, the potential benefits of including stakeholders, and tips for better communication with stakeholders. While involvement of employees is critical to the success of your EMS, how far you proceed with including additional stakeholders is your decision. Identifying and Understanding Stakeholders Almost every organization will have a wide array of internal and external groups that may be interested in, and helpful partners to, that organization. These groups will not be homogenous. Each will have its own priorities and perspectives and each will have something different to contribute in support of your EMS. Part of communication is identifying and understanding these parties over time. Two types of stakeholders are discussed in this module: internal and external.



Examples of internal and external stakeholders are provided below:

Internal Stakeholders • Employees • Shareholders • Customers • Suppliers • Investors & Insurers • Trading Partners

External Stakeholders • Neighbors • Community Organizations • Environmental Groups • Larger Companies • The Media • The General Public

You may want to start by communicating with those stakeholders who have expressed interest in your operations. If you desire additional input, you might take the following steps in your effort to locate suitable stakeholders:

• ask your employees, including plant/site managers and public relations personnel; • obtain suggestions from local officials; • contact a local planning agency for suggestions; or • get input from a national advocacy group regarding local or national groups that may be

interested/suitable. Stakeholder Roles Before engaging stakeholders, be clear on what you expect their role to be. Consider why you want to include internal and external stakeholders and what roles they can play. What do you want from them? What do you intend to tell them? Consider the following:

• Internal stakeholder (e.g., employee) participation can facilitate implementation of environmental projects as employees “take ownership” of the EMS and the changes it may bring.

• Different stakeholders bring useful perspectives to environmental issues, often identifying issues that might otherwise have been overlooked.

• Participation by all types of stakeholders can add credibility, transparency and value to your EMS.

• Involving external stakeholders can help them understand your business’ operating constraints.

• Sometimes being an environmental leader can confer customer recognition and loyalty, and involving customers in your EMS helps them recognize your leadership.

• Forming partnerships with customers and suppliers can help to identify shared concerns and ways to cooperate to resolve them. There may be ways that your company can help your customers meet their environmental management needs. Forming partnerships with suppliers can help your company obtain important information and may help you meet your EMS goals.



How to Work with Your Stakeholders The next stage of the process is to communicate with stakeholders. This provides an opportunity to further refine your understanding of their interests. Develop stakeholder participation in stages and learn as you go. You might think about the different kinds of stakeholders as forming ever-broader circles around your business (see Figure 9-1). Begin with the innermost circle and work outward.

Figure 9-1. Levels of Stakeholder Interest

L Tip Create and maintain a list of everyone you can think of who would be interested in your facility’s environmental activities. Include how you could reach them (for example, if you already have established ways of communicating with certain groups, you might start with those). You can then make a decision about where to begin. You could start with staff and later add other stakeholders if that suits your capabilities and needs. It is helpful to make your communication list as complete as possible, and then pare it down to a manageable list as you start out. Begin small, and then you can use the list to expand when ready. L Tip Remember, your stakeholders’ concerns may be very different from what you expect, and may be less difficult to resolve than you may think. The only way to find out is to talk with them.

Neighbors

Customers/

Staff

Suppliers



Hints for Effective Communication When working with either internal or external stakeholders, including your Cross Functional Team (CFT), effective communication will facilitate smooth implementation of your EMS. You will want to follow these effective rules of communication: 1. Begin early in the process. Let people know what you are doing. In most cases, you will need the cooperation of several people within your company to gather information and develop an EMS that works. In small and large organizations, early communication will pay off in greater acceptance of the resulting system. 2. Set communication objectives. Decide what you want to achieve. Setting goals will help you get the right message across without overwhelming people with too much information, spending too much time, or missing the mark. It is helpful to create an EMS communication procedure for your company. The procedure should outline what kinds of information will be communicated to external stakeholders, and how the company will document and respond to communications from external stakeholders. It should include communication for emergency and preparedness and response stakeholders. It can also address internal stakeholder communication principles. 3. Communicate regularly and integrate EMS communication with other efforts. To build support for the EMS, communicate on a regular basis. Some simple means of regular communication can usually be accomplished without straining resources – for example, a bulletin board posting, email messages, or articles in the organization newsletter. Don’t forget to consider direct word-of-mouth communication, particularly in smaller organizations. Talking directly with key individuals at regular intervals may be the best mechanism for ensuring good communication. Use existing channels of communication to communicate your EMS activities. Consider various methods of regular communication with stakeholders about your company and your environmental efforts and goals. These methods can build on existing methods, such as:

• discussing the EMS at company meetings; • updating the company website or including as part of your annual report; • scheduling tours of your facility; • producing a fact sheet about your facility’s activities, the EMS program, and why and

how your company would like to include stakeholders; • establishing a phone line to answer questions, record concerns, etc.; • holding public meetings when you feel it is appropriate.

L Tip Make use of current technology. A company website can be used to communicate your company’s environmental policy and other important elements of your EMS. It can also be used to solicit comments and suggestions from stakeholders.



4. Ensure that stakeholder dialogue is a two-way process. The stakeholders will want to know that their comments and concerns are being listened to and taken into account. You need to convey that your organization is genuinely interested in their input and explain how you will include them. 5. Track communication. You should develop a procedure for documenting and responding to stakeholder communication. This will help you track input from stakeholders and documentation of your responses or efforts. Also, a person should be appointed to be responsible for carrying out your communication procedure. Tool 9-2 provides a sample procedure for communication with stakeholders.



TOOLS Tool 9-1a: Communications Worksheet

Who are our key external stakeholders? How were these stakeholders identified?

With regard to our organization, what are the key concerns of these stakeholders? How do we know this?

What community outreach efforts are we making now (or have we made in the recent past)? How successful have these efforts been?

What methods do we use for external communications? Which appear to be the most effective ? Who has primary responsibility for external communications?

How do we gather and analyze information to be communicated? Who has responsibility for this?

How do we communicate internally (as well as with our suppliers and contractors)? What processes do we have to respond to internal inquiries , concerns and suggestions? How effective are these methods?

Our next step on communication is to …



Tool 9-1b: Sample Communications Program Matrix

Stakeholder(s)

Potential Environmental

Interest

What We Want to

Tell Them

What We Want Them to Tell Us

How We Will Communicate With/

Tell Them

When We Will

Do It

Person

Responsible

See Example 9-2a for an example of how to fill out this matrix (note: not all columns are repeated on Example 9-2a).



Tool 9-2: Sample Procedure for Communication with Stakeholders

Purpose To ensure that stakeholders receive appropriate information about, and can provide input regarding, environmental activities, [Your Facility’s Name] has developed this company policy for considering and, where appropriate, responding to queries, comments, or complaints from stakeholders. Both internal and external stakeholders are addressed. Procedure 1. The cross functional team (CFT) will identify stakeholders and their potential interests in

the environmental performance of [Your Facility’s Name] using Form 9-2a. The CFT also determines what communication on SEAs will occur and records its decision on Form 9-2a. If the CFT decides that proactive communication on environmental issues is necessary with any group, that decision is recorded on Form 9-2a and responsibility is designated. Internal stakeholder communication is addressed through a variety of elements of our EMS such as training, objectives and targets, and implementation that all require internal stakeholder communication.

2. Internal communication is documented as appropriate for EMS needs. When any form of

communication is received from external stakeholders regarding our environmental performance or management, that communication is immediately forwarded to the Environmental Management Representative (EMR). The EMR also maintains communication with response agencies as outlined in Module 13.

3. The EMR considers the nature of any external stakeholder communication and makes a

decision on whether and how to respond, based on the guidance in Form 9-2a. The EMR is responsible for maintaining records of each external stakeholder communication and response using Form 9-2b, Stakeholder Communication Record. Where internal actions are necessary to address nonconformance with this procedure, this is noted on Form 9-2b and a Corrective and Preventive Action Notice (CAPAN) is initiated using Form 15-2a.

Guidance for Communicating with Stakeholders on Environmental Issues: This facility’s environmental policy will be made available to all stakeholders upon request. Our facility also will do its best, to respond in kind to all good-faith communications from stakeholders about environmental issues. However, our facility (under guidance of EMR) may choose not to respond in all cases, particularly if a request is made in bad faith or if sensitive data is requested. Frequency On an as-needed basis for external input, and as shown on Form 9-2a. Records Records of environmental communications from external stakeholders and our corporation’s responses are kept by the EMR and are tracked using Form 9-2b. An updated version of Form 9-2a, Stakeholders and Environmental Issues, is kept in the EMS manual.



Form 9-2a: Sample Form for Stakeholders and Environmental Issues

Stakeholder(s)

Potential Environmental Interest

Communication Plan And Basis*

(with frequency, as applicable)

Person Responsible

* The communication plan may include a decision not to do outreach at this time. This form should document that communication to external stakeholders regarding significant environmental aspects was considered (whether or not outreach is undertaken at this time). Contact Person: Date Completed:



Form 9-2b: Sample Form for External Stakeholder Communication Record

External Stakeholder Communication Record

Date Communication Received

Type of Communication

Received From

Address/Telephone Number/ E-Mail

Content of Communication. Copy attached? YES NO (attach copy if possible). Will We Respond? YES NO

Date of Response

Person Responding

Position

Nature of Response. Copy attached? YES NO (attach copy if possible). Are Internal Actions Necessary? YES NO (If Yes, fill out a Corrective and Preventive Action Notice (see Module 15)




EXAMPLES Example 9-1: Case Study—Working with Stakeholders The following Case Study shows how “Company B” set up a process to train and use employees (internal stakeholders) to identify environmental concerns and some of the benefits achieved.

Case Study: Company B--Working With Stakeholders Company B is a 50-person company that does ship repair. With senior management backing and support from a local consultant, Company B focused initially on building environmental awareness among its employees. Company B offered general environmental awareness training to all workers and managers and additional training on how to identify specific environmental issues. Employees then were divided into 10 teams, each charged with identifying the environmental issues associated with a specific area of operation, from the acquisition of raw materials through to delivery of the product. Using this input, Company B developed a list of its most important environmental issues and concrete objectives and plans for improvement. The key to Company B’s success lay in using participatory teams to identify new environmental issues and develop solutions. For example, the company identified environmental impacts of abrasive blasting, and teams from more than one area found ways of reducing these impacts. Company B now has a process by which it routinely inspects and cleans sediment traps and drains to ensure containment of spent material. It also enhanced its training of new employees and contractors that do abrasive blasting on proper abrasive blasting methods, proper material handling, reducing floatable solids, and practicing good house keeping. Employees whose jobs included filling abrasive blasting containers recommended the installation of particulate suppression equipment on vents to minimize emissions when containers were being filled. Other benefits Company B has realized include improved compliance, a safer work environment, and reduced emissions from its transport vehicles thanks to improved maintenance. The environmental awareness of all employees has increased significantly, with some workers extending their new-found environmental awareness to their homes. The company has also publicized its implementation of an EMS to the local community in an effort to improve its community relations and to help improve the environmental awareness of the community.



Example 9-2: Communications Program Matrix

Stakeholder(s)

Potential or Known Environmental Interest

What We Want to Tell Them:

What We Want Them to Tell Us:

How we Will Communicate with/Tell

Them:

When We Will Tell Them

Person Responsible

Employees Ø Safety for workers

Ø Protection of environment

Ø Competitiveness

Environmental policy

How to get it done Memo, bulletin board, meetings, suggestion box, intranet

Initial training for new employees, EMS update at annual picnic, as needed per training program for specific workers

EMR, CFT, and training personnel

Neighbors Ø Our expansion on north side of ship yard, near residences

Ø Run off into creek behind electrical shop

Environmental policy and EMS plans

Their environmental concerns, particularly regarding planned expansion

Meetings, open house, flyers, suggestion box, web site

Town meeting in November (for expansion discussion)

Annual open house

Web site (ongoing)

EMR with communications representative (as appropriate)

Customers Ø Major client considering requiring EMS for suppliers

Environmental policy and EMS plans

Specific EMS requirements that might ensue

Above, plus inserts in direct mail advertising, or invoices and on our web site

Ongoing and as billing occurs

Marketing lead and company president


Example 9-2 above provides an example of how to complete Tool 9-1b.



Module 10: EMS Documentation Guidance ................................................................................................................................... 10-2 Tools and Forms ....................................................................................................................... 10-6

Tool 10-1: EMS Documentation Worksheet ................................................................ 10-6 Tool 10-2: Sample Worksheet for Development of EMS Documentation................... 10-7 Tool 10-3: Sample Outline for EMS Manual and Other EMS Documents .................. 10-8 Tool 10-4: Sample Procedure for EMS Documentation............................................... 10-9



GUIDANCE

Documentation is manifested in the EMS Manual and other documents that are used to develop the EMS Manual. Documentation is important to the success of your EMS for several reasons:

• Consistency. Word-of-mouth information is rarely communicated consistently, whereas written information is more likely to be constant from person to person and over time. Documentation is vital to maintaining consistency in an EMS over time and from department to department. In most companies, change is a fact of life; new projects are undertaken, the company grows, and employees change positions or leave the company. Accurate documentation will make it much easier to maintain an effective and flexible EMS during these changes.

• Assessment of Progress. Creating documentation helps you assess the progress of your EMS. Some inconsistencies show up only as you commit your ideas to paper and having a record allows you to check on progress and evaluate results.

• Demonstration. If you want to certify your EMS (for example, to the ISO 14001 standard) or enter a recognition program such as those under EPA’s Performance Track, you must demonstrate that you EMS is complete and functioning. In this case, your EMS documentation may be audited or reviewed.

The EMS Manual An EMS manual is a series of explanations of the processes your organization implements to conform to the EMS criteria (such as the elements discussed in this Guide). While you don’t need to maintain a single “manual” that contains all of your EMS documentation, you should maintain a summary of the EMS that:

• describes the system’s core elements (and how the elements relate to each other), and • provides direction to related documentation.

Other EMS Documentation In addition to the EMS manual, your organization should maintain other documentation of its EMS. You should document the processes used to meet the EMS criteria. (For example, “How do we identify environmental aspects?” “How do we implement corrective actions?”) This documentation generally takes the form of system procedures. In addition, you might maintain area-or activity-specific documentation (such as work instructions) that direct employees on how to carry out certain operations or activities.



EMS documentation is related to (but not the same as) EMS records . ü EMS documentation describes what your system consists of (i.e., what you do and how

you do it), while ü EMS records demonstrate that you are doing what the documentation said you would

do. Records management is discussed later in this Guide (see Module 16).

L Tip Keep EMS documentation simple. Your manual does not need to describe every detail of your EMS. Instead, the manual can provide references to other documents or procedures. EMS documentation should be updated as needed, based on any system improvements you put in place. However, if you put too much detail in an EMS manual, you might need to update the manual frequently.

What Constitutes EMS Documentation? Consider the following:

• your environmental policy

• your organizational chart or lists/tables of key responsibilities

• a description or summary of how your organization satisfies EMS requirements (e.g., “How do we identify environmental aspects?” “How do we identify and comply with lega l requirements?” “How do we control documents?”)

• system-level procedures (for example, procedure for corrective and preventive action)

• activity- or process-specific operational control procedures/work instructions

• other EMS-related documents (such as emergency preparedness and response plans, training plans, etc.)



How to Develop Your Documentation Step 1: Determine how EMS documentation can be integrated into existing documents. Before you dive into your documentation, learn how deep the water is. Find out what documentation already exists, what its purpose is, and whether it works. The goal of this search is to locate materials you can use to begin your EMS implementation and documentation. Many facilities use the same format for all of their documents. An example of existing documentation might be a quality plan or tracking report. See Tool 10-1 through Tool 10-4 will assist you in developing EMS documentation while following these steps. Step 2: Tailor the documentation to your organization’s needs. You will probably have to compromise in producing documentation that meets your needs while also meeting your budget. Here are some questions to help you determine what fits your needs:

• How can we use or revise existing documents rather than creating new ones? • Does our business operate in a single location or many? This will affect who creates

some of the documents and where they are located. It may also affect how many versions of a document might be necessary to cover different circumstances.

• What is our current computer capability? Many companies use an electronic system to maintain documents.

• What security precautions do we need? While computer systems are handy, they often can be accessed by a number of people. Electronic documentation can be edited or destroyed. Security, or at least restrictions on who can change data, can be a critical issue for many companies that use electronic documentation systems.

Step 3: Determine a standard format for all documents. Before developing your EMS documents, plan the format (document and page appearance) for the documents. If a company standard exists, use it. If not, the need for EMS documentation provides an opportunity to create a standard company format. Consider whether pages are single- or double-sided and why; choose margins, header, footer, typefaces, text, headings, etc. Include plans for bulleted and numbered lists, tables, and even paragraph spacing. Once you have a consistent format for documents, anyone who writes one will use the established format and fill in the necessary text. All documents will look like part of an organized, integrated system. Most importantly, documents will be easier to read and understand! L Tip Not all documentation needs to be text. Some shops use signs above the appropriate equipment for some work instructions (like a no dumping sign above a storm drain). Sometimes, bilingual text may be needed. Consider the needs of the user; if its not understood, it won’t be implemented.



Step 4: Prototype each document. Prototyping means visualizing what you will need in the document and creating an outline for it before you actually have information to fill in. This is like drafting a document, but in an outline fashion. As you consider what is needed for the document, you also gain understanding about what you may need to support the EMS. It’s a way of “outlining” your EMS as well as designing documents. The best people to prototype or provide early input to documents, are the people who will use the document. Involving them in the process should help make sure the documents are usable and applied to support the EMS. The following questions will help you plan your documents. Consider these questions for each document you identify as necessary for your company:

• What is the document’s purpose? • Who will use it and how will they use it? • How long should the document be? • What must be included in the document? Which information is most critical? • Is it process-focused? Process focus rather than regulation- or program-focus helps

people who use the documents to better understand how their jobs fit into the rest of the company functions.

• How is the information best arranged? Will the user read sequentially or randomly?



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

Do we have existing documentation of our EMS ? If yes, how is this EMS documentation maintained? (electronically? In paper form?)

Who is responsible for maintaining EMS documentation within our organization?

Do we have an EMS manual or other summary document that describes the key elements of the EMS? If so, does this document describe the linkages among system elements?

What does our EMS documentation consist of? (List components such as environmental policy, EMS manual, activity-level procedures or work instructions, emergency plans, etc.)

Is our EMS documentation integrated with other organizational documentation (such as human resource plans or quality procedures)? If so, how do we ensure proper coordination between environmental and these other functions?

How will we keep our EMS documentation up-to-date?

Our next step on EMS documentation is to …



Tool 10-2: Sample Worksheet for Development of EMS Documentation

Documents

Determine

Format: Who/ Date Completed

Develop Prototype/

Draft: Who/ Date Completed

Assign Writing: Who/ Date

Review Writing/ Compare to

Prototype/Draft: Who/ Date

Added to

Document List/ Date

Who Has Access

Where Located

Existing Documents

/ / / / /

/ / / / /

/ / / / /

/ / / / /

Documents to be Created

/ / / / /

/ / / / /

/ / / / /

/ / / / /




Tool 10-3: Sample Outline for EMS Manual and Other EMS Documents

Basic EMS Manual • Index/Revision History/Distribution List • Environmental Policy • Description of How Our EMS Addresses Each of the EMS Elements (and linkages among these elements)

- How We Identify Significant Environmental Aspects and Determine Significance - How We Identify, Access and Analyze Legal and Other Requirements - How We Establish and Maintain Objectives and Targets - How the Organizational Structure Supports EMS (organization charts, key responsibilities) - How We Train our Employees and Ensure Competence - How We Communicate (internally and externally) - How We Prepare, Revise, and Control EMS Documents - How We Identify Key Processes and Develop Operational Controls for Them - How We Prepare for and Respond to Emergencies - How We Measure and Monitor Key Characteristics of Operations and Activities - How We Identify, Investigate and Correct Nonconformance - etc.

Environmental Management Program(s) Description • Annual Objectives and Targets • EMP(s) (to achieve objectives and targets) • Tracking and Measuring Progress

EMS Procedures • Index/Revision History/Distribution List • Organization-wide Procedures (for some EMS elements there might be more than one procedure)

- Identification and Access to Legal and Other Requirements - Identification of Environmental Aspects and Determination of Significant Environmental Aspects - Identification of Objectives and Targets - Environmental Review for New Purchases, Processes, and Products - Training, Awareness and Competence - Communication (internal and external) - EMS Documentation and Control - Management of Suppliers / Vendors - Operational Control Development - Emergency Preparedness and Response - Compliance Assessment - Corrective and Preventive Action - Records Management - EMS Auditing - Management Review

• Procedures/Work Instructions for Specific Operations or Activities - Waste Management - Wastewater Treatment (These are examples only) - Operation of Abrasive Blasting Equipment

Other EMS Documentation

• Emergency response plans, etc.



Tool 10-4: Sample Procedure for EMS Documentation Purpose To ensure effective operation of the EMS, [Your Facility’s Name] documents the procedures of its EMS and keeps records of the outcomes of EMS processes and of the important environmental issues facing the plant. This EMS manual comprises this documentation. Procedure

1. The Environmental Management Representative (EMR) documents the procedures that define [Your Facility’s Name] EMS in this EMS manual.

2. The Cross Functional Team (CFT) formally reviews and, if necessary, revises this manual on an annual basis.

3. Revised manuals are assigned a new revision number (a minor set of revisions would change the number from, say, 1.1 to 1.2; a major revision would change the number from, say, 1.1 to 2.0). Finally, the EMS Coordinator ensures that no employees or managers use outdated revisions of this manual.

Frequency This EMS Manual will be reviewed and revised on an annual basis. Records The EMS Manual will be maintained as described above.



Module 11: Document Control

Guidance ................................................................................................................................... 11-2 Tools and Forms ....................................................................................................................... 11-4

Tool 11-1: Document Control Worksheet .................................................................... 11-4 Tool 11-2: Sample Procedure for Document Control................................................... 11-5 Form 11-2a: Sample Document Control Form............................................................ 11-6 Form 11-2b: Sample Document Index Form............................................................... 11-7



GUIDANCE

To ensure that personnel are consistently performing their jobs in the right way, the organization must provide them with the proper tools. In the context of an EMS, the “tools” needed are correct and up-to-date procedures, instructions, and other documents. People in your organization probably use various documents (procedures, work instructions, forms, drawings, etc.) as they perform their duties and have some means to manage the documents. You also need to manage documents for your EMS. Without a way to manage these EMS documents, you can’t be sure that people are working with the right tools. To ensure that everyone is working with the proper EMS documents, your organization should have a procedure that describes how such documents are controlled. Implementation of this procedure should ensure that EMS documents:

• can be located (we know where to find them), • are periodically reviewed (we check to make sure they are still valid), • are current versions and available where needed (we make sure the right people have

access to them), and • removed if they are obsolete (people don’t use the wrong documents by mistake).

Your document control procedure should address responsibility and authority for:

1. preparing documents,

2. making changes to them, and

3. keeping them up-to-date.



Hints for Good Document Control

• Don’t make your document control procedure more complicated than it needs to be. While larger organizations often have complex processes for document control, smaller organizations can use simpler processes.

• Limiting distribution can make the job easier. Determine how many copies you really need and where they should be maintained for ease of access.

• If the people that need access to documents are connected to a local area network or have access to the organization’s internal web site, consider using a paperless system. Such systems can facilitate control and revision of documents considerably. There also are a number of commercial software packages that can simplify the document control effort. To avoid edits to documents by unauthorized personnel, you can convert documents to a read-only format (such as pdf) before butting them on the network.

• Prepare a document control index that shows all of your EMS documents and the history of their revision (see Form 11-2b). Include this index in your EMS manual. Also, if multiple paper copies of documents are available at the facility, prepare a distribution list, showing who has each copy and where the copies are located.

• As your procedures or other documents are revised, highlight the changes (by underlining, boldface, etc.). This will make it easier for readers to find the changes.



TOOLS Tool 11-1: Document Control Worksheet

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

Who needs to be involved in this process within our organization?

Who needs access to controlled copies of EMS documents? How do we ensure that they have access?

How do we ensure that EMS documents are periodically reviewed and updated as necessary?

Who has authority to generate new documents or modify existing ones? How is this process managed?

How are users alerted to the existence of new EMS documents or revisions to existing ones?

How do we ensure that obsolete documents are not used?

Is our EMS document control process integrated with other organizational functions (such as quality)? If so, how do we ensure proper coordination between environmental and other functions?

Our next step on document control is to …



Tool 11-2: Sample Procedure for Document Control Purpose To ensure effective operation of the EMS, [Your Facility’s Name] will ensure that EMS documents are easy to find and are kept up-to-date. Procedure 1. The EMS Coordinator maintains updated documents for the following outcomes, or results,

of the functioning of the EMS environmental policy: • Applicability of legal requirements to environmental aspects (Module 4). Copies of the

regulations are maintained by the Environmental Management Representative (EMR). • Environmental aspects and SEAs (Module 5) • Objectives, targets, and action plans for environmental management programs (Modules

6 & 7) • List of operational control procedures related to significant environmental aspects

(Module 12) • Results of internal audits (Module 17) • Corrective and preventive actions taken (Module 15) • Management reviews (Module 18)

2. The EMS Coordinator is not responsible for maintaining records of environmental training and emergency response preparations; the operational control procedures themselves; or the New Purchase Approval Forms, the Design Approval Forms, or the Facility Expansion or Modification Plans. These records are maintained by the appropriate person or group.

3. The EMR or designee will control all EMS documents and records from items 1 and 2

using Form 11-2a: Document Control Form and Form 11-2b: Document Index Form. Frequency Manual review and revision on an annual basis. Records Maintained as outlined in this procedure.

Shipbuilding and Ship Repair Industry - EMS Implementation Guide Revision 3.0 (November 2001))


Form 11-2a: Sample Document Control Form

Document Who Will Use It Permanent Location Periodic Review Schedule/ Who When Can Be Destroyed

/

/

/

/

/

/

/

/

/




Form 11-2b: Sample Document Index Form

Revision Number (with Date and Initial of Responsible Party

Module # Document

1 2 3 4 5 6

3 Environmental Policy

All EMS Manual

4 Procedure: Identification of Legal and Other Requirements

5 Procedure: Identification of Environmental Aspects and Determination of Significance

6 Procedure: Setting Objectives & Targets

7 Procedure: EMPs – Environmental Review for New Purchases, Processes, and Products

8 Procedure: Training

9 Procedure: Communication (internal and external)

10 Procedure: EMS Documentation

11 Procedure: Document Control

12 Procedure: Development of Operational Controls

13 Procedure: Emergency Preparedness and Response

14 Procedure: Compliance Assessment

15 Procedure: Corrective and Preventive Action

16 Procedure: Records Management

17 Procedure: EMS Audits

18 Procedure: Management Reviews

NA Procedure(s) 12-X (list individually)

17 EMS Audit Questionnaire (Example 17-1) and Gap Analysis Form (Example 1-1)

NA Other plans & documents related to above procedures (for example, SPCC, etc. – list separately)

NA Other forms and checklists (list separately under appropriate modules or here)

NA indicates not applicable.



Module 12: Operational Control

Guidance ................................................................................................................................... 12-2

Table 12-1: Partial List of Typical Activity Areas and Operational Controls at Shipbuilding and Ship Repair Facilities ........................................................................ 12-4

Tools and Forms ....................................................................................................................... 12-7

Tool 12-1: Operational Controls Worksheet ................................................................ 12-7 Tool 12-2: Sample Worksheet for Determining Which Operations Require Operational Controls ...................................................................................................... 12-8 Tool 12-3: Sample Worksheet for Operational Control Responsibilities..................... 12-9 Tool 12-4: Sample Worksheet for Training for Operational Controls ....................... 12-10 Tool 12-5: Sample Procedure for Development of Operational Control Procedures .................................................................................................................... 12-11 Form 12-5: Sample Form for EMS Operational Control Procedures ........................ 12-12

Examples................................................................................................................................. 12-13

Example 12-1: Operational Control for Coating and Thinner Use ............................ 12-13



GUIDANCE

To ensure that you satisfy the commitments in your environmental policy, certain operations and activities must be controlled. Where operations or activities are complex and/or the potential environmental impacts are significant, operational controls should include documented procedures. Procedures can help your organization to manage its significant environmental aspects (SEAs), ensure regulatory compliance, and achieve environmental objectives. Procedures can also play an important role in employee training. Documented procedures also called operational control procedures should be established where the absence of procedures could lead to deviations from the environmental policy (including the commitments to compliance and pollution prevention) or from your objectives and targets. Determining which operations should be covered by documented procedures and how those operations should be controlled is a critical step in designing an effective EMS. Remember that you might need operational controls to manage SEAs that have legal requirements, regardless of whether you established objectives and targets for each of them. As mentioned at the end of Module 5, for every SEA you identify, it is desirable that one of two actions be taken. The action may include either:

• Evaluating alternatives to make changes in processes in order to reduce the potential for impact, or

• Writing operational control procedures for activities or steps in a production process where the potential impact can be controlled.

In writing operational control procedures for an SEA, consider the environmental objectives desired, the targets set for performance and write the procedures to ensure that the objective will be met. Your company may already have many procedures in place. These should be reviewed to make sure that they are consistent with EMS objectives. This module describes the process for setting objectives, developing operational controls, and creating the organizational support for ensuring that those objectives are met. If you determine that process changes should take place in order to address an SEA, the EMS emphasizes the need to evaluate alternatives before setting targets. In determining which operations and activities need to be controlled, look beyond routine production or service delivery. Activities such as equipment maintenance, start-up, and shutdown, management of on-site contractors, and services provided by suppliers or vendors could affect your organization’s environmental performance significantly.



The following are some examples of the kinds of activities that might be improved with operational controls:

• management/disposal of wastes • approvals for using new chemicals • production processes or operations • storage & handling of raw materials and chemicals • wastewater treatment • building and vehicle maintenance • transportation • operation and maintenance of equipment • management of contractors • marketing and advertising • acquisition or construction of property and facilities

The process of setting targets and ensuring their attainment has several steps that are discussed in more detail below: 1. Determine the possible causes of a potential impact.

For all of your significant environmental aspects, you should determine the cause of the impact. In some cases, the cause might seem obvious. However, sometimes the root cause of the problem is not the most obvious cause. Use the “root cause” analysis described in Module 15 to help your EMS team get to the cause of the impact prior to developing your operational controls.

2. Set targets and measurement indicators for environmental performance.

As discussed in Module 5, you need to set a target for each objective and establish measurements for environmental performance indicators. The targets should reflect correction of the root cause identified above. Measurement indicators should document changes in the causes identified above. Using the measurement indicators, you can determine if your operational controls are helping you meet your objectives.

3. Draft operational controls. Next, for each significant aspect that you have decided to address with procedures, draft operational controls. Review each of the causes identified in your root cause analysis that would contribute to the environmental impact of a significant aspect. Address the causes by drafting operational controls.



Operational controls may already exist for some of the activities associated with a SEA. Identify which SEAs have written procedures that describe operational controls and which need to have procedures developed. In some cases the procedures that you have in place to comply with environmental and health and safety regulations may be useful to meet your EMS objectives. Table 12-1: Partial List of Typical Operational Controls for Activities at a Shipbuilding and Ship Repair Facility might help your facility identify some of the operational controls that might be important to address SEAs.

Table 12-1: Partial List of Typical Activity Areas and Operational Controls at Shipbuilding and Ship Repair Facilities

Category of Activity Operational Control (Procedure) Purchase of Raw Materials • Subcontractor Requirements Tank Farm and Fuel Transfer • Above Ground Tank Inspection

• Taking on Fuel • Spill Reporting and Clean-up • Secondary Containment Inspection

Storage Raw Materials (chemicals) and Hazardous Waste Accumulation

• Hazardous Waste Area Inspection • Bulk Storage and Containment • Containerized Material Storage • Drum Handling – Satellite and Warehouse Storage • Hazardous Waste Operations Procedure • Control of Discharge and Disposal • Waste Manifest/Chain of Custody • Bulk Cargo Transfer Inspection

Drydock Operation • Best Management Practices for Ships in Drydock • Drydock Maintenance

Wastewater Management • Shipboard Wastewater Handling • Shipboard Sanitary Waste Disposal • Bilge and Ballast Water • Oily Water Transfer

Surface Preparation (Hydro and Abrasive Blasting) and Painting

• Hydroblasting Discharge Procedure • Air Emissions Control of Blasting • BMPs of Surface Preparation and Painting • Designated Material Mixing Areas • Excess Material Handling • Environmental Requirements for Distribution and

Handling of Marine Coatings • Operational Control for Control of Coating and Thinner

Use Shops and Facility Plant Maintenance • Environmental Compliance Assessment Checklist

• Procedure for Pressure Washing Near Water • Maintenance and Machine Shop Checklist • Disposition of Fluorescent Bulbs, Batteries, and Mercury

Items



3. Draft operational controls (Cont’d.)

This EMS template provides you with Tool 12-2: Sample Worksheet for Determining Which Operations Require Operational Controls to help guide the process of establishing necessary operational controls.

It is useful to involve the people who will implement the procedures in drafting them. You can accomplish this in several ways:

• Meet with workers and have them describe current procedures. Discuss the

environmental objective desired and obtain their input on operational controls (procedures) to ensure that the objectives will be met.

• Have someone (possibly an intern) interview the workers to establish current (undocumented) procedures; then draft (or revise) operational controls. Have the workers and a manager review the draft and incorporate their input.

Remember to keep written operational controls simple and concise. They should include the appropriate actions, precautions, and notifications required. Focus on activities that may lead to significant impacts and avoid getting overwhelmed by trying to control every activity and process.

4. Designate responsibility for maintaining and reviewing operational controls.

Designate those people responsible for maintaining the controls and for reviewing them to ensure that procedures are followed and deviations are corrected. Generally, the workers responsible for the SEA under consideration will be responsible for implementing the associated operational controls. The immediate line manager would most likely be responsible for regular review of the controls. It is helpful to list those people responsible for each set of procedures. Tool 12-3 might help you assign operational control responsibilities.

5. Develop training. Achieving success in meeting environmental objectives for each SEA depends upon making sure that each person responsible for maintaining or reviewing controls has received adequate training. After operational controls are drafted, develop a training program that ensures everyone understands the controls and their role in ensuring that they are followed. Training can include on-the-job training. Tool 12-4 is provided to help your facility to determine training needs associated with operational controls. It should help you identify, plan for, and track the training needs of your employees. This information should be combined with general environmental training when creating an integrated training needs analysis for your EMS (See Module 8).

6. Take corrective action when objectives are not met. Take action to correct failures in operational controls as quickly as possible to meet environmental objectives. You can record corrections made on the Corrective and Preventive Action Notice included in Module 15 (Form 15-2a).



A sample operational control procedure is provided as Example 12-2: Operational Control for Control of Coating and Thinner Use. Sample forms for providing documented evidence that the procedure is being implemented effectively are also included in the example.



TOOLS Tool 12-1: Operational Controls Worksheet Have we identified operations and activities associated with significant environmental aspects, legal requirements, and environmental objectives? If not, how will this be accomplished? Who should be involved?

What operations and activities are associated with significant environmental aspects?

What operations and activities are associated with legal requirements ?

What operations and activities are associated with environmental objectives and targets?

How are the above operations and activities controlled? (list methods)

How do we know whether these controls are adequate (i.e., to manage significant aspects, to ensure compliance, to achieve objectives?

How do we train employees and contractors on relevant operating controls?

If new controls are needed (or existing ones need to be revised), what is our process for doing so? Who needs to be involved in this process?

Our next step on operational control is to …



Tool 12-2: Sample Worksheet for Determining Which Operations or Activities Require Operational Controls

Procedure is Needed Operation or Activity with

SEA to be Controlled And Must Be

Developed

Procedure Exists, but Must Be Documented

Exists and Is Documented

No procedure is needed



Tool 12-3: Sample Worksheet for Operational Control Responsibilities

SEA Operational Control Procedures (list) Responsible for Maintaining Controls



Tool 12-4: Sample Worksheet for Training Plan for Operational Controls

SEA

Operational

Control Procedure(s)

Person(s) Responsible for

Procedure’s Implementation

Training

Needs

How to Train

When/ Length

Budget

Completion

Date

Person Responsible for Training



Tool 12-5: Sample Procedure for Development of Operational Control Procedures Purpose By developing operational control procedures for critical activities [i.e., those activities associated with significant environmental aspects (SEAs)], [Your Facility’s Name] intends to mitigate and control, to the extent possible, the environmental impacts associated with its SEAs. Procedure 1. The Cross Functional Team (CFT), with additional input from other employees as

needed, carries out a root cause analysis of each SEA to determine the underlying cause(s) of the environmental impact. As part of the root cause analysis, the committee will determine the need for (and adequacy of, if already existing) operational control procedures to control the critical activities related to the and record findings on Form 12-5. The CFT, with input from operations managers as needed, will also select one or more indicators for the purposes of monitoring [Your Facility’s Name] environmental performance related to each SEA.

2. Where there is a need to create or modify an operational control procedure, the CFT

assigns a member of the CFT to draft an operational control procedure, with input from the employees who undertake that procedure. Where possible, environmental controls will be integrated into existing operational control procedures. In other cases, a new procedure will be written. The operational control procedure will be issued as a “Work Instruction,” (that is, a summary list of required steps or measures). In addition to describing the steps necessary to carry out the particular activity in an environmentally sound manner, the work instruction will include steps to conduct monitoring, as applicable.

3. After the operational control procedure has been developed and implemented, its status is

recorded as such on Form 12-5. The procedure itself is entered into the relevant [Your Facility’s Name] operator’s handbook and/or is posted at the site of the activity in question. It is also listed in the EMS manual, or included in it, as a procedure related to the EMS.

Frequency As new SEAs are identified. For existing SEAs, a review of the associated root cause analysis and operational control procedures is conducted yearly. Records Form 12-5: EMS Operational Control Procedures, is maintained by the EMS coordinator. The procedures themselves are maintained in the relevant [Your Facility’s Name] operator’s handbook and/or posted at the site of the activity in question. Also, each procedure is listed in EMS documentation such as the EMS manual (listed or included).



Form 12-5: Sample Form for EMS Operational Control Procedures

SEA

Measurement Indicator(s)

Associated Job

Functions

Existing Operational Control Procedures

Operational Control Procedures Development/

Modification Needed

Person Responsible/

Status

Location

Posted

Contact Person: Date Complete



EXAMPLES

Example 12-1: Operational Control for Coating and Thinner Use ENVIRONMENTAL OPERATING PROCEDURE/WORK INSTRUCTION PROC-EMS-12-1: Control of Coating and Thinner Use by Customers, Contractors, and Others to Comply with NESHAP Shipyard Regulations 1.0 Purpose:

Maintain compliance with NESHAP Shipyard Regulations which control the emission of volatile organic compounds (VOCs) from coatings and thinners at [Your Facility’s Name].

2.0 References:

2.1. National Emission Standards for Shipbuilding and Ship Repair (Surface Coatings) Regulations

2.2. Code of Federal Register; 40 CFR 63.780 Through 40 CFR 63.788

3.0 Responsibility:

3.1. The V. P. Commercial or designee shall assure that [Your Facility’s Name]’s Environmental Purchasing Statement requirements are included in the bid tender presented to applicable customer representatives. The Environmental Purchasing Statement is as follows: “[Your Facility’s Name] in compliance with 40 CFR 63.780 through 40 CFR 63.788, is not permitted to allow the application of any coating that does not comply with the VOC (VOHAP) limitations. Failure to obtain proper approval prior to the application of any coating and/or failure to comply with these EPA regulations may result in the Owner and/or his supplier’s contractors and suppliers being liable for all costs and fines associated with any non-compliance. All coatings used and procedures followed must be approved by the [Your Facility’s Name] Environmental Engineer.”

3.2. The V. P. Commercial or his designate shall assure that the Environmental Purchasing Statement in Sec. 3.1 is included in contracts with [Your Facility’s Name] customers.



3.3 The Purchasing Agent shall assure that the Environmental Purchasing Statement in Sec. 3.1 is included in contracts with applicable subcontractors working directly for [Your Facility’s Name].

3.3. The Ship Manager shall make this procedure available to customer representatives prior to production work as applicable.

3.4. The Purchasing Subcontractor Coordinator shall make this procedure available to the applicable [Your Facility’s Name] subcontractors.

3.5. The Paint Department Head shall be responsible for interfacing with the Environmental Engineer and applicable contractor or customer personnel.

4.0 Procedure for contractors or customer personnel applying coatings at [Your Facility’s Name]

The Customer’s designated representative (Ship’s Force and customer subcontractors) or the [Your Facility’s Name] subcontractor representative shall:

4.1. Complete the top section of [Your Facility’s Name] approval form—Form PROC-EMS-12-1a and submit the completed form to the [Your Facility’s Name] Environmental Engineer for approval and completion of the bottom section prior to any coating use. Complete the [Your Facility’s Name] compliance form—Form PROC-EMS-12-1b and submit it to the [Your Facility’s Name] Environmental Engineer prior to any coating use.

4.2. No coating shall be used which does not have a VOC data sheet or have VOC data by batch number on can labels.

4.3. Report any damaged or leaking containers to the shipyard Paint Department immediately. [Fax 222-567-1234; Phone 222-567-1235 or 1236]

4.4. Thinner guidelines must be strictly adhered to during mixing and application.

4.5. Assure that paint and thinner lids are in place unless mixing or applying materials.

4.6. Report actual paint and thinner use on a daily basis to the Paint Department. (See 4.4 for fax and/or phone numbers).

4.7. Control all paint and thinner not used at the end of each shift.



Form PROC-EMS-12-1a

[YOUR FACILITY’S NAME] Paint Use Approval Form

This form must be completed by the Environmental Engineer, copied for retention and returned to the requestor prior to any coating application as indicated in the request form. Comments and/or precautions if applicable:_______________________________

___________________________________________________________________

______________Approve ______________Disapprove

Reason ____________________________________________________________

Signature ________________________________Date ______________________ Note! Environmental Engineer’s approval is required for all coatings used at [Your facility’s

Name] except those coatings that are applied and reported by the Paint Department.

[YOUR FACILITY’S NAME] Paint Use Approval Form

This form is to be completed by the Environmental Engineer, copied for retention and returned to the requestor prior to any coating applications as indicated in the request form. Comments and/or precautions if applicable: ________________________________________ ____________________________________________________________________________ ___________Approve __________Disapprove Reason ______________________________________________________________________ Signature ______________________________________________Date __________________ Note! Environmental Engineer’s approval is required for all coatings used at [Your Facility’s Name] except those coatings that are applied and reported by the Paint Department.



Form PROC-EMS-12-1b

Note: VOC limits are provided as examples only and do not attempt to represent actual conditions.

[YOUR FACILITY’S NAME] Shipyard Receipt Compliance Certification Form

Coating Identification: __________________________________________________________

Coating Manufacturer: _________________________

Container: ___________________________________

Batch Number Count: ________________________

Volume Received: ________________ Gallons VOC Content: _______________Grams/liter

Source of Data: MSDS ____ Technical Data Sheet ____ Container Label____ Method 24 ____

Coating Category: Code Description VOC Limit Grams/liter of coating General Use G1 General Use 340 Specialty S1 Air Flask 340 S2 Antenna 530 S3 Antifouling 400 S4 Heat Resistant 420 S5 High-Gloss 420 S6 High-Temperature 500 S7 Inorganic Zinc High-Build 340 S8 Military Exterior 340 S9 Mist 610 S10 Navigational Aids 550 S11 Nonskid 340 S12 Nuclear 420 S13 Organic Zinc 360 S14 Pretreatment Wash Primer 780 S15 Repair/Maintenance of Thermoplastics 550 S16 Rubber Camouflage 340 S17 Sealant for Thermal Spray Aluminum 610 S18 Special Marking 490 S19 Specialty Interior 340 S20 Tack Coat 610 S21 Undersea Weapons Systems 340 S22 Weld-Through Preconstruction Primer 650 I certify that the VOC content of this product is less than or equal to the allowable Federal VOC content for its applicable coating category. Signed: _________________________________________ Date: ________________________



Module 13: Emergency Preparedness and Response Guidance ................................................................................................................................... 13-2 Tools .......................................................................................................................................... 13-4

Tool 13-1: Emergency Preparedness and Response Worksheet................................... 13-4 Tool 13-2: Emergency Preparedness and Response Requirements Matrix.................. 13-5 Tool 13-3: Sample Procedure for Emergency Preparedness and Response ................. 13-6



GUIDANCE

Despite an organization’s best efforts, accidents and other emergency situations can occur. Effective emergency preparation and response can reduce injuries, prevent or minimize environmental impacts, protect employees and neighbors, reduce asset losses, and minimize downtime.

An effective emergency preparedness and response (EP&R) program should include provisions for: (1) assessing the potential for accidents and emergencies; (2) preventing incidents and their associated environmental impacts; (3) responding to incidents (emergency plans and procedures); (4) testing of emergency plans and procedures periodically; and, (5) mitigating impacts associated with accidents and emergencies. Consistent with the focus on continual improvement, it is important to review your emergency response performance after an incident has occurred. Use this review to determine if more training is needed or if emergency plans and procedures should be revised. This is another area where you should not have to start from scratch. Several environmental and health and safety regulatory programs require emergency plans and/or procedures. Examples of requirements related to EP&R that may apply to you are listed below:

Regulatory Driver

Requirement

RCRA Contingency Plan (LQG), Preparedness and Prevention Plan (LQG and SQG) CWA Spill Prevention, Control and Countermeasure Plan (SPCC) and Stormwater

Pollution Prevention Plans (SPPP) OPA Facility Response Plan (portions of shipyard not subject to Coast Guard

contingency plan requirements), SPCC Coast Guard Facility Response Plan CAAA Risk Management Plan EPCRA Community Right to Know Reporting and Coordination with Local and State

Emergency Response Committees

Some facilities are addressing these numerous requirements through Integrated Contingency Plans that combine the requirements of numerous regulatory programs into one plan. The federal government has issued guidance for such plan [Federal Register: June 5, 1996 (Volume 61, Number 109)][Page 28641-28664] and electronic versions with corrections and updates are available at http://www.epa.gov/swercepp/p-tech.htm#one-plan. While reviewing your EP&R documents for your EMS, you may consider such a streamlining approach.



Because you probably have programs in place for this area, this module focuses on additional items you will need to consider or address for your EMS. Specifically, you will need an EP&R procedure . A sample procedure is included as Tool 13-3, Sample Procedure for EP&R. Getting Started

• Two planning components that many organizations overlook are how they identify the potential for accidents and emergencies and how they prevent these occurrences or mitigate their impact. A cross-functional team (CFT) (with representatives from engineering, maintenance, and environmental health & safety, for example) can identify most potential emergencies by asking a series of “what if” questions related to hazardous materials, activities, and processes employed at the site. In addition to normal operations, the team should consider start-up and shutdown of process equipment, and other abnormal operating conditions.

• When developing procedures ask yourself: How will we ensure that everyone (including new employees) know what to do in an emergency? (For example, how would contractors or site visitors know what to do in an emergency situation?)

• Communicate with local officials (fire department, hospital, etc.) about potential emergencies at your site and how they can support your response efforts.

Hints

• Mock drills can be an excellent way to reinforce training and get feedback on the effectiveness of your plans/procedures.

• Post copies of your EP&R plans and procedures (or at least critical contact names and phone numbers) around your facility and especially in areas where high hazards exist. Include phone numbers for your on-site emergency coordinator, local fire department, local police, hospital, rescue squad, and others as appropriate.

• Revise and improve your plans as you learn from mock drills, training, or actual emergencies.

Checklist for Emergency Preparedness and Response Plans

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

explosions, spills or releases of hazardous materials, and natural disasters)?

q hazardous materials used on-site (and their locations)?

q key organizational responsibilities (including emergency coordinator)?

q arrangements with local emergency support providers?

q emergency response procedures, including emergency communication procedures?

q locations and types of emergency response equipment?

q maintenance of emergency response equipment?

q training / testing of personnel, including the on-site emergency response team (if applicable)?

q testing of alarm / public address systems? q evacuation routes and exits (map), and assembly

points?



TOOLS

Tool 13-1: Emergency Preparedness and Response Worksheet

Have we reviewed our operations and activities for potential emergency situations? If not, how will this be accomplished? Who should be involved?

Do our existing emergency plans describe how we will prevent incidents and associated environmental impacts? If not, how will this be accomplished? Who should be involved?

Have we trained personnel on their roles and responsibilities during emergencies?

What emergency equipment do we maintain? How do we know that this equipment is adequate for our needs?

How do contr actors and other visitors know what to do in an emergency situation?

When was our last emergency drill? Is there a plan / schedule for conducting future drills?

Have we established a feedback loop so we can learn from our experiences?

Our next step on emergency preparedness & response is to …



Tool 13-2: Emergency Preparedness and Response Requirements Matrix

Potential Emergency Scenario

Potential Environmental Impact

Action Required

Procedures Needed

Training Needed



Tool 13-3: Sample Procedure for Emergency Preparedness and Response [Note: This procedure assumes that your company has a general EP&R plan in place, into which environmental considerations can be integrated.] Purpose As part of its EMS, [Your Facility’s Name] strives to ensure that the environmental impacts associated with any emergency situations are prevented or mitigated to the greatest extent possible. Procedure 1. [Your Facility’s Name] has an Emergency Response Committee charged with identifying

potential emergency scenarios and developing and ensuring the implementation of appropriate procedures, should an emergency situation develop.

2. With the assistance of the EMS coordinator, the Emergency Response Committee (a)

identifies the potential negative significant environmental impacts associated with potential emergency scenarios, (b) incorporates measures to prevent these emergencies or minimize the impacts into EP&R procedures, and (c) ensures that adequate training (including simulations) is provided to appropriate [Your Facility’s Name] staff to implement these procedures. Input is obtained from staff in relevant areas that might have suggestions on how to improve EP&R program at our facility.

3. The Emergency Response Committee maintains records of the potential emergency

scenarios it is prepared for, the potential environmental impacts associated with each scenario, and the procedures established to minimize these impacts. Also the Emergency Response Committee or designee maintains contact with local emergency response personnel that might assist in the event of an actual emergency. The Human Resources manager keeps records of training received by staff on implementation of emergency response procedures.

Frequency The Emergency Response Committee meets quarterly to review the status of its work. Contact with local emergency personnel is made at least annually or as necessary based on regulatory requirements or activity changes at the facility that impact the EP&R program. Records Records of emergency scenarios, associated potential environmental impacts, and procedures to mitigate these impacts are kept by the Emergency Response Committee. Training records are maintained by the Human Resources manager.


EMS Corrective and Prevention Action, Management Review, and Continuous Improvement

EMS CORRECTIVE AND PREVENTIVE ACTION,

MANAGEMENT REVIEW, AND CONTINUOUS IMPROVEMENT

The EMS Corrective and Preventive Action, Management Review, and Continuous Improvement section includes 5 of the 18 modules. Ø Module 14: Monitoring and Measurement Ø Module 15: Nonconformance and Corrective & Preventive Action Ø Module 16: Records Ø Module 17: EMS Audits Ø Module 18: Management Review

Shipbuilding and Ship Repair Industry - EMS Implementation Guide Revision 3.0 (Nove mber 2001)

EMS Corrective and Prevention Action, Management Review, and Continuous Improvement Module 14 - 1

Module 14: Monitoring and Measurement


Tool 14-1: Monitoring and Measurement Worksheet .................................................. 14-8 Tool 14-2: EMS Program Measurement Criteria Worksheet ....................................... 14-9 Tool 14-3: Sample Procedure for a Compliance Assessment .................................... 14-10 Form 14-3: Sample Form for Compliance Tracking .................................................. 14-11 Tool 14-4: Pollution Prevention Tracking Log .......................................................... 14-12 Tool 14-5: Calibration Log......................................................................................... 14-13 Tool 14-6: Tracking Environmental Measurement Indicators ................................... 14-14

Examples................................................................................................................................. 14-15

Example 14-1: Example of Links Between Aspects, Objectives and Targets, Operational Controls, and Monitoring and Measurement ........................................... 14-15 Example 14-2: Linking Operational Controls and Monitoring.................................. 14-16



GUIDANCE

An EMS without effective monitoring and measurement processes is like driving at night without the headlights on — you know that you are moving but you can’t tell where you are going.! Monitoring and measurement help you:

• evaluate environmental performance; • analyze 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 helps 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:

ü Monitor key characteristics of operations and activities that can have significant environmental impacts and/or compliance consequences;

ü Track performance (including your progress in achieving objectives and targets); ü Calibrate and maintain monitoring equipment; and, ü Through internal audits, periodically evaluate your compliance with applicable laws

and regulations. An illustration of how monitoring and measurement is tied to the significant environmental aspects, objectives and targets, and operational controls of a shipbuilding facility’s EMS is presented in Example 14-1.



Monitoring Key Characteristics Many management theorists endorse the concept of the “vital few” — that is, that a limited number of factors can have a substantial impact on the outcome of a process. The key is to figure out what those factors are and how to measure them. Process mapping can help you determine what those factors might be (see Module 3 for examples). Most effective environmental monitoring and measurement systems use a combination of process and outcome measures.

• Outcome measures look at results of a process or activity, such as the amount of waste generated or the number of spills that took place.

• Process measures look at “upstream” factors, such as the amount of paint used per unit of product or the number of employees trained on a topic.

Select a combination of process and outcome measures that are right for your organization.

Which operations and activities can have

significant environmental impacts?

What are the key characteristics of these

operations and activities?

How do we measure these characteristics?



Tracking Performance To have a successful EMS, it is important to determine program measurement criteria. Determining measurement criteria, also called performance indicators , will help you evaluate the success of your overall EMS program. Performance indicators measure overall success, while key characteristic indicators measure progress against EMS objectives for specific SEAs. Examples of Performance Indicators are Provided on the next page of this module. The purpose of these indicators is different from the specific measurement criteria you developed for evaluating progress toward individual objectives. These performance indicators focus on how well the overall system for improving environmental management is functioning. Select performance indicators that will help you and your employees decide whether success has been achieved or whether improvement in procedures needs to be made. It is easier for management and staff to understand how things are going if they have benchmarks as guidelines. You will need performance indicators that describe how well your environmental policy is being implemented. In addition, you will need performance indicators for all of the various components of your EMS. The measurement criteria selected for each component of your EMS will probably be different. For example, how will you measure the success of communication, documentation, stakeholder outreach, or training programs? One approach is to measure the actions, for example, number of meetings held with stakeholders, number of documents created, number of employees trained, or number of hours of training. Action, however, does not always mean results. Consider the objective of each EMS component and define a way to measure results so that you would feel satisfied that the objectives are being achieved. Tools 14-1 and 14-2 are worksheets that might help guide your facility in creating a thorough and effective monitoring and measurement element of your EMS.

To measure results effectively, you methods should be:

þ simple

þ flexible þ consistent

þ ongoing þ produce reliable data

þ communicate results



Here are some examples of EMS results Performance Indicators for your EMS or various program components that can be tracked over time:

• number of SEAs included in environmental projects plan • number of environmental objectives and targets met • pounds of hazardous waste generated per unit of production • employee sick leave absences related to work environment • percentage of employees completing environmental training • average time for resolving corrective action • energy or water use per unit of production • percentage of solid waste recycled/reused • number of complaints from community; number of responses to complaints • number of pollution prevention ideas generated from employees • resources used per unit of product or service • pollution (by type) generated per unit of product or service • percentage of products for which life cycle assessment has been conducted • number of products which have a recycling program • number of instances of non-compliance

It is the results shown by these environmental performance indicators that will become the basis for your plans for next year and for documenting continuous improvement. Measuring pollution prevention achievements is part of tracking performance, but may be different from, and often more difficult than, measuring environmental achievements in general. Simply measuring the reduction in a waste stream might mean only that the waste has been transferred to another medium, not reduced. It is therefore important to measure the reduction at the source of waste generation. It may also be important to measure the activities that your company directs towards pollution prevention. The following sources of information may help you track pollution prevention: - Permit applications - TRI reports - Purchasing records - Utility bills - Hazardous waste manifests - Material Safety Data Sheets In addition, administrative procedures can be established to support pollution prevention activities. Your facility should consider:

- Establishing procedures in each facility area for identifying pollution prevention

opportunities. - Having a chemical or raw material inventory system in place. - Assessing how many objectives have been met through pollution prevention.



Calibrating Equipment A component of monitoring and measurement is equipment calibration. Your facility should identify process equipment and activities that affect your environmental performance. As a starting point, look at those key process characteristics you identified earlier. For monitoring and measurement you can: (1) measure the equipment itself (for example, measuring the paint flow rate through a flow gun to see if it is within the optimal range for transfer efficiency) or you can (2) add measurement equipment to a process to help measure the key characteristic (for example, a thermometer on a plating bath to make sure that the temperature is within the optimal range for plating quality to reduce the need for replating which causes significant waste through product rework). Some organizations place critical monitoring equipment under a special calibration and preventive maintenance program. This can help to ensure accurate monitoring and make employees aware of which instruments are most critical for environmental monitoring purposes. Some organizations find it is more cost-effective to subcontract calibration and maintenance of monitoring equipment than to perform these functions internally. An illustration of how calibration needs are tied to SEAs, operational controls, key characteristics of the operation, and monitoring and measurement methods is presented in Example 14-2. Getting Started

• Monitoring and measuring can be a resource- intensive effort. One of the most important steps you can take is to clearly define your needs . While collecting meaningful information is clearly important, resist the urge to collect data “for data’s sake.”

• Review the kinds of monitoring you do now for regulatory compliance and other purposes (such as quality or health and safety management). How well might this serve your EMS purposes? What additional monitoring or measuring might be needed?

• You can start with a relatively simple monitoring and measurement process, then build on it as you gain experience with your EMS. Its better to measure less items consistently, than to measure many items inconsistently.

Hints

• Regulatory compliance: Determining your compliance status on a regular basis is very important. You should have a procedure to systematically identify, correct, and prevent violations. Effectiveness of the compliance assessment process should be considered during EMS management review. The EPA encourages “systematic discovery” of regulatory violations, which means detecting potential violations through environmental audits or compliance management systems that show due diligence in preventing, detecting, and correcting violations. EPA has prepared guidance documents



and protocols for conducting environmental compliance audits under a number of its regulatory programs. For more information, check the EPA web site at www.epa.gov/oeca/index.html.

• Operational performance: Consider what information you will need to determine whether the company is implementing operational controls as intended.

• Progress on meeting objectives: You should measure progress on achieving objectives and targets on a regular basis and communicate the results of such measurement to top management. To measure progress in meeting objectives, select appropriate measurements of the key characteristics which apply to that objective.

• Selecting performance indicators: Performance indicators can help you to understand how well your EMS is working overall. Start by identifying a few performance indicators that are:

- simple and understandable; - objective; - measurable; and - relevant to what your organization is trying to achieve (i.e., its objectives and

targets)

Data collected on performance indicators can be quite helpful during management reviews (see Module 18). So, select indicators that will provide top management with the information it needs to make decisions about the EMS.

Make sure you can commit the necessary resources to track performance information over time. It is OK to start small and build over time as you gain experience in evaluating your performance. Keep in mind that no single measurement will tell your organization how it is doing in the environmental area.

• Communicating performance : People respond best to information that is meaningful to “their world.” Putting environmental information in a form that is relevant to their function increases the likelihood they will act on the information. Be sure to link your measurement program with your communications program and other elements of the EMS (such as management reviews, as discussed later).

Tool 14-3 is sample procedure that your facility can adopt for assuring environmental regulatory compliance. Form 14-3 is an example of a compliance tracking form to be used in association with that procedure. Tools 14-4, 14-5, and 14-6 are examples of forms for tracking pollution prevention, calibration, and overall environmental performance indicators, respectively. Similar to the example provided by Tool 14-3, Procedure for Compliance Assessment, your facility might want to establish written procedures to which these tracking forms, Tools 14-4, 14-5, and 14-6, will be associated.



TOOLS Tool 14-1: Monitoring and Measurement Worksheet Have we identified operations and activities associated with significant environmental aspects, legal requirements and environmental objectives? If, not how will this be accomplished?

What type(s) of monitoring and measurement do we need to ensure that operational controls are being implemented correctly?

What type(s) of monitoring and measurement do we need to ensure that we are complying with applicable legal requirements?

What type(s) of monitoring and measurement do we need to ensure that we are achieving our environmental objectives & targets?

How do we identify the equipment used for any of the monitoring or measurement listed above?

How will we ensure that monitoring and measurement equipment is properly calibrated and maintained?

What process do we have to periodically evaluate compliance with legal requirements? How effective is this process?

Our next step on monitoring and measurement is to …



Tool 14-2: EMS Program Measurement Criteria Worksheet

Facility Name_____________________________

Measurement Elements

EMS Component(s

Objectives of Component

Activity Measures

Results Indicators

Review Period

Communication Plan

Stakeholders Input

Environmental or EMS Training

Review of Aspects

Operational Controls

Environmental Review of New Processes and Activities

Setting Objectives & Targets

Environmental Management Program 1

Environmental Management Program 2

Documentation

Regulatory Compliance

Pollution Prevention

Other

Contact person for form: Date Completed:



Tool 14-3: Sample Procedure for a Compliance Assessment Purpose [Your Facility’s Name] will conduct periodic compliance assessments to ensure that it complies with all applicable local, state, and federal environmental regulations. Procedure 1. The Environmental Management Representative (EMR) maintains copies of applicable

legal regulations (see Module 4, Form 4-3). Based on these regulations, the EMR and EMS Coordinator compile a list of questions as a compliance assessment protocol. These questions are intended to be sufficient to determine the compliance status of [Your Facility’s Name] with respect to applicable environmental regulations (both administrative and performance-related components).

2. The EMS Coordinator and another operations manager carry out the assessment by

determining and recording the answers to the compliance assessment protocol. When they are done with the compliance assessment, they note any actual or potential compliance issues on Form 14-3: Compliance Tracking Log. Each actual and potential compliance issue is immediately referred to corrective action.

Frequency Monthly. Records Compliance assessment results are recorded by the EMS Coordinator using Form, 14-3. Records are maintained by the EMS Coordinator.



Form 14-3: Sample Form for Compliance Tracking Log

Person

Responsible

Regulation

Root Cause

Compliance Check

Date

Results

Corrective Action/Date

(see: TCA-01)

Compliance

Verified/Date



Tool 14-4: Pollution Prevention Tracking Log

Area of Company

Pollution Prevention Activity

Date Started

Results

Measurement Method

Person Responsible

Contact: Date Completed:



Tool 14-5: Calibration Log

Indicator

Measurement Method

Equipment Used

Equipment calibrated: date/method




Tool 14-6: Environmental Measurement Indicators Log

Aspect Objective Indicator Date Checked Who Checked Result Corrective Action




EXAMPLES

Example 14-1: Example of Links Between Aspects, Objectives and Targets, Operational Controls, and Monitoring and Measurement

Significant Aspect

Objective Target Operational Control

Monitoring and Measurement

Anti corrosive paint X

C-Maintain compliance

Ongoing ! Coating and thinning NESHAP procedure ! Paint application work instruction (WI) ! Bulk storage WI and containment WI

! Compliance audit ! Regulatory reporting ! EMS audits

Non-abated emission of VOCs

I-Reduce VOC emissions

10% by January 2002

! VOC -reduction EMP

! VOC volume reduction tracking metric ! EMS audits

Solid waste from unmasking process

S-Investigate potential for reduction

Complete study by January 2002

! Solid waste reduction EMP

! Waste reduction tracking metric ! EMS audits



Example 14-2: Linking Operational Controls and Monitoring

Operation with Significant

Environmental Aspect

Operational

Controls

Key Characteristics of Operation or Activity

Monitoring or Measurement

Methods

Equipment Calibration

Needs Surface Coating Operation (SEA is VOC emissions)

• Approved list of coatings

• Coating work

instruction • Permit report

procedure

• Type of coating

• Rate of

application • Frequency of

application • Emissions of

VOCs

• Compare to approved list

• Measure quantity applied

• Use coating log book

• Calculate based on use

• None

• Flow meter

• None

• Flow meter

Liquid Waste Storage (SEA is potential for spills)

• Generator procedure

• Storage area

procedure

• Use of proper containers

• Segregation of incompatibles

• Availability of

spill equipment

• Inspections of storage area



• None

• None

• None



Module 15: Nonconformance And Corrective And Preventive Action

Guidance ................................................................................................................................... 15-2

Figure 15-1: Root Cause Diagram............................................................................... 15-3 Tools and Forms ....................................................................................................................... 15-6

Tool 15-1: Corrective & Preventive Action Worksheet ............................................... 15-6 Tool 15-2: Sample Procedure for Corrective and Preventive Action........................... 15-7 Form 15-2a: Sample Corrective and Preventive Action Notice .................................. 15-9 Form 15-2b: Sample Corrective and Preventive Action Tracking Log..................... 15-10



GUIDANCE

No EMS is perfect. You will probably identify problems with your system (especially in the early phases) through audits, measurement, or other activities. In addition, your EMS will need to change as your organization adapts and grows. To deal with system deficiencies, your organization needs a process to ensure that: 1. Problems (including nonconformities) are identified and

investigated; 2. Root causes are identified; 3. Corrective and preventive actions are identified and

implemented; and, 4. Actions are tracked and their effectiveness is verified. EMS nonconformities and other system deficiencies (such as legal noncompliance) should be analyzed to detect patterns or trends . Identifying trends allows you to anticipate and prevent future problems. Focus on correcting and preventing problems. Preventing problems is generally cheaper than fixing them after they occur (or after they reoccur). Start thinking about problems as opportunities to improve! Determining Causes of Problems You will need to establish a method to determine the causes of failing to meet a target. In some cases, the cause might not be difficult to understand. Other times, however, the cause might not be obvious. One method is called “root cause analysis.” This method can be applied to identify causes for not meeting targets. You can also use it to determine the possible causes of a potential impact. You should determine the root cause of each of your SEAs that has an impact on the environment. For example, if a spill occurs several times in your raw material transfer area, you should attempt to identify why the spill is occurring – that is, the root cause – so you can address the cause and prevent the spill in the future.

Why do EMS problems occur? Typical causes include:

þ poor communication

þ faulty or missing procedures

þ equipment malfunction (or lack of maintenance)

þ lack of training þ lack of understanding

(of requirements) þ failure to enforce rules

þ corrective actions fail to address root causes of problems

Key Steps

þ identify the problem

þ investigate to identify the root cause

þ come up with solution

þ implement solution

þ document solution

þ communicate solution

þ evaluate effectiveness of solution



The root cause diagram, shown in Figure 15-1, will help you organize your thinking when you analyze your company’s potential for environmental impact. This analysis can be done by one person or by a group, with one person writing down the ideas produced. Each diagonal line represents a main component of the production process. Each horizontal line stemming from the diagonal represents an important element contributing to each of the main components. For example, elements of work practices might contribute to the labor component. This diagram is simply a device to help organize the analysis of the cause of potential environmental impacts. Use it if it helps, but don’t get hung up on trying to make it work. Figure 15-1: Root Cause Diagram



Taking corrective action Once you document a problem with respect to meeting targets, you must resolve it. Take action as quickly as possible. Make sure assigned responsibilities for actions and schedules are clear so that correction occurs in a timely manner. Employees in the shop may recognize the need for corrective action and provide good ideas for solving problems. Find ways to get them involved in the improvement process. It’s important to determine whether a lapse is temporary or due to some flaw in the procedures or controls. For this reason, communicate any findings to employees, and provide any follow-up training for changes in the procedures that may result. The following is a checklist to help complete corrective action. Have you:

√ Identified the problem(s)? √ Identified the cause(s)? √ Come up with a solution for each? √ Implemented the solution(s)? √ Documented the solution(s)? √ Communicated the solution(s)? √ Documented the action(s)?

Hints

• If your organization has an ISO 9001 management system, you should already have a corrective and preventive action process for quality purposes. Use this as a model (or integrate with it) for EMS purposes.

• Some organizations find that they can combine some elements of their management review and corrective action processes. These organizations use a portion of their management review meetings to review noncomformities, discuss causes and trends, identify corrective actions, and assign responsibilities.

• The amount of planning and documentation needed for corrective & preventive actions will vary with the severity of the problem and its potential environmental impacts. Don’t go overboard with bureaucracy — simple methods often work quite effectively.

• Once you document a problem, the organization must be committed to resolving it in a timely manner. Be sure that your corrective & preventive action process specifies responsibilities and schedules for completion. Review your progress regularly and follow up to ensure that actions taken are effective.

• Make sure your actions are based on good information and analysis of causes. While many corrective actions may be “common sense,” you need to look beneath the surface to determine why problems occur. Many organizations use the term “root cause” in their corrective and preventive action processes. While this term can be used to describe a very formal analysis process, it can also mean something simpler – looking past the obvious or immediate reason for a nonconformance to determine why the nonconformance occurred.



• Rule of thumb: Corrective actions should (1) resolve the immediate problem, (2) consider whether the same or similar problems exist elsewhere in the organization, and (3) prevent the problem from recurring. The corrective action process also should define the responsibilities and schedules associated with these three steps.

• Initially, most EMS problems may be identified by your internal auditors. However, over the long run, many problems and good ideas may be identified by the people doing the work. This should be encouraged. Find ways to get employees involved in the system improvement process (for example, via suggestion boxes, contests, or incentive programs).

Tool 15-1 is a worksheet that might guide your facility in establishing and implementing a corrective and preventive action program. Tool 15-2 provides a sample procedure for conducting corrective and preventive action. Form 15-2a is a sample form that can be used to document the use of your procedure. Form 15-2b can be used to track corrective and preventive actions. Form 15-2a could also be combined with the EMS Audit Findings, Form 17-2e (see Module 17).



TOOLS

Tool 15-1: Corrective & Preventive Action Worksheet

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


How are nonconformities and other potential system deficiencies identified? (List methods such as audits, employee suggestions, ongoing monitoring, etc.)

How do we determine the causes of nonconformities and other system deficiencies? How is this information used?

How do we track the status of our corrective and preventive actions?

How is / can information on nonconformities and corrective actions be used within the EMS (for example, in management review meetings, in employee training sessions, in review of procedures, etc.)

How do we ensure the effectiveness of our corrective and preventive actions?

Our next step on corrective and preventive action is to …



Tool 15-2: Sample Procedure for Corrective and Preventive Action Purpose The purpose of this procedure is to establish and outline the process for identifying, documenting, analyzing, and implementing preventive and corrective actions. Scope Preventive or corrective actions may be initiated using this procedure for any environmental problem affecting the organization. General A. Corrective action is generally a reactive process used to address problems after they have

occurred. Corrective action is initiated using the CAPAN, Form 15-2a, as the primary vehicle for communication. Corrective action may be triggered by a variety of events, including internal audits and management reviews. Other items that might result in a corrective CAPAN include neighbor complaints or the results of monitoring and measurement.

B. Preventive action is generally a proactive process intended to prevent potential problems

before they occur or become more severe. Preventive action also is initiated using the CAPAN, Form 15-2a. Preventive action focuses on identifying negative trends and addressing them before they become significant. Events that might trigger a preventive CAPAN include monitoring and measurement, trends analysis, tracking of progress on achieving objectives and targets, response to emergencies and near misses, and customer or neighbor complaints, among other events.

C. CAPAN’s are prepared, managed, and tracked using the preventive and corrective action

database. D. The EMR (or designee) is responsible for reviewing issues affecting the EMS, the application

and maintenance of this procedure, and any updates to EMS documents affected by the preventive and corrective actions.

E. The EMR is responsible for logging the CAPAN into the database, and tracking and recording

submission of solutions in the database. The requester and recipient of the CAPAN responsible for verifying the effectiveness of the solution. The EMR is responsible for overall tracking and reporting on preventive and corrective actions.

F. Personnel receiving CAPANs are responsible for instituting the required corrective or

preventive action, reporting completion of the required action to the EMR, and assuring sustained effectiveness.

G. Completed records of CAPANs are maintained in the database for at least two years after

completion of the corrective or preventive action.



Procedure A. Issuing a CAPAN

1. Any employee may request a CAPAN. The employee requesting the CAPAN is responsible for bringing the problem to the attention of the EMR. The EMR is responsible for determining whether a CAPAN is appropriate and enters the appropriate information into the corrective and preventive action database. Responsibility for resolving the problem is assigned to a specific individual (“the recipient”).

2. The EMR, working with the recipient, determines an appropriate due date for resolving

the CAPAN. B. Determining and Implementing Corrective and Preventive Actions

1. The CAPAN is issued to the recipient, who is responsible fo r investigation and resolution of the problem. The recipient is also responsible for communicating the corrective or preventive action taken.

2. If the recipient cannot resolve the problem by the specified due date, he/she is responsible

for determining an acceptable alternate due date with the EMR. C. Tracking CAPAN’s

1. Close-out of CAPAN’s should be tracked by the EMR or his designee using Form 15-2b. CAPAN’ whose resolution dates are overdue appear on the Overdue Solutions report. The EMR is responsible for issuing this report on a weekly basis to the Plant Manager and the recipients of any overdue CAPAN’s.

2. Records of CAPAN’s are maintained in the database for at least two years after

completion of the corrective or preventive action. D. Tracking Effectiveness of Solutions

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



Form 15-2a: Sample Corrective and Preventive Action Notice

Issue Date: Solution Due Date:

Requested by: Issued to:

Problem Statement:

Most Likely Causes:

Suggested Solutions/Preventions:

Action Taken:

Measured Results:

Corrective and Preventive Action Closed by: Date:

Contact for Notice: Date completed:



Form 15-2b: Sample Corrective and Preventive Action Tracking Log

CAPAN Number

Requested By

Issued To

Plan Due

(Date)

Plan Completed

(Date)

Corrective and

Preventive Action

Completed (Date)

Effectiveness Verified (Date)

CAPAN Closed (Date)



Module 16: Records

Guidance ................................................................................................................................... 16-2 Tools .......................................................................................................................................... 16-4

Tool 16-1: Records Management Worksheet ............................................................... 16-4 Tool 16-2: Sample Checklist for Records of Supporting Documentation.................... 16-5

Examples................................................................................................................................... 16-6

Example 16-1: Sample of Environmental Records Organizer ..................................... 16-6 Example 16-2: Sample EMS Records Management Table.......................................... 16-7



GUIDANCE The purpose of records management is fairly simple —to help you demonstrate that your organization is actually implementing the EMS as designed. While records have value internally, you also may need to provide them to external parties (such as customers, a registrar, or the public), as evidence of EMS implementation. Records management is sometimes seen as bureaucratic, but it is difficult to imagine a system operating consistently without accurate records.

The basics of records management are straightforward: you need to decide what records you will keep, how you will keep them and for how long. You should also think about how you will dispose of records once you no longer need them.

If your organization has an ISO 9001 (or other) management system, you should have a process in place for managing records. This process could be adapted for EMS purposes.

Hints:

• Start by identifying what EMS records are required. Look at your other procedures and work instructions to determine what evidence is needed to demonstrate implementation. Also consider records that are required by various legal requirements.

• Focus on records that add value — avoid bureaucracy. If records have no value or are not specifically required, don’t collect them. The records you choose to keep should be accurate and complete.

• You may need to generate certain forms in order to implement your EMS. When these forms are filled out, they become records. Forms should be simple and understandable for the users. This Guide provides example forms for some EMS modules that you may include as EMS records if they are relevant to your operations and EMS.

• Establish a records retention policy and stick to it. Make sure that your policy takes into account records retention requirements specified in applicable environmental regulations . For example, hazardous waste manifests must be maintained for a specified period of time under RCRA. Therefore, that would be an appropriate period of time to use for this record as part of your EMS.

What are “records”?

Records provide evidence that the processes that make up your EMS are being implemented as

described.



• In designing your records management process, be sure to consider: - who needs access? - to what records? - in what circumstances?

• If your organization uses computers extensively, consider using an electronic EMS records management system. Maintaining records electronically can provide an excellent means for rapid retrieval of records as well as controlling access to sensitive records.

• Think about which records might require additional security. Do you need to restrict access to certain records? Should a back-up copy of critical records be maintained at another location? Should a hard copy of some records be maintained in case an inspector arrives and your computer system is down (this has actually happened to facilities).

Types of Records You Might Maintain (Examples):

• legal, regulatory, and other code requirements • results of environmental aspects identification • reports of progress towards meeting objectives and targets • permits, licenses, and other approvals • job descriptions and performance evaluations • training records • EMS audit and regulatory compliance audit reports • reports of identified nonconformities, corrective action • plans, and corrective action tracking data • hazardous material spill / other incident reports • communications with customers, suppliers, contractors, and

other external parties • results of management reviews • sampling and monitoring data • maintenance records • equipment calibration records

Key Questions

þ what records are kept? þ who keeps them? þ where are they kept? þ how are they kept? þ how long are they

kept? þ how are they

accessed? þ how are they

disposed?



TOOLS

Tool 16-1: Records Management Worksheet Have we identified what records need to be maintained? Where is this defined?

Have we determined records retention times? Where is this defined?

Have we established an effective storage and retrieval system?

Our next step on records is to …



Tool 16-2: Sample Checklist for Records of Supporting Documentation Note: This is an example checklist format for records that you should modify for the records that are important to your EMS. PLEASE PROVIDE COPIES OF THE FOLLOWING: _____ Facility organization chart _____ Staffing and organization chart for the EMS _____ Facility environmental policy _____ Samples of supporting documentation for reporting and communication networks

such as meeting notices, meeting minutes, memoranda, etc. _____ Training records related to EMS training. _____ Documentation records for monitoring and measurement efforts. _____ Samples of written EMP performance and status reports _____ Samples of facility-specific environmental policies and procedures



EXAMPLES

Example 16-1: Sample of Environmental Records Organizer

Air Emissions Regulations Air Emissions Fees Air Emissions Inventories Air Emissions Permits Air Permit Applications Air Permit(s): Historical Annual Licenses & Fees Compliance Reporting Compliance Plans Community Right-to-Know EPCRA Regulations EPCRA Reporting Hazardous Waste Regulations Hazardous Waste Permit/ID Number Hazardous Waste Fees Hazardous Waste Biennial Report Hazardous Waste: Open Manifests Hazardous Waste: Closed Manifests Historical Data Indoor Air Quality

Loss Prevention Information Other Permits & Permit Applications Pollution Prevention (P2) Regulations Pollution Prevention Fees Pollution Prevention Reporting Recycling Information Recycling Projects Special Wastes Solid Waste Permit Solid Waste Fees Spill Reports Spill Response Actions Stormwater Regulations Stormwater Permit Training Records VOC/HAPs Reporting VOC Annual Analysis Wastewater Regulations Wastewater Fees Wastewater Permit Wastewater: Semi-Annual Reporting



Example 16-2: Sample EMS Records Management Table Title: EMS RECORDS MANAGEMENT TABLE Revision Date: November 7, 2000 Print Date: January 2, 2002 (Uncontrolled document if printed)

Doc. No.: EMF-4.5.3 Approval by: Page 1 of 2

EMS Records Management Table

The following table lists records related to the Environmental Management System, in accordance with EMP-4.5.3 (Record Keeping Procedure).

Record Type

Person Responsible

Location

File Method

Retention Minimum

ADMINISTRATION Records on costs - purchasing, operations, and disposal

Office Manager

Admin. Office

Date order

3 years

Utility bills

Office Manager

Admin. Office

Date order

3 years

Record of annual waste quantity received

Office Manager

Admin. Office

Date order

Life of Co.

Certificates of Insurance

Office Manager

Admin. Office

Date order

Life of Company

Waste Analysis Sheets

Office Manager

Admin. Office

Customer name

3 years

Waste Manifests - outgoing

Office Manager

Admin. Office

Date order

3 years

HUMAN RESOURCES Training Needs Analysis and Training Records

Human Resource Manager

Human Resource Office

By type and date order

5 years

ENVIRONMENTAL

Incident Reports

Env. Dept. Env. Office Date order 3 years

Complaint Reports

Env. Dept. Env. Office Date order 3 years

EMS Communications with external parties

Env. Dept.

Env. Office

Issue

3 years



Record Type

Person Responsible

Location

File Method

Retention Minimum

Decision regarding external communication of significant environmental aspects

Env. Dept.

Env. Office

Date order

3 years

Major Source Determination Records

Env. Dept.

Env. Office

Date order

Life of Co.

Title V Permit Exemption

Env. Dept.

Env. Office

Date order

Life of Company

Correspondence regarding Air Notices

Env. Dept.

Env. Office

Date order

5 years

Odor Control System Permit

Env. Dept.

Env. Office

Date order

5 years or per Permit

Air Emission Reports

Env. Dept.

Env. Office

Date order

5 years

Records on waste disposal sites used

Env. Dept.

Env. Office

Site name

Life of Co.

EMS Audit Reports

Env. Dept.

Env. Office

Date order

5 years

EMS Corrective and Preventive Action Notices (Form 15-sa) and Database Logging Summary (Tracking Log format of Form 15-2b)

Env. Dept - EMR Env. Office – CAPAN database

Date order 2 years after completion of action.

EMS Management Review Records (Form 18-2)

Env. Dept. – EMS Coordinator

Env. Office Date Order Life of company

Note: This example does not include all records that would need to be maintained for the EMS or for environmental regulatory purposes but is included for illustrative purposes.


EMS Corrective and Prevention Action, Management Review, and Continuous Improvement Module 17- 1

Module 17: EMS Audits Guidance ................................................................................................................................... 17-2

Figure 17-1: Linkages Among EMS Audits, Corrective Action and Management Reviews .................................................................................................17-5

Tools and Forms ....................................................................................................................... 17-7

Tool 17-1: EMS Auditing Worksheet........................................................................... 17-7 Tool 17-2: Sample Procedure for EMS Audits ........................................................17-8 Form 17-2a: Sample Audit Plan Form....................................................................... 17-11 Form 17-2b: Sample Form for Communications to Audit Team........................ 17-12 Form 17-2c: Sample Form for Internal Assessment Checklist............................ 17-13 Form 17-2d: Sample EMS Audit Summary Form................................................ 17-14 Form 17-2e: Sample Form for EMS Audit Findings ............................................ 17-15

Examples................................................................................................................................. 17-16

Example 17-1: Sample Questionnaire for EMS Audits ............................................. 17-16 Example 17-2: Sample Checklist for Top Management EMS Audits ....................... 17-25



GUIDANCE

Once your organization has established its EMS, verifying the implementation of the EMS is critical. To identify and resolve EMS deficiencies you must actively seek them out. In any organization, periodic audits can be valuable. Managers and employees are often so close to the work they perform that they may not see problems or bad habits that have developed. Periodic EMS audits will help determine whether all of the requirements of the EMS are being carried out in the specified manner. For your EMS audit program to be effective, you should:

• develop audit procedures and protocols; • determine an appropriate audit frequency; • select and train your auditors; and • maintain audit records.

Results of your EMS audits should be linked to the corrective and preventive action process, as described in Module 15. While they can be time-consuming, EMS aud its are critical to EMS effectiveness. Systematic identification and reporting of EMS deficiencies to management provides a great opportunity to:

• maintain management focus on the environment, • improve the EMS and its performance, and • ensure the system’s cost-effectiveness.

Audit procedures should describe:

þ audit planning þ audit scope (areas and

activities covered) þ audit frequency

þ audit methods

þ key responsibilities for the audits

þ reporting mechanisms for the audits

þ recordkeeping for audit results



Getting Started: How frequently do we need to audit? To determine an appropriate frequency of your EMS audits, consider the following factors:

< the nature of your operations and activities, < your significant environmental aspects / impacts

(which you identified earlier), < the results of your monitoring processes, and < the results of previous audits.

As a rule of thumb, all parts of the EMS should be audited at least annually. You can audit the entire EMS at one time or break it down into discrete elements for more frequent audits. What do we need to audit? As part of your audits, it is critical that you regularly review your company’s environmental aspects and objectives. Over time, you will probably add to the list of environmental aspects and you may need to re-rank the aspects as your activities change and as new information becomes available. Here are some things to check:

• New process review — have any changes introduced new environmental aspects? • Worksheets from the most recent environmental aspect identification and significance

determination — is there new information on chemical effects? If so, update your worksheets.

• Communication received from external stakeholders — do any comments suggest a need for you to reevaluate your aspects?

• Environmental objectives and targets — what new ones will your company set for this time period? Which are now accomplished and can be closed out or maintained?

• Pollution prevention program — has information become available from this effort that would add aspects or objectives?

• Audit program — have your audits turned up information on where your EMS and environmental programs could be improved? Would this information be useful in your aspect identification process or in redesigning your objectives?

L Tip Regularly revisiting your environmental aspects and objectives is an essential step in developing an EMS that achieves the goal of continuous improvement. The regular review of aspects can be used to change the priorities you set last time, or it can be used to examine a part of your company’s activities that you set aside last time. The regular review can be part of a planned “phasing in” process, wherein different parts of your company’s operations are reviewed until all your company’s activities are included in your EMS. The regular review of aspects is the foundation for your company’s continuing improvement.



Who will perform the audits? You should select and train EMS auditors. Auditor training should be both initial and ongoing. Commercial EMS auditor training is available, but it might be more cost-effective to link up with businesses or other organizations in your area (perhaps through a trade association) to sponsor an auditor training course. Some local community colleges also offer EMS auditor training courses.

Auditors should be trained in auditing techniques and management system concepts. Familiarity with environmental regulations, facility operations, and environmental science can be a big plus, and in some cases may be essential to adequately assess the EMS. Some auditor training can be obtained on-the-job. Your organization’s first few EMS audits can be considered part of auditor training, but make sure that an experienced auditor leads or takes part in those “training” audits. Auditors should be independent of the activities being audited. This can be a challenge for small organizations. If your company is registered under EMS 9001, consider using your internal quality auditors as EMS auditors. While some additional training might be needed for EMS auditing, many of the required skills are the same.

How should management use audit results? Management can use EMS audit results to identify trends or patterns in EMS deficiencies. The organization also should ensure that identified system gaps or deficiencies are corrected in a timely fashion and that corrective actions are documented. Management review of the EMS can use these results, as discussed in Module 18, Management Review.



Hints

• Your EMS audits should focus on objective evidence of conformance. During an audit, auditors should resist the temptation to evaluate, for example, why a procedure was not followed — that step comes later.

• During an audit, auditors should review identified deficiencies with people who work in the relevant area(s). This will help the auditors verify that their audit findings are correct. This also can reinforce employee awareness of EMS requirements.

• If possible, train at least two people as internal auditors. This will allow your auditors to work as a team. It also allows audits to take place when one auditor has a schedule conflict, which is often unavoidable in a smaller organization!

• Before you start an audit, be sure to communicate the audit scope, criteria, schedule, and other pertinent information to the people in the affected area(s). This helps to avoid confusion and facilitate the audit process.

• Consider integrating your EMS and regulatory compliance audit processes, but keep in mind that these audit processes have different purposes. While you might want to communicate the results of EMS audits widely within your organization, the results of compliance audits might need to be communicated in a more limited fashion.

• Final thought: An EMS audit is a check on how well your system meets your own established EMS requirements. An EMS audit is not an audit of how well employees do their jobs. Auditors should avoid the “gotcha” mentality. Audits should be judged on the quality of findings, rather than on the number of findings.

Figure 17-1:

Linkages Among EMS Audits, Corrective Action and Management Reviews

EMSEstablished

ManagementReviews

PeriodicEMS Audits

Corrective ActionProcess



Tool 17-1 is a worksheet that might guide your facility in establishing and implementing an EMS audit program. Tool 17-2 provides a sample procedure for conducting internal EMS audits. Forms 17-2a, 17-2b, 17-2c, 17-2d, and 17-2e are sample forms that can be used to document planning, implementation, reporting, and follow-up associated with your internal EMS audits. Example 17-1 and 17-2 are sample questionnaires/checklists that you can customize for use in guiding the work of your internal EMS audit team.



TOOLS Tool 17-1: EMS Auditing Worksheet

Have we developed an EMS audit program? If not, how will this be accomplished? Who need to be involved in the audit process?

Is there another audit program with which our EMS audits could be linked (for example, our quality or health & safety management system audits)?

Have we determined an appropriate audit frequency? What is the basis for the existing frequency? Should the frequency of audits be modified?

Have we selected EMS auditors? What are the qualifications of our auditors?

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

Have we conducted EMS audits as described in the audit program? Where are the results of such audits described?

How are the results of EMS audits communicated to top management?

How are the records of these audits maintained?

Our next step on EMS auditing is to …



Tool 17-2: Sample Procedure for EMS Audits Purpose To define the process for conducting periodic audits of the environmental management system (EMS). This procedure defines the process [Your Facility’s Name] will use to schedule, conduct, and report EMS audits. Scope This procedure applies to all internal EMS audits conducted at this plant. The scope of EMS audits may cover all activities and processes comprising the EMS or selected elements thereof. This will be specified at the initiation of each audit. General Internal EMS audits help to ensure the proper implementation and maintenance of the EMS by verifying that activities conform with documented procedures and that corrective actions are undertaken and are effective. All audits are conducted by trained auditors. Auditor training is defined by Procedure #. Records of auditor training are maintained in accordance with Procedure #. When a candidate for EMS auditor is assigned to an audit team, the Lead Auditor will prepare an evaluation of the candidate auditor’s performance following the audit. The EMS Management Representative (EMR) is responsible for maintaining EMS audit records, including a list of trained auditors, auditor training records, audit schedules and protocols, and audit reports. Training records also will be maintained by the Human Resource Manager in accordance with the EMS Training procedure (see Module 8 of this EMS Manual). EMS audits are scheduled to ensure that all EMS elements and plant functions are audited at least once each year. Form 17-2a shall be used to document the facility’s audit plan. The EMR is responsible for notifying EMS auditors of any upcoming audits a reasonable time prior to the scheduled audit date. Plant areas and functions subject to the EMS audit will also be notified a reasonable time prior to the audit. Form 17-2b shall be used to notify the facility’s EMS audit team. The Lead Auditor is responsible for ensuring that the audit, audit report and any feedback to the plant areas or functions covered by the audit is completed per the audit schedule. Forms 17-2c and 17-2d shall be submitted to the EMR in conjunction with the audit report. The EMR, in conjunction with the Lead Auditor, is responsible for ensuring that EMS Audit Findings Forms, Form 17-2e, are prepared for audit findings, as appropriate.



Procedure A. Audit Team Selection - One or more auditors comprise an audit team. When the team

consists of more than one auditor, a Lead Auditor will be designated. The Lead Auditor is responsible for audit team orientation, coordinating the audit process, and coordinating the preparation of the audit report.

B. Audit Team Orientation - The Lead Auditor will assure that the team is adequately prepared

to initiate the audit. Pertinent policies, procedures, standards, regulatory requirements and prior audit reports are made available for review by the audit team. Each auditor will have appropriate audit training, as defined by Procedure #.

C. Written Audit Plan - The Lead Auditor is responsible for ensuring the preparation of a written

plan for the audit. The Internal EMS Audit Checklist may be used as a guide for this plan. D. Prior Notification - The plant areas and / or functions to be audited are to be notified a

reasonable time prior to the audit. E. Conducting the Audit

1. A pre-audit conference is held with appropriate personnel to review the scope, plan and schedule for the audit.

2. Auditors are at liberty to modify the audit scope and plan if conditions warrant. 3. Objective evidence is examined to verify conformance to EMS requirements, including

operating procedures. All audit findings must be documented. 4. Specific attention is given to corrective actions for audit findings from previous audits. 5. A post-audit conference is held to present audit findings, clarify any misunderstandings,

and summarize the audit results. F. Reporting Audit Results

1. The Team Leader prepares the audit report, which summarizes the audit scope, identifies the audit team, describes sources of evidence used, and summarizes the audit results.

2. Findings requiring corrective action are entered into the corrective action database.



Procedure (cont’d.) G. Audit Report Distribution

1. The EMR is responsible for communicating the audit results to responsible area and / or

functional management. Copies of the audit report are made available by the EMR. 2. The EMR is responsible for ensuring availability of audit reports for purposes of the

annual Management Review (see Management Review Procedure in Module 18 of this EMS Manual.).

H. Audit Follow-up

1. Management in the affected areas and / or functions is responsible for any follow-up actions needed as a result of the audit.

2. The EMR is responsible for tracking the completion and effectiveness of corrective

actions. I. Record keeping

Audit reports are retained for at least two years from the date of audit completion. The EMR is responsible for maintaining such records. Forms 17-2a through 17-2e will be retained by the EMR. Auditor training records will be retained by both the EMR and the Human Resources Manager.



Form 17-2a: Sample Audit Plan Form

Area or Function to be Audited

Lead Auditor

Audit Team Members

Target Date

Special Instructions

• • • • •

• • • • •

• • • • •

• • • • •

• • • • •

• • • • •

• • • • •



Form 17-2b: Sample Form for Communications to Audit Team

ENVIRONMENTAL MANAGEMENT SYSTEM AUDIT

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



Form 17-2c: Sample Form for Internal Assessment Checklist Internal Assessment Team: Date of Internal Assessment: Signed: _____________________ EMS Procedures: Check each item assessed (includes auditing of records, where applicable): __ Environmental policy (adherence to policy commitments) __ Environmental objectives (progress; implementation of action plans) __ EMS responsibilities __ Identification of Environmental Aspects __ Identification of Legal Requirements __ Identification of Significant Environmental Aspects __ Development of Objectives, Targets, and Action Plans __ Conducting an Alternatives Evaluation __ Development of Operational Controls __ Environmental Training (Awareness and Task-Specific) __ Emergency Preparedness __ Review of New Products and Processes __ Documentation __ Conducting a Compliance Assessment __ Conducting an Internal Assessment __ Taking Corrective Action __ Management Review EMS Performance __ Achieved objective #1 __ Achieved objective #2 __ Achieved objective #3 Contact Person: Date Completed



Form 17-2d: Sample EMS Audit Summary Form

EMS AUDIT SUMMARY SHEET

Organization Audited: ______________________________________________

Lead Auditor: Date:

ELEMENT NUMBER AND DESCRIPTION

AUDIT RESULTS

No. of Majors / No. of Minors

A, N, or X*

4.2 Environmental Policy 4.3 Planning 4.3.1 Environmental Aspects 4.3.2 Legal and Other Requirements 4.3.3 Objectives and Targets 4.3.4 Environmental Management Program(s) 4.4 Implementation and Operation 4.4.1 Structure and Responsibility 4.4.2 Training, Awareness, and Competence 4.4.3 Communication 4.4.4 EMS Documentation 4.4.5 Document Control 4.4.6 Operational Control 4.4.7 Emergency Preparedness and Response 4.5 Checking and

Corrective Action

4.5.1 Monitoring and Measurement 4.5.2 Corrective and Preventive Action 4.5.3 Records 4.5.4 EMS Audit

4.6 Management Review

TOTAL

Legend: A = Acceptable: Interviews and other objective evidence indicate that the EMS meets all the requirements of that section of the standard.

N = Not Acceptable: The auditor has made the judgment that, based on the number and type of nonconformances, the requirements of that section of the EMS are not being met. X = Not Audited



Form 17-2e: Sample Form for EMS Audit Findings

EMS AUDIT FINDINGS FORM

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

EMS 14001 (or other EMS criteria) Reference: _________________________________

Date: _______________

Finding Number: _______________

Auditor: __________________________

Auditee’s Rep.: ______________________

Corrective Action Plan (including time frames): ________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ Preventive Action Taken: ________________________________________________________________________ ________________________________________________________________________________________________________________________________________________

Individual Responsible for Completion of the Corrective Action: ________________________________________

Date Corrective Action Completed: _____________________________

Corrective Action Verified By: ______________________________________________________Date: ______________



Example 17-1: Sample Questionnaire for EMS Audits Principle 1: Management Commitment

1-1 Has your parent company issued a formal, written statement of environmental policy? When? How was your facility or operation made aware of this policy?

1-2 Has senior management issued a facility-specific, formal, written statement of environmental policy? When? How were facility personnel made aware of this policy? Do new personnel receive a copy of the policy? How?

1-3 What procedures are in place for regular review of and updates to the policy?

1-4 Has your facility established short- and long-term environmental goals? Please describe the key objectives and targets.

1-5 How and by whom are these goals developed? Did representatives of a variety of functions and levels within the facility work together to develop environmental objectives and targets?

1-6 What is the basis for your environmental goals? Are they based on compliance with legal requirements? Parent company directives? Environmental impacts of the facility’s mission? Pollution prevention? Public perception? Employee initiatives?



Example 17-1: Sample Questionnaire for EMS Audits (Continued) Principle 1: Management Commitment (Continued)

1-7 What are your most recent environmental initiatives?

1-8 What is the approval process for new environmental initiatives at your facility?

1-9 How are funds allocated for new environmental initiatives? For the environmental program? Who is ultimately responsible for these funding decisions?

1-10 Is staffing for the environmental program appropriate to program requirements and facility environmental goals? What mechanisms exist to adjust staffing level or staff capabilities?

1-11 Are managers familiar with facility and operation-specific environmental policies, regulations, and pollution prevention opportunities? Do managers participate in process reviews, assessments, environmental committees, or other activities to improve environmental performance?

1-12 How is this facility perceived by local environmental groups and the surrounding community? Are there any specific issues, i.e., noise, water quality, that are of particular concern?



Example 17-1: Sample Questionnaire for EMS Audits (Continued) Principle 2: Compliance Assurance And Pollution Prevention

2-1 How and how often does the facility’s environmental staff communicate with federal, state, and local regulatory agencies? Historically, how would you characterize the facility’s relationship with these agencies?

2-2 Has the facility taken advantage of any EPA Technical Assistance programs? Other environmental technical assistance programs?

2-3 How does facility staff track and interpret new federal, state or local regulations, policies and programs, or changes to existing regulations, policies, and programs?

2-4 How are programs and procedures updated to reflect these changes?

2-5 How does facility staff maintain environmental documentation and records, e.g., manifests, TRI data? Who is responsible for reporting to federal or state agencies? Parent company?

2-6 Does the facility have an Emergency Response Plan? Spill Plan? What are the established procedures for an environmental emergency?



Example 17-1: Sample Questionnaire for EMS Audits (Continued) Principle 2: Compliance Assurance And Pollution Prevention (Continued)

2-7 Has the facility performed a pollution prevention assessment?

2-8 Does the facility have a pollution prevention plan that addresses all environmental impacts and compliance programs?

2-9 Does the facility have a formal plan to reduce or eliminate the purchase and use of hazardous materials and ozone depleting chemicals? Does the facility have a hazardous materials pharmacy or similar program?

2-10 Does the facility have an affirmative procurement program?



Example 17-1: Sample Questionnaire for EMS Audits (Continued) Principle 3: Enabling Systems

3-1 Does the facility have a formal, facility-wide environmental training program?

3-2 How are training requirements determined?

3-3 How are training records maintained?

3-4 What is the annual budget for environmental training?

3-5 Is funding available for staff development training opportunities?

3-6 What guidance is provided to staff concerning compliance with new or updated environmental regulations or policies?



Example 17-1: Sample Questionnaire for EMS Audits (Continued) Principle 3: Enabling Systems (Continued)

3-7 How do managers communicate environmental performance issues or goals to staff?

3-8 What other mechanisms are used to increase staff environmental awareness? Newsletters? Seminars?

3-9 Is there a formal outreach effort to communicate the facility’s environmental activities and programs to the community?

3-10 How does the facility evaluate the effectiveness of outreach efforts?



Example 17-1: Sample Questionnaire for EMS Audits (Continued) Principle 4: Performance And Accountability

4-1 What are the routine reporting relationships between the environmental management program and upper level management?

4-2 How does the environmental staff communicate with upper management about environmental performance and the status of specific environmental initiatives?

4-3 How does the environmental program communicate with managers and staff about environmental performance and the status of environmental initiatives?

4-4 How do employees provide input to environmental decisions?

4-5 Are environmental duties included in staff job descriptions and performance standards?

4-6 How is excellence in environmental performance recognized and rewarded?

4-7 How do managers review and respond to poor environmental performance?



Example 17-1: Sample Questionnaire for EMS Audits (Continued) Principle 5: Measurement And Improvement

5-1 What mechanisms are used to track and measure facility environmental performance? How often is such measurement performed?

5-2 Does the facility have a self audit or self monitoring program in place?

5-3 Does facility environmental staff conduct routine facility inspections? Tests of pollution control and monitoring equipment?

5-4 What are the current procedures for reporting an environmental problem? How does facility environmental staff track corrective action?

5-5 Does the parent company review facility environmental performance? How often are such reviews conducted?

5-6 Are written protocols or guidance documents used to conduct environmental performance reviews? Are summary reports available?



Example 17-1: Sample Questionnaire for EMS Audits (Continued) Principle 5: Measurement And Improvement (Continued)

5-7 Does this facility participate in any cooperative environmental programs with state, local or private organizations?

5-8 Does this facility participate in any Federal voluntary initiatives such as ENERGYSTAR or Performance Track?

5-9 What new environmental initiatives are planned for the facility?



Example 17-2: Sample Checklist for Top Management EMS Audits

Function: TOP MANAGEMENT

1. Environmental Policy Top Management

Objective Evidence

a. Describe your role in the development of the environmental policy.

b. How do you know that your policy is appropriate for your activities, products, and services?

c. What is management’s role in the review and revision of the policy?

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

e. How does the policy help guide organizational decisions?

f. How are employees made aware of the environmental policy?

g. How is the policy made available to the public?

[Auditor Note: Is there evidence that the policy was issued by top management? (e.g., Is the policy signed? By whom? At what level in the organization are they?)]

Notes:

2. Objectives and targets

Top Management Objective Evidence a. What are the environmental objectives and targets for your

organization? What is your role in approving them? What are the relevant functions and levels within your organization that support the attainment of each of the objectives and targets?

b. How are the environmental objectives linked to other organizational goals (and vice versa)?

c. Are the objectives/targets consistent with the goals of the environmental policy for prevention of pollution and continual improvement?

d. How were the objectives and targets developed by or communicated to management?

e. How does management keep up with progress in meeting their objectives and targets throughout the year?

f. How often are you informed of the status of the objectives and targets?

g. On what basis are the objectives and targets reviewed and modified?

Notes:



Example 17-2: Sample Checklist for Top Management EMS Audits (Continued)


3. Structure and responsibility

Top Management Objective Evidence a. At what level within the organization is the designated EMS

representative placed? Auditor Note: Is the EMS representative at a level within the organization to effectively implement an EMS for his/her organization?]

b. What authority does the EMS representative have to carry out his/her responsibilities?

c. How does the organization assess its resource needs for environmental management? How are these factored into operating and strategic plans (and vice-versa)?

d. What resources (financial, technical personnel) has management provided to develop or maintain the EMS?

e. How are you informed on the performance of the EMS? Do you receive routine reports?

f. Are responsibilities for the environmental management of the organization documented? If so, where? Is an integrated structure in place in which accountability and responsibility are defined, understood, and carried out?

g. How are these responsibilities communicated to all employees (including managers)?

Notes:

4. Communication

Top Management Objective Evidence a. How are you informed of the environmental issues within

your organization? How often does this take place? Does this include compliance issues?

b. How are you kept up to date with progress in meeting your organization’s environmental objectives and targets?

How is this information passed on to your managers?

c. How do you communicate with the organization on environmental issues?

How is this done? How frequently?

d. How does the organization handle inquiries from interested parties (e.g., the public, regulators, other organizations) on environmental matters?

Who has responsibility for responding to such inquiries?



Example 17-2: Sample Checklist for Top Management EMS Audits (Continued)


4.6 Management review

Top Management Objective Evidence a. Describe the organization’s management review process.

b. How often are management reviews performed? How was this frequency determined?

c. Who is involved in the management review process? What are their roles in this process?

d. What changes have been made to the EMS as a result of the last review?

Notes:



Module 18: Management Review


Tool 18-1: Management Review Worksheet................................................................ 18-5 Tool 18-2: Sample Procedure for Management Review .............................................. 18-6 Form 18-2: Sample Management Review Record ....................................................... 18-7



GUIDANCE Just as a person should have periodic physical exams, your EMS must be reviewed periodically by top management to stay “healthy”. Management reviews are one key to continual improvement and for ensuring that the EMS will continue to meet your organization’s needs over time. The goal of the review should be to allow management to bring about overall improvements. The scope and frequency of the review should depend upon the size and complexity of the organization and other factors that are determined relevant in each organization. Establish a senior management review process To maintain continual improvement, suitability, and effectiveness of your environmental management system, and thereby its performance, your organization’s senior management should review and evaluate your EMS at defined intervals, such as quarterly. The scope of the review should be comprehensive, though not all elements of your EMS need to be reviewed at once. Also, the review process may take place over a period of time. Review of the policy, objectives, and procedures should be carried out by the level of management that defines them. Some of the things that should be included in the management review follow:

1. results from assessments 2. the extent to which objectives and targets have been met 3. the continuing suitability of the EMS in relation to changing conditions and

information, and 4. concerns among relevant interested parties.



Questions for management to consider include: 1. Is our environmental policy still relevant to what we do? 2. Are roles and responsibilities clear and do they make sense? 3. Are we applying resources appropriately? 4. Are we meeting our regulatory obligations? 5. Are the procedures clear and adequate? Do we need others? Should we eliminate some? 6. What effects have changes in materials, products, or services had on our EMS and its

effectiveness? 7. How effective are our measurement and assessment systems? 8. Can we set new measurable performance objectives? 9. What effects have changes in materials, products, or services had on our EMS and its

effectiveness? 10. Do changes in laws or regulations require us to change some of our approaches? 11. What stakeholder concerns have been raised since our last review? 12. Is there a better way? What else can we do to improve? Create a continual improvement plan and check progress. Document observations, conclusions, and recommendations for necessary action. Assign action items for follow-up, and schedule the next regular review. Form 18-2 can be used to document your management review and assign action items for follow up. Management reviews also offer a great opportunity to keep your EMS efficient and cost-effective. For example, some organizations have found that certain procedures and processes initially put in place were not needed to achieve their environmental objectives or to control key processes. If EMS procedures and other activities don’t add value, eliminate them. The key question that a management review seeks to answer follows: “Is the system working?” (i.e., is it suitable, adequate, and effective, given our needs?)

Hints

• Two kinds of people should be involved in the management review process: - people who have the right information / knowledge about the EMS, - people who can make decisions about the organization and its resources (top

management). • Determine a management review frequency that will work best for your organization.

Some organizations combine these reviews with other meetings (such as director meetings). Other organizations hold “stand-alone” reviews. At a minimum, consider conducting management reviews at least once per year.



Hints (continued) • During management review meetings, make sure that someone records what issues were

discussed, what decisions were arrived at, and what action items were selected. Results of management reviews should be documented. Form 18-2 can be used to document management reviews.

• Management reviews should assess how changing circumstances might influence the suitability, effectiveness, or adequacy of your EMS. Changing circumstances might be internal to your organization (such as new facilities, new raw materials, changes in products or services, new customers, etc.) or might be external factors (such as new laws, new scientific information or changes in adjacent land use).

• After documenting the action items arising from your management review, be sure that someone follows up. Progress on action items should be tracked to completion.

• As you assess potential changes to your EMS, consider other organizational plans and goals. In this way, environmental decision-making can be integrated into your overall management and strategy.

Tool 18-1 is a questionnaire to help guide your facility in establishing and maintaining an EMS Management Review element. If you desire to make a documented procedure for Management Review of your facility’s EMS, then Tool 18-2 is an example of a procedure you could adapt. Form 18-2 can be used to document the management reviews in accordance with your procedure.



TOOLS Tool 18-1: Management Review Worksheet

Do we have an existing process for conducting management reviews? If yes, does that process need to be revised? In what way?


When is the best time for us to implement this process? Can this effort be linked to an existing organizational process (such as our budget, annual planning, or auditing cycles?)

How frequently are management reviews? What is the basis for this frequency? Should we conduct reviews more or less frequently?

Who is responsible for gathering the information needed to conduct management reviews? Who is responsible for presenting this information?

How do we ensure that changing circumstances (both internal and external to the organization) are considered in this process?

How do we ensure that the recommendations of management reviews are tracked and acted upon ?

Our next step on management review is to …



Tool 18-2: Sample Procedure for Management Review Purpose To ensure the effectiveness of the EMS and its continual improvement, [Your Facility’s Name]’s top management periodically reviews the important elements and outcomes of the EMS. General The Management Review process is intended to provide a forum for discussion and improvement of the EMS and to provide management with a vehicle for making any changes to the EMS necessary to achieve the organization’s goals. Procedure 1. In preparation for the management review, the EMS management representative (EMR)

gathers the following information and makes it available to top plant management, including the owner, company President, and the plant manager: • Environmental policy • List of the Cross Functional Team (CFT) members and others responsible for major

parts of the EMS • List of significant environmental aspects and criteria of significance • Update on compliance status of the plant and on any potential upcoming regulations

that might require an advance strategy • List of environmental objectives and targets • Environmental performance results (from monitoring and measuring Significant

Environmental Aspect indicators and indicators of progress toward environmental objectives and targets)

• Bullet-point descriptions of other accomplishments of the EMS (e.g., number of people trained)

• Results of most recent EMS internal assessment, compliance assessment and corrective actions taken

• Description and documentation of feedback from stakeholders (if received) • Analysis of the costs and benefits of the EMS (as quantitative as possible)

2. Top plant management meets to review and discuss the information presented. The EMR

and EMS Coordinator will also be present. Depending on its review, top management may direct specific and/or significant changes in the scale and direction of the EMS in order to improve its effectiveness and business value. The conclusions and directives that result from the management review are recorded on Form 18-2 and kept by the EMS Coordinator.

Frequency Quarterly. Records Results of management reviews are recorded using Form 18-2. Records are kept by the EMS Coordinator.



Form 18-2: Sample Management Review Record

EMS Management Review Record

Date of review meeting

Persons present at meeting

Name Position

Conclusions Actions to be taken Person(s) responsible

Signed: _______________________ __________________________

Environmental Management Plant Manager Representative


Appendices

APPENDICES

Ø Appendix A: Glossary Ø Appendix B: EPA’s National Environmental Performance Track Ø Appendix C: Quality Management Systems Integration Ø Appendix D: Health and Safety Integration Ø Appendix E: Environmental Aspect/Impact Ranking


Appendix A - 1

Appendix A Glossary

Alternatives evaluation: Process by which alternative methods for completing a particular function are evaluated using business and environmental criteria. Cross functional team (CFT): Members of an organization who are responsible for representing their area or department in several facets of the EMS, e.g., establishing environmental aspects, determining significant aspects, setting objectives and targets, implementing environmental management programs, reviewing and tracking EMS internal audits results, and serving as an information resource. The CFT meets to discuss the EMS on a regular basis. Document: Written communication that presents an organization’s policy, procedures, and requirements. Documents describe the EMS, provide a basis for auditing, provide continuity of the EMS and its requirements during changing circumstances, support training of personnel in EMS requirements, present the EMS for external purposes, demonstrate the conformance of the EMS in contractual situations, and allow improvement in the control of practices and environmental management activities. EMS coordinator: A member of the organization whose responsibility is to identify, assign, schedule, provide the necessary support for, and ensure completion of all tasks relating to the EMS. The coordinator works closely with the EMR and with the CFT. The EMS coordinator is also responsible for maintaining this manual, under the leadership of the management representative. It is possible for the functions of EMS coordinator and EMR to be performed by the same person. Environmental aspect: An element of a company’s activities, products, or services that can or does interact with the environment (create an environmental impact). Environmental impact: Any change to the environment, whether adverse or beneficial, resulting from a company’s activities, products, or services. Environmental management program (EMP): Action plans necessary to achieve the objectives and targets. Environmental management representative (EMR): Member of the organization’s top management group who is responsible for the functioning of the EMS. An EMR ensures that all tasks relating to the EMS are identified and completed in a timely manner. An EMR is responsible for reporting periodically to the top plant management group on the progress and results of the EMS.


Appendix A - 2

Non-conformity: Discrepancy between a company’s actual EMS activities and the procedures laid out in their EMS manual and associated documentation (that is, where the actual activities do not follow the procedures). Objective: Overall environmental goal, arising from the environmental policy, that an organization sets itself to achieve, and which is quantified where practicable. Outcome measure: Key monitoring and measurement characteristics associated with results, i.e. by-products or environmental- impacting outputs, of a process or activity, such as amount of waste generated (per unit of production) or the number of spill occurrences (per unit of time). Performance indicator: Measurement criteria that allow an organization to evaluate the success of the overall EMS program (as opposed to measurement criteria developed for evaluating progress toward individual objectives). Process measure: Key monitoring and measurement characteristics associated with "upstream" factors of a process or activity, such as the amount of paint used per unit of product or percent of employees trained on a topic related to environmental improvement. Record: Written evidence established and maintained to track performance of an EMS and to demonstrate conformance with EMS requirements. Root cause analysis: Systematic process to uncover underlying causes of a particular issue or problem. If a drum is not labeled, you would ask what happened that resulted in the unlabeled drum (for example, a new employee did not know the procedure, which would indicate that entry training might be a root cause of the issue). Significant environmental aspect (SEA): An environmental aspect deemed by a company as having, or potentially having, a significant impact on the environment. Stakeholder: Anyone who has a stake in your company’s environmental performance. Internal stakeholders may include employees, shareholders, customers, suppliers, investors and insurers. External stakeholders may include neighbors, community organizations, environmental groups, larger companies, the media, and the general public. Target: Detailed performance requirement, quantified where practicable, applicable to the organization or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives.


Appendix B - 1

Appendix B EPA’s National Environmental Performance Track

The National Environmental Performance Track is designed to recognize and encourage top environmental performers – those who go beyond compliance with regulatory requirements to attain levels of environmental performance and management that benefit people, communities, and the environment. As top environmental performers, participants earn access to a unique reward package that includes recognition, better information, and administrative streamlining. The Performance Track consists of two levels. The first level, the National Environmental Achievement Track, is available now and is open to facilities of all types, sizes, and complexity, public or private, manufacturing or service-oriented. It is designed to recognize facilities that consistently meet their legal requirements and have implemented high-quality environmental management systems, as well as encourage them to even better achievement by continuously improving their environmental performance and informing and involving the public. The second level, the National Environmental Stewardship Track, is currently under development and will be designed to recognize and encourage broader and higher levels of voluntary environmental performance than those expected under the Achievement Track. To qualify for Achievement Track, facilities must have:

• A systematic approach to managing environmental responsibilities (an EMS) • A strong record of environmental compliance • Demonstrated continual improvement • Public Reporting of Progress

Specific Environmental Management System (EMS) Requirements Facilities wanting to participate in the Performance Track must meet several requirements. A facility will certify that it has an EMS in place.1 The EMS will include the elements listed below and will have gone through at least one full cycle of implementation (i.e., planning, setting performance objectives, EMS program implementation, performance evaluation, and management review). A facility that has adopted systems based on EMS models with a Plan-Do-Check-Act framework would meet most of these elements.

1 For purposes of the Achievement Track, an EMS represents an organization’s systematic efforts to meet its environmental requirements, including maintaining compliance and achieving performance objectives that may be related to unregulated aspects of the organization’s activities.


Appendix B - 2

EPA recognizes that the scope and level of formality of the EMS will vary, depending on the nature, size, and complexity of the facility. EPA's experience with a variety of programs suggests that these EMS elements are within the capability of small facilities and can be met through a variety of approaches. To help small facilities implement an EMS, EPA will make guidance documents and assistance materials available. A facility will certify that it has implemented an EMS that includes these elements: Policy A written environmental policy, defined by top facility management, that includes commitments to: (1) compliance with both legal requirements and voluntary commitments; (2) pollution prevention (based on a pollution prevention hierarchy where source reduction is the first choice); (3) continuous improvement in environmental performance, including areas not subject to regulations; and (4) sharing information about environmental performance and the operation of the EMS with the community. Planning

• Identification of significant environmental aspects2 and legal requirements, including procedures for integrating anticipated changes to the facility's requirements or commitments into the EMS.

• Measurable objectives and targets to meet policy commitments and legal requirements, to reduce the facility’s significant environmental impacts, and to meet the performance commitments made as part of the facility’s participation in the program. In setting objectives and targets, the facility should consider the following criteria: preventing non-compliance, preventing pollution at its source, minimizing cross-media pollutant transfers, and improving environmental performance.

• Active, documented programs to achieve the objectives, targets, and commitments in the EMS, including the means and time-frames for their completion

Implementation and Operation

• Established roles and responsibilities for meeting objectives and targets of the overall EMS and compliance with legal requirements, including a top management representative with authority and responsibility for the EMS.

2 An “environmental aspect” is defined as an “element of an organization’s activities, products, or services that can interact with the environment.” Facilities are asked to use their list of significant environmental aspects in selecting performance commitments under this program.


Appendix B - 3

• Defined procedures for: (1) achieving and maintaining compliance and meeting performance objectives; (2) communicating relevant information regarding the EMS, including the facility’s environmental performance, throughout the organization; (3) providing appropriate incentives for personnel to meet the EMS requirements; and (4) document control, including where documents related to the EMS will be located and who will maintain them.

• General environmental training programs for all employees, and specific training for those whose jobs and responsibilities involve activities directly related to achieving objectives and targets and to compliance with legal requirements.

• Documentation of the key EMS elements, including the environmental policy, significant environmental aspects, objectives and targets, a top management representative, compliance audit program, EMS audit program, and overall EMS authority.

• Operation and maintenance programs for equipment and for other operations that are related to legal compliance and other significant environmental aspects.

• An emergency preparedness program. Checking and Corrective Action

• An active program for assessing performance and preventing and detecting non-conformance with legal and other requirements of the EMS, including an established compliance audit program and an EMS audit program.

• An active program for prompt, corrective action of any non-conformance with

legal requirements and other EMS requirements. Management Review

• Documented management review of performance against the established objectives and targets and the effectiveness of the EMS in meeting policy commitments.

*******

Although a third-party audit of the EMS is not necessary to qualify for the Achievement Track, a facility is asked in the application form if it has undergone such an audit. If it has not, it will have conducted a self-assessment. A facility will retain EMS documentation and provide a summary of its performance, including performance against objectives and targets, and a summary of the results of compliance and EMS audits, in its Annual Performance Report.


Appendix B - 4

Special Consideration for Small Businesses Any program for improving environmental performance must aim for participation by small businesses and other small entities, such as local governments. EPA is making every effort to make the Achievement Track accessible for small entities. This effort is reflected in several aspects of the design. For example, depending on the nature and extent of a facility’s operations, the EMS for a small facility may be simpler than one for a larger, more complex facility. For the same reason, a small facility may have fewer environmental aspects. In addition, a small facility is not asked to make as many performance commitments as other participants. For more information about the National Environmental Performance Track, contact the EPA via: Web: www.epa.gov/performance track E-Mail: [email protected] Phone: 888-339-PTRK


Appendix C - 1

Appendix C

Integration of Environmental Management Systems and Quality Management Systems

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


Appendix C - 2

to products or processes for quality purposes. Organizations that have a QMS in place generally are better off when implementing an EMS for several reasons. First, employees typically are already familiar with management system concepts and are involved in making the system work. Second, many of the processes needed for the EMS might already be in place. Finally (and perhaps most importantly), top management has committed the use of management systems to achieve organizational goals. Figure C-1. Relationship of EMS Elements to QMS (based on ISO 9001: 1994) Elements that are Essentially the Same F Training, Awareness & Competence F Document Control F Nonconformance, Corrective &

Preventive Action F Calibration (part of the Monitoring &

Measurement element) F Records Elements that are Similar F Policy F Structure and Responsibility F Documentation F Operational Control F Monitoring & Measurement F Audit F Management Review Elements that are Unique to EMS F Environmental Aspects F Legal and Other Requirements F Objectives & Targets F Environmental Management

Program(s) Communications F Emergency Preparedness &

Response


Appendix C - 3

A Few Tips on System Integration For organizations that have an existing QMS and wish to integrate an EMS with it, some suggestions are provided below. F Understand the existing QMS, its effectiveness and how the workforce perceives the system.

Is the existing QMS documentation clear and workable? Do employees believe that the system is helping the organization to achieve desired results?

F Ensure that the scope of the two systems will be consistent (i.e., that the systems will cover

the same facilities, products, activities and/or services). In particular, this will be an important issue if third-party registration will be sought.

F Establish a cross-functional team (including, at a minimum, representatives from the

environmental and quality functions) to determine the optimal approach to system integration.

F As needed, manage resistance to change. Some employees and managers may be reluctant to

change a system that they are already familiar with and/or in which they have important roles.

F Understand how QMS and EMS differ in purpose. While there are many common

management system elements, there are elements of each system that are unique (see below). In the case of EMS, these include for example, environmental aspects, communications, and emergency preparedness and response. These differences must be acknowledged and accommodated within the integrated management system.

F Modify system documentation as required. Keep procedures simple and clear for users.

Review proposed changes with affected managers and employees. F On a procedure-by-procedure basis, consider whether to integrate procedures or keep them

separate. While integration can reduce the total number of procedures or work instructions, it also can confuse the overall purpose of such procedures in some cases.

F Once the integrated system documentation has been prepared, train managers and

employees on the integrated system. F Audit the integrated system and take actions as necessary.


Appendix C - 4

A few final thoughts on system integration:

• Can your organization afford to have two or more separate systems? • Are there compelling reasons to keep these systems separate? • What is the optimal approach from a strategic and operational standpoint? • What approach is best suited for the organization’s change and growth?


Appendix D - 1

Appendix D Health and Safety Integration Questionnaire

L Tip Remember to consider health and safety of workers, as well as people outside your plant, when evaluating known health concerns. 1. Does your company have an Environmental, Health & Safety Policy?

• Is this policy written down? • Where is it located? • How many employees know about this policy? • How did they learn of it? Is it included in a training or orientation program? • Do employees have the opportunity to make suggestions regarding environmental

concerns? • What points are included in this policy?

2. Does your company have specific environmental or health & safety goals?

• Are these documented? • How are these communicated to employees? • Is there a way of tracking whether goals are met? • Are there pena lties within the company for not achieving the objectives? • Is there a way to change these goals when changes in processes, production, or activities

occur? How are these changes communicated? 3. Does your company have a process to identify all environmental, health & safety regulatory

requirements? • Has your company conducted compliance audits? • Has your company received any fines or penalties requiring corrective action? • Has your company experienced difficulties in complying with regulations? • Are some regulations difficult/costly to meet? • Does your company know whom to contact at local, state, and federal regulatory agencies

in the event of environmental accidents or compliance concerns? • Does your company have a mechanism for staying up to date on changing regulations?

4. How does your company evaluate risk to human health & safety and the environment caused

by your business operations? How is this information incorporated into planning for business activities/production?

5. Is there a process within the company to review any changes in products or processes with an

eye toward environmental concerns?


Appendix D - 2

L Tip As you discuss these questions, it will be beneficial to write down the answers for reference as you proceed with the following questions. 6. Are there policies and procedures regarding procurement and contracting that consider

environmental concerns? 7. What training is offered at your company that would support environmental objectives?

• Do employees receive environmental, health & safety training? What percent of employees? Which ones?

• How is that training documented? Where are the records kept? • Is there provision for regular training on environmental, health & safety requirements?

L Tip As you discuss these questions, it will be beneficial to write down the answers for reference as you proceed with the following questions. 8. Does your company have a procedure for responding to suggestions regarding environmental

concerns that it may receive from customers, neighbors, or employees? • Is there a process for soliciting and recording any “suggestions”? Where are these

records kept? • Is there a process for following up on any of these suggestions to be sure that appropriate

action was taken? L Tip You should review your environmental and/or health and safety policy statement(s) as you complete the questions following this item to determine whether changes need to be made. 9. How does your company keep track of its documents?

• Is there a filing system? • How many people are familiar with the system? • How many people have access to it? • How could someone find information relating to environmental, health & safety

concerns? Are there Material Safety Data Sheets (MSDS) available? Does your company have documented standard operating procedures for plant operations, emergencies, or document control?

• How are decisions made about when to dispose of documents?


Appendix D - 3

10. How does your company identify potential accidents or emergency situations? • Are emergency procedures documented? • How do employees find out about them? Is there regular training? • Are these procedures periodically tested, evaluated, and revised as needed? • Have there been failures in response to accidents or emergency situations? • Is there a communications plan in place in the event of emergencies?

Shipbuilding and Ship Repair Industry - EMS Template Revision 3.0 (November 2001)

Appendix E - 1

Appendix E Environmental Aspect/Impact Ranking

Guidance .....................................................................................................................................E-2 Figures..................................................................................................................... as shown below

Figure E-1: Example of Ranking Symbols ....................................................................E-3 Figure E-2: Sources of Information About Chemicals ..................................................E-4 Figure E-3: Information on an MSDS ...........................................................................E-5

Tools ............................................................................................................................................E-8

Tool E-1: Worksheet for Health, Safety, and Potential Environmental Concerns.........E-8 Tool E-2: Worksheet for Exposure to Chemicals and Material.....................................E-9 Tool E-3: Worksheet for Impact Ranking....................................................................E-10 Tool E-4: Sample Identification and Significance Determination of Environmental Aspects and Setting Objectives and Targets That Includes Impact Ranking ................E-11

Examples...................................................................................................................................E-12

Example E-1: Worksheet for Health, Safety, and Potential Environmental Concerns—Non-abated VOC and HAP Emissions .......................................................E-14 Example E-2: Worksheet for Exposure to Chemicals and Material — Non-abated VOC and HAP Emissions ..............................................................................................E-15 Example E-3: Worksheet for Impact Ranking — Non-abated VOC and HAP Emissions ..............................................................................................................E-16


Appendix E - 2

GUIDANCE

Using Environmental Risk Information to Rank Impacts of Your Environmental Aspects This appendix provides several environmental aspect/impact ranking tools that involve risk management techniques. These tools are presented as an optional methodology that could be integrated into the significance determination criteria that have been presented in Tool 5-2 for a Sample Procedure for Identification of Environmental Aspects and Determination of Significant Aspects — specifically the last criterion that addresses the potential impact to the environment. That is, if an aspect has not been determined to be significant as a result of regulatory requirements, company policy/goals, community concerns, or pollution prevention potential, then risks associated with environmental impacts can be considered. An example of how to include aspect/impact ranking into the Form 5-2: Identification and Significance Determination of Environmental Aspects and Setting Objectives and Targets is provided. Though not a formal risk assessment, this appendix can help you apply your familiarity and judgment about chemical and material use at your facility to the significance determination process. It presents:

• A brief introduction to the concept of risk and to ranking symbols • Guidance in gathering chemical and material effects information • A method to rank impacts on the basis of effects • A method for making judgments about exposure to chemicals and materials and ranking

impacts according to exposure • A method for laying out risk as well as other environmental concerns and ranking

impacts considering these factors Risk Risk assessment, in brief, is a process that integrates the work of several sciences to determine the kind and degree of environmental and human health impacts potentially produced by exposure to a chemical or material. Risk is composed of two parts: toxicity (or potential effects) and exposure. Toxicity is the ability to cause harm to the health of humans, wildlife, or vegetation, as well as the type and seriousness of that effect. You will collect the information needed to form a judgment about effects in Tool E-1: Worksheet for Health, Safety, and Potential Environmental Concerns . You will review the chemical effects information for aspects that reach the stage in the process of applying this criterion. You will assign a rank based on your judgment of the seriousness of the effects of this chemical or substance.


Appendix E - 3

Exposure is the amount of material with which workers, the community, or the environment come into contact. The amount is determined by both severity and time of contact. Severity refers to the amount of material that one can come into contact with at any one time. The time of contact depends on the number of times that contact occurs in a given period (the frequency of contact) and the duration of the contact. You will collect the information needed to form a judgment about exposure in Tool E-2: Worksheet for Exposure to Chemicals and Materials. Contact with humans and animal or plant life is characterized as occurring along pathways. These pathways describe the routes along which the substance must travel, before it enters an animal or plant, and how the substance is taken up by the living organism. Several pathways for human exposure include:

• Breathing the material (inhalation pathway), • Touching the material (skin or dermal pathway), and • Ingesting (eating or drinking) the material (oral pathway).

Using Ranking Symbols One way to rank environmental impacts is to use symbols representing a range of high (H) to low (L). Whatever ranking you use (Figure E-1 shows an example), phrase the meaning consistently across all ranking categories; this is most straightforward if you think of “high” as meaning a project you would ultimately like to undertake and “low” as one having lesser priority. Thus, when considering environmental effects, a chemical receiving a “low” rank would be one with low impact or good environmental performance. Figure E-1: Example of Ranking Symbols

Symbol Meaning EMS Meaning

H High Most environmental impact

Mi-H Moderately High More environmental impact

M Moderate Medium environmental impact

Mi-L Moderately Low Lower environmental impact

L Low Lowest environmental impact


Appendix E - 4

Identify and Rank Potential Human Health and Environmental Effects of Chemicals and Materials To rank the environmental impacts associated with chemicals and materials used in your business operations, you will need to find information on the human health and environmental effects associated with those chemicals. Unfortunately, there is no single and comprehensive source of information for most chemicals. Information that will help you understand the effects associated with the chemicals you use may be located in several different sources. By taking the time and effort to find information about the chemicals you use, you will be able to understand the potential effects of the chemicals on humans and on the environment. You will also know how to use them in a way to minimize or avoid harmful effects. You can decide whether you want to continue using your current chemicals, or find alternatives that would mitigate any potential harmful impact. Figure E-2: Sources of Information About Chemicals

Organize the information you have into a format that will enable you to make comparisons among aspects. You may find that sometimes there exists very little information for a particular chemical. That discovery in itself is useful. By using this format and showing where information gaps occur, you will know that whatever decision you make now about using a specific chemical may change if information becomes available at a later date. Although you may want to use the chemical now, you may need to make adjustments later when more information becomes available. Tool E-1: Worksheet for Health, Safety, and Potential Environmental Concerns will help you organize your information on the chemicals you use in your business activities. The column headings list the categories and specific information needed. The final column asks for your judgment about the ranking of the environmental concerns associated with the chemical or material under consideration. Figure E-3: Information on an MSDS lists the kinds of information OSHA requires on an MSDS. Most of the kinds of information listed below can be used to fill in the columns on Tool E-1: Worksheet for Health, Safety, and Potential Environmental Concerns . Much of the environmental information will have to be found elsewhere.

• Manufacturer’s Safety Data Sheets (MSDSs). These are supplied by the manufacturer according to OSHA regulation. You should receive a MSDS with any chemicals you purchase. They should be kept in a location that is available for review.

• Your suppliers. Ask them for hazard and exposure information on any products you purchase. Ask them to supply the environmental information that is not on the MSDS.

• Your trade association. • EPA or state environmental agency. • Online sources in various websites, e.g. various EPA programs. (EPA’s DfE Program

website contains a Risk Guide with additional information.)


Appendix E - 5

Figure E-3: Information on an MSDS

As defined by the Occupational Safety & Health Administration (OSHA) (29 CFR 1910.1200), an MSDS is written or printed material concerning a hazardous material which contains the following:

• The identity of the hazardous material (except as provided for materials that are trade secrets).

• The physical and chemical characteristics of the hazardous chemical (such as vapor pressure, flash point).

• The physical hazards of the hazardous chemical, including the potential for fire, explosion, and reactivity.

• The health hazards of the hazardous chemical, including signs and symptoms of exposure, and any medical conditions which are generally recognized as being aggravated by exposure to the chemical.

• The primary route(s) of entry. • The OSHA PEL (Permissible Exposure Level), the ACGIH (American Conference

of Governmental Industrial Hygienists) Threshold Limit Value, and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the MSDS, where available.

• Whether the hazardous chemical is listed in the National Toxicology Program (NTP) Annual Report on Carcinogens (latest edition) or has been identified as a potential carcinogen in the International Agency for Research on Cancer (IARC) Monographs (latest editions) or by OSHA.

• Any generally applicable precautions for safe handling and use which are known to the chemical manufacturer, importer, or employer preparing the MSDS, including appropriate hygienic practices, protective measures during repair and maintenance of contaminated equipment, and procedures for cleani-up of spills and leaks.

• Any generally applicable control measures which are known to the chemical manufacturer, importer or employer preparing the MSDS, such as appropriate engineering controls, work practices, or personal protective equipment.

• Emergency and first aid procedures. • The date of preparation of the MSDS or the last change to it. • The name, address, and telephone number of the chemical manufacturer, importer,

employer or other responsible party preparing or distributing the MSDS, who can provide additional information on the hazardous chemical and appropriate emergency procedures, if necessary.


Appendix E - 6

Ranking Your Significant Environmental Aspects Now you will put the effects information together with the exposure information and consider some additional information. The following paragraphs explain how to use Tool E-3: Worksheet For Impact Ranking. Chemical and Material Risk Place both the ranking for effects from Tool E-1: Worksheet for Health, Safety, and Potential Environmental Concerns and the ranking for exposure from Tool E-2: Worksheet for Exposure to Chemicals and Materials in the appropriate columns. The effects rank for humans would be placed in both the worker and community columns of Tool E-3: Worksheet For Impact Ranking. Worker Safety Look at the information in Tool E-1: Worksheet for Health, Safety, and Potential Environmental Concerns under worker safety and apply a judgment of ranking. Enter this rank in the worker safety column of Tool E-3: Worksheet For Impact Ranking. Overall Impact Ranking and Significance Review the columns for the aspect and make a judgment as to whether it should be determined H, Hi-M, M, Mi-L, L in rank. This can be done in two ways. 1. Look across the columns and assign a total that in your judgment best reflects the

individual ranks in each column. 2. Assign a number from 1-5 to each rank such that H = 5 and L = 1. To get an average

rank for a particular row, sum the ranks across the columns and then divide by the number of columns. For example, if the total of the ranks were 20, and you have 6 individual effects and exposure rankings then the average rank is 3.33. This corresponds approximately to a Mi-H ranking overall. Thus, place Mi-H in the total column and yes (Y) in the significance column.

Integrating Impact Ranking into Significant Aspect Determination If you choose to include impact ranking as part of your significant aspect determination procedure then you can substitute, in place of the “Potential Impact to the Environment” column on Form 5-2: Identification and Significance Determination of Environmental Aspects and Setting Objectives and Targets, one labeled “Impact Ranking” as shown in Tool E-4: Sample Identification and Significance Determination of Environmental Aspects and Setting Objectives and Targets That Includes Impact Ranking.


Appendix E - 7

Grouping Environmental Aspects In reviewing your facility’s list of environmental aspects you may discover that some aspects occur in more than one process step. Energy use is a good example. It might be effective in some circumstances to combine all the process steps having energy aspects, and develop a facility-wide strategy and program for achieving improvement. Understand, however, that the energy aspect should be ranked in each process step to determine its relative importance in that step. For example, energy use in office work might be a different priority than energy use in a manufacturing step. In addition, standards and procedures developed to reduce energy use would be different for each process step. Consequently, although you might achieve certain efficiencies through a facility-wide effort, your actual environmental improvement will be attained through objectives set for each process step. Consider “Practical” Criteria Also To determine which significant environmental aspects will become projects, it is important to consider the economic and technical feasibility and the time frame for your facility. It is also important to consider what improvements could be expected from each project. Selecting high-priority projects is desirable from an environmental perspective, but there is value in undertaking some short term, “easier to implement” projects that may not be ranked high in environmental risk. The easier projects provide a useful learning experience, boost confidence as people see results, and focus attention on environmental goals. Finally, compare in general the expected improvements to be gained by working on each aspect. Like any undertaking in a business operation, you should be able to describe what you expect to get before you undertake the project! First, develop a list of benefits criteria. These might include such things as:

• Reduced human health impacts • Reduced environmental impacts • Cost savings • Improved community relations • Improved employee morale • Customer benefit.

Make a list of criteria identifying kinds of improvements that could be derived from undertaking environmental projects. These expected improvements need not be ranked; simply describe the potential for each criterion to be achieved.


Appendix E - 8

TOOLS Tool E-1: Worksheet for Health, Safety, and Potential Environmental Concerns

Regulatory Data

Human Health Effects by Pathways

Acute and Chronic

Effects on Wildlife or Other Environmental

Effects Rank

Process

Asp

ect*

Info

rmat

ion

Sour

ce

Car

cino

gen?

O

SHA

Per

mis

sibl

e

Exp

osur

e L

imit

(PEL

)?

Vol

atile

Org

anic

C

ompo

und

(VO

C)?

T

oxic

Rel

ease

In

vent

ory

(TR

I)?

Inha

latio

n D

erm

al

Inge

stio

n A

ir Wat

er

Lan

d Sa

fety

C

once

rns

Hum

an

Env

iron

men

t

Contact Person: Date Completed: *For aspects not determined significant by other previous criteria See Example E-1 on how to fill out this worksheet.


Appendix E - 9

Tool E-2: Worksheet for Exposure to Chemicals and Materials

Exposure Time

Pathway

Rank Exposed Groups Process

Aspect*

Quantity Used per

Time Period

Duration

Frequency

Personal Protective Equipment

(PPE)

Human (inhalation,

dermal, oral)

Environ-mental

(air, water, land)

Workers

Community

Environ-ment



Appendix E - 10

Tool E-3: Worksheet for Impact Ranking

Chemical and Material Risk Process

Aspect* Worker

Effects/

Exposure

Community Exposure

Environment

Effects/Exposure

Worker

Safety

Impact

Ranking

Significant?

Y/N



Appendix E - 11

Tool E-4: Sample Identification and Significance Determination of Environmental Aspects and Setting Objectives and Targets That Includes Impact Ranking

Person Completing Form: Area/Process: Date:



uant

ity

or

Vol

ume

Leg

al R

equi

rem

ents

/ V

olun

tary

Com

mit

men

ts,

Com

pany

Pol

icy

Com

mun

ity

Con

cern

Pol

lutio

n P

reve

ntio

n P

oten

tial

Impa

ct R

anki

ng

N o




I = improve Target Energy Usage: Water Usage: Supplies/ Disposables:

Chemicals: Air Emissions: Noise/Odor/Radiation: Wastes: Water Discharges: Stormwater Discharges:

Spillage and Other:


Appendix E - 12

EXAMPLES

Environmental Aspects/Impact Ranking Example for New Construction Indoor Painting The following example shows you how to rank impacts using risk management techniques for aspects that have not been determine as significant by other criteria. It is important that you think through even solutions that seem obvious, because sometimes you might find a better solution. This is a hypothetical example that pertains to new construction indoor painting. Let us assume that a number of aspects have already been determined to be significant because they were the subject of regulatory requirements, company policy/goals, were significant community concerns, and had high pollution prevention potential. However, at least one of the aspects, “Non-abated emissions of VOCs and HAPs from overspray (solvents and dry paint particles) and equipment cleaning solvents” did not meet these criteria and therefore you decided to do an environmental aspect/impact ranking to determine significance. Examples of assessments of exposure, effects, and worker safety risks associated with“Non-abated emissions of VOCs and HAPs from overspray (solvents and dry paint particles) and equipment cleaning solvents” are provided in Examples E-1 and E-2. The decisions that were made using these worksheets was then transferred to Example E-3: Worksheet for Impact Ranking — Non-abated VOC and HAP Emissions How to Obtain Overall Rank: this can be done in two ways. 3. Look across the columns and assign a total that in your judgment best reflects the

individual ranks in each column. 4. Assign a number from 1-5 to each rank such that H = 5 and L = 1. Sum these across the

columns and then divide by the number of columns used to get an average rank for that row. For VOC and HAP non-abated emissions the total would be 20. Divide by 6 (the number of individual ranks). The average rank would be 3.33, which corresponds with Mi-H. Place Mi-H in the total column.

Meaning of Rank The total for ranking the environmental impact of non-abated VOS and HAPs emissions was Mi-H and therefore should be considered significant. This would mean that this aspect would then


Appendix E - 13

become the focus of an improvement objective and an associated target. Consequently an environmental management program (EMP) describing who would doing what and by when to achieve the target would also be drafted and monitored for progress. EMPs are operational controls for improvement objectives such as the one that would be associated with reduction in non-abated VOC and HAPs emissions.


Appendix E - 14

Example E-3: Worksheet for Health, Safety, and Potential Environmental Concerns — Non-abated VOC and HAP Emissions

Regulatory Data

Human Health Effects by Pathways

Acute and Chronic

Effects on Wildlife or Other Environmental

Effects Rank

Process

Aspect* In

form

atio

n So

urce

Car

cino

gen?

O

SHA

Per

mis

sibl

e

Exp

osur

e L

imit

(PEL

)?

Vol

atile

Org

anic

C

ompo

und

(VO

C)?

T

oxic

Rel

ease

In

vent

ory

(TR

I)?

Inha

latio

n D

erm

al

Inge

stio

n A

ir Wat

er

Lan

d Sa

fety

C

once

rns

Hum

an

Env

iron

men

t

New Construction Indoor Painting

Non-abated emissions of VOCs and HAPs from overspray (solvents and dry paint particles) and equipment cleaning solvents such as xylene

MSDS No 100 ppm

Yes Yes Acute and Chronic

Acute Low toxicity

Ozone Degradation

NA NA Flammable

H L

Contact Person: Date Completed: *For aspects not determined significant by other previous criteria Corresponds Tool E-1: Worksheet for Health, Safety, and Potential Environmental Concerns


Appendix E - 15

Example E-3: Worksheet for Exposure to Chemicals and Materials — Non-abated VOC and HAP Emissions

Exposure Time

Pathway

Rank Exposed Groups Process

Aspect*

Quantity Used per

Time Period

Duration

Frequency

Personal Protective Equipment

(PPE)

Human (inhalation,

dermal, oral)

Environ-mental

(air, water, land)

Workers

Community

Environ-ment


Non-abated emissions of VOCs and HAPs from overspray (solvents and dry paint particles) and equipment cleaning solvents

50 ppm Entire shift Continuous Respirator Inhalation, dermal

Air H w/o PPE L M-L


*For aspects not determined significant by other previous criteria

Corresponds Tool E-2: Worksheet for Exposure to Chemicals and Materials


Appendix E - 16

Example E-4: Worksheet for Impact Ranking — Non-abated VOC and HAP Emissions

Chemical and Material Risk Process

Aspect * Worker

Effects/

Exposure

Community

Exposure

Environment

Effects/Exposure

Worker

Safety

Impact

Ranking

Significant?

Y/N


Non-abated emissions of VOCs and HAPs from overspray (solvents and dry paint particles) and equipment cleaning solvents

H/H L M/M M Mi-H Yes

Contact Person: _____ Date Completed: _____ *For aspects not determined significant by other previous criteria

Ranking Notes: Chemical and Material Risk: Assign the ranks from your Effects and Exposure Worksheets. Safety might include reference to a flammable chemical, hence the rank of M. Corresponds Tool E-3: Worksheet for Impact Ranking