Environmental Management Systems - Ensuring current and future environmental performance

Environmental Management Systems -Ensuring current and future environmental performance

Business leaders have come to understand that strong management systems are essential in achieving top business performance. Successful projects need management support and personnel commitment, formal goals, a method of reaching the goals, periodic review, and accountability. Having achieved business success, environmental leaders have developed environmental management systems (EMSs) designed to achieve top environmental performance. Today, environmental performance means more than compliance, it also assures that compliance and, in many cases, beyond compliance, will continuously improve.

The Environmental Protection Agency has identified EMSs as an essential component of a full scale Environmental Leadership Program (ELP). Through the EMS component, environmental management is incorporated into a facility's daily business operations. Effective EMSs include, in part, components for compliance management that assure the facility meets legal environmental requirements on a continuous basis, and demonstrates commitment to pollution prevention, community outreach, and environmental protection and enhancements. Major components of an EMS include:

•A formal commitment to improving environmental performance, supported by policies and procedures that uphold the commitment

•Compliance assurance through self-policing by conducting audits, regulatory tracking, and environmental impact planning

•Implementation through a formal structure, internal and external communications, training, and education

•Measurement and evaluation of the entire EMS.

•Review and improvement by addressing root causes of deficiencies.

ELP participants that have demonstrated EMSs include Ciba-Geigy’s St. Gabriel plant in Louisiana; Motorola's Oak Hill facility in Austin, Texas; Ocean State Power in Rhode Island; Arizona Public Service Company's Deer Valley Facility; and WMX Technologies’ Columbia Ridge Landfill and Recycling Center and Chemical Waste Management of the Northwest facility, both in Oregon. Other ELP participants in the process of finalizing elements of their EMSs include the Gillette Company (South Boston Manufacturing Center) and the Duke Power Company's Riverbend Station in North Carolina.

Recognized as a leader in continuous improvement of business processes, Motorola has seen tangible benefits from fully integrating EMSs into business processes. Motorola demonstrates corporate and facility level commitment by rewarding managers and line workers for finding new ways to improve environmental performance. The results have been not only an outstanding compliance record, but also improved manufacturing efficiency and reduced waste generation. Specific savings have included:

•Working with chemical suppliers to reduce hazardous waste generated, finding less toxic alternative chemicals, and improving efficiency

•Reusing packaging material

• Reviewing production processes to reduce or eliminate unnecessary chemical use

•Turning waste into product, both internally and externally.

Measuring Compliance

Ciba-Geigy has a mature EMS. The company prides itself on thorough plant self-assessments through a tiered approach of facility and corporate audits. Areas of noncompliance with corporate policy and legal requirements are corrected in a timely fashion. On a recent audit, the facility uncovered several opportunities for improving its EMS and compliance assurance program. By maintaining a strong EMS, Ciba-Geigy is able to identify and correct issues that otherwise may be overlooked. This approach requires an uncommon amount of employee involvement at all levels.

Assuring Compliance and Preventing Non-compliance

Ocean State Power (OSP), operational since 1990, had a strong environmental ethic that translated easily into the development of an EMS. By establishing an EMS, OSP was able to assure its stakeholders that it was responding to society’s demand for a clean environment. OSP’s EMS also helps ensure continued compliance, assuring its owners and customers that its business will not be impacted negatively by compliance issues.

OSP also found that by participating in the ELP, it could assess its own EMS relative to other ELP participants. In working with other environmental leaders, it was able to reinforce areas of success while being exposed to alternative approaches for improvement.

The compliance component of WMX’s EMS is referred to as "PACT." This acronym represents four major concepts: Preventing compliance issues from arising; Assessing environmental compliance systems and performance; Correcting any identified non-compliance issues and preventing their recurrence; and Training facility employees on environmental requirements and management systems. WMX has found that consistently upholding and applying all the components of this system helps prevent non-compliance and thus reduces environmental compliance concerns.

Environmental Enhancement Activities

WMX’s Environmental Policy and Principles provides a framework for environmental protection and enhancement at the facility level. One activity at WMX’s Oregon facilities, as part of their environmental impact assessment and planning, is to catalog all the flora and fauna on their property and reintroduce native plant species as ground cover when sections of the landfill are closed. This project works toward the goals of restoring biodiversity and developing a plan for protecting any endangered or threatened species. It is one of several initiatives meeting WMX’s principles of biodiversity, energy conservation, and recycling.

WMX as well as other pilot project facilities have included energy conservation activities as environmental enhancements. These energy conservation benefits are frequently the results of implementing pollution prevention techniques. Ocean State Power has made significant progress in eliminating oil waste created from test firing by recycling oil back into the system. They have also developed methods to eliminate ammonia wastes released by truck hoses during deliveries by recycling it back to the on-site ammonia tank. These pollution prevention techniques help the facility to reduce releases of unnecessary environmental pollutants while providing enhancements to the surrounding environment.

Lessons Learned

During the course of the pilot project, the facilities involved with demonstrating their interest and strength in the EMS component of the ELP have learned many valuable lessons about the implementation of an EMS. The following are some of these lessons from the facilities:

•To ensure compliance, corrective action schedules from findings either through an audit or daily observation should be set at limits tighter than regulatory requirements. In this way, facilities can be sure that regulatory timetables will be met regardless of business changes.

•Smaller facilities may initially have difficulty implementing a full scale EMS. Efforts are ongoing to appropriately "size" EMS requirements for small facilities.

•Facilities should use care when establishing compliance performance measures. WMX Technologies found that using solely the number of compliance issues as a performance measure is a disincentive for reporting them. Alternatives are basing performance on the number of issues resolved on time, or the percent of issues identified at the facility verses at the corporate level.

•Facilities may find initial hesitation when soliciting input for participation in environmental programs. OSP overcame initial difficulty in recruiting volunteers for the programs in its EMS by requiring the entire plant to participate.

•Ciba-Geigy determined that the real strength of the St. Gabriel facility EMS was how the EMS as a whole contributed to the facility’s leadership status. Each component of the EMS was individually valuable, but, a fully developed EMS is itself the major tool in an effective environmental leadership program.