Cal/EPA Environmental Management System Project Report to the Legislature: Seventh Quarterly Update October through May 2001

Robust and Effective Systems for Public Health and Environmental Protection

As an industry representative on the Cal/EPA Southern California Working Group stated, all organizations with a responsibility for protecting the environment have an environmental management system, the question is how effective is that system in protecting the environment. This section describes findings related to improved environmental protection due to implementation of better systems of environmental management.

Improved environmental protection begins with organizations becoming more systematic in their approach to environmental management. A systems approach to environmental management provides information on impacts and current performance, clear policy and targets, implementation strategies and plans, measurement and review of progress, and adjustments to the system to maximize performance. The ISO 14001 EMS Standard provides a consistent and systematic framework for improved environmental performance, by providing organizations with a clear structure to follow when developing an EMS. Further, the ISO 14001 Standard provides more consistent EMS implementation and the possibility of third party certification for adherence to the Standard. Finally, the ISO 14001 Standard identifies the necessary system elements for improving environmental performance and can be used to evaluate the potential effectiveness of an EMS.

There are several key indicators of a robust system for public health and environmental protection including:

• An environmental policy describing the organization's commitments and principles in regards to environmental protection;

• Demonstrated knowledge and understanding of environmental laws, regulations, and other requirements;

• Demonstrated knowledge and understanding of the environmental impacts (regulated and non-regulated) of the organization;

• Documentation of objectives and targets for environmental performance improvements (lessening negative environmental impacts); 

• Documented implementation strategies and responsibilities designed to meet regulatory requirements and achieve objectives and targets for environmental improvement; and

• Measures and a review process to assess both the management system and environmental performance and to make adjustments in order to continually improve both.

• Ideally, broad public and stakeholder input into the EMS process and ready public access to information about both the EMS and environmental performance (not required by ISO 14000).

An EMS with these characteristics can provide for public health, and for environmental protection that goes beyond legal and regulatory requirements, in two ways. First, an EMS can address the non-regulated impacts to public health and the environment that result from issues like natural resource depletion, energy consumption, or green house gas emissions. Secondly, an EMS with the above characteristics includes mechanisms to better meet or exceed legal and regulatory requirements.

Findings

• Each pilot project based their EMS on the ISO 14001 Standard. Three organizations, IBM, Anheuser-Busch, and San Diego are certified to ISO 14001; Lockheed Martin has self-declared that it meets the ISO 14001 Standard; Pentel and CMSA intend to certify to the ISO 14001 standard later this year; Davis Bynum and Benziger Family Winery are basing their EMS on ISO 14001, and Artistic Plating is using the Merit Partnership ISO 14001 based Metal Finishing EMS Template.

• ISO 14001 based EMSs provide structure to establish policy direction, understand impacts, set improvement targets, measure progress towards objectives, review performance and continually improve the EMS.

• Pilot projects demonstrate the improved environmental protection realized through EMS implementation.

• The ability to set environmental performance improvement objectives and measure progress towards objectives may have public policy applications in driving performance of an individual company or industry sector to meet public policy goals.

Environmental Policy
A primary indicator of a robust and effective EMS is the presence and content of an environmental policy. The ISO 14001 Standard defines an environmental policy as a statement by the organization of its intentions and principles; in relation to overall environmental performance; which provides a framework for action; and for the setting of environmental objectives and targets to lessen negative environmental impacts. Environmental policies of the Pilot Projects are included in the appendices.

The environmental policy of each pilot project is signed by their senior management and is an initial demonstration of management support and environmental commitment necessary for an effective EMS. The environmental policies of the pilot projects follow the requirements of ISO 14001, including management commitments to:

• Compliance with relevant environmental laws and other requirements,

• Pollution prevention, and

• Continual Improvement.

The Benziger Family Winery's environmental policy demonstrates this commitment by stating: "Benziger Family Winery is committed to identifying and promoting the most environmentally safe and sustainable business and farming practices. We believe that sound environmental policy will lead to an increase in product quality as well as the social well being of our employees and community. We will:

• Continually monitor and improve environmental performance through an EMS.

• Comply fully with the letter and spirit of environmental laws and regulations.

• Seek to prevent pollution before it is produced and reduce the amount of waste at our facilities."

Above is only a portion of Benziger's environmental policy.  Their complete policy is included in the appendix.

Understanding Laws and Regulations
Another indicator of a robust and effective EMS, especially in maintaining environmental compliance, is the organization's knowledge and understanding of environmental laws and regulations. This can be measured through the pilot's documentation of all environmental requirements and the presence of procedures for updating and communicating requirements to employees.

EMS development helped Pentel identify previously unknown regulations. As part of their process to document all environmental requirements, Pentel invited the small business assistance representative for the South Coast Air Quality Management District. Through this visit, Pentel identified a previously unknown regulatory requirement for the elimination of the volatile organic compound (VOC) threshold exemptions for general cleaning of plastics, and subsequently set an objective to eliminate the use of alcohol for plastic cleaning.

Aspects and Impacts
The capacity of an organization to know and understand the environmental impacts of their regulated and unregulated activities is another indicator of an improved system for public health and environmental protection. In an ISO 14001-based EMS, this process begins with the organization identifying their environmental aspects. An environmental aspect is defined as any element of an organization's activities, products, or services, which can interact with the environment. Environmental aspects are then evaluated in order to determine which aspects have or can have significant impacts on the environment.

At LM Aero-Palmdale, in order to identify which of their aspects have a significant impact, aspects are evaluated in terms of environmental safety and health impacts as well as business impacts. The probability of an impact occurring and the environmental consequence of that impact are ranked low, medium, or high. Business impacts are evaluated in terms of compliance, costs and stakeholder interest/concern and are also ranked low, medium, or high. The two scores are combined on a risk/significance matrix which yields a significance level. Impacts ranked at level 1 have the highest risk/significance while level 5 have the lowest risk/significance. Through this analysis, LM Aero-Palmdale better understands the risk and significance of their environmental impacts and designs management responses accordingly.

Objectives and Targets
While understanding that the impacts of an organization are important to improve public health and environmental protection, true improvements can only be achieved when an organization has identified objectives and targets for environmental performance improvements. According to the ISO 14001 Standard, the organization shall ensure that the aspects related to significant impacts are considered in setting its environmental objectives. Objectives and targets may be performance driven, such as a reduction in waste generation, management focused, such as establishing a pollution prevention committee, or related to gathering better information on a particular aspect. The evaluation of aspects and impacts and the setting of environmental objectives and targets are a primary way that an organization with an EMS improves compliance with regulated environmental aspects and addresses environmental impacts that are not required through the regulatory system.

IBM - San Jose's EMS demonstrates the potential to drive environmental performance beyond regulatory requirements through aspect and impact identification and objective and target setting. All of IBM San Jose's objectives and targets achieve results that are not compliance-related or compliance driven. The objectives and targets may address an aspect/impact that has regulatory elements, but the actual program either exceeds compliance requirements or works with non-regulated elements of the aspect/impact. As an example, the following table presents IBM San Jose's aspects and objectives and targets.

 

Aspect/Impact	Objective and Target
Energy Use	Conserve 4% electrical usage (kWh)
Solid Waste	Recycle 73% of solid waste  Recycle 90% of industrial waste
Water Use	Track site water use and trends
Transportation (employee)	Increase Eco Pass users by 10% Commuter Check users by 25%
Products (environmental impacts)	Various objectives covered under Environmentally Conscious Product Strategy
Water Discharge	Reduce wastewater discharge year to year indexed to production
Chemical Use	Establish chemical use reduction committee and set target
Hazardous Waste Discharges	Reduce disposal amount year to year indexed to production

Environmental Management Programs and EMS Implementation
To facilitate the achievement of environmental objectives and targets, a robust and effective EMS will include an environmental management program. This is a strategic plan of action for the realization of environmental goals and describes how objectives and targets will be achieved. The environmental management program template developed for the Vineyard/Winery Pilot Project and used by Davis Bynum and Benziger Family Winery identifies resource needs, required actions, responsibilities, schedules, and performance indicators to track progress towards goals. An environmental management program like the one used in the Vineyard/Winery EMS Template, is a required feature in an ISO 14001 EMS and is the basis for the implementation phase of the EMS.

Implementing the environmental management program is only one element of EMS implementation; others include training, communication, operational control, and emergency preparedness and response. Each of these components supports the organization in meeting its environmental commitments and achieving objectives and targets and thus helps provide greater environmental protection.

Although there are many legal requirements for employee training, an EMS can improve an organization's training programs in two ways. First, an EMS can identify training needs and provide mechanisms to ensure personnel receive necessary training and are competent in the subject matter. Secondly, by training employees on the policy, objectives and programs of the EMS, employees can better understand how their jobs can impact the environment and clearly understand their responsibility toward meeting the environmental performance goals of the organization. At IBM, prior to ISO 14001 EMS implementation, the on-the-job and classroom training focused on compliance with legal, regulatory and corporate environmental requirements. Following EMS implementation, employees received additional EMS awareness training annually. The EMS awareness training tied the job responsibility training more directly to the site EMS, including the employee's contribution to meeting environmental objectives.

Internal communication can also be improved through EMS implementation resulting in greater environmental protection. At Artistic Plating, an EMS information board helps employees follow the progress towards environmental objectives. This improvement in communication, coupled with increased employee understanding of the EMS and environmental performance goals, have resulted in creative pollution prevention ideas coming from plating operators.

At CMSA, communication between staff and management has improved as a result of the EMS program. The non-management employees previously had little input into operational needs and potential improvements. Now, through EMS implementation, multiple subgroup teams address specific environmental aspects of their organization. The subgroups have created a mechanism for voicing the interests of the employee and staff level input, and have generated insightful suggestions for improving operations based on first-hand knowledge of the system. For example, performing routine maintenance on a given pump may be more complex and may increase the impact on facility operation during peak flow periods through the day. Workers have suggested that evening staff perform routine maintenance during off-peak hours to conserve resources.

Better awareness by employees of the environmental impacts of their jobs and the environmental objectives articulated in their EMS appears to have resulted in the Anheuser-Busch, Fairfield brewery being the lowest water user and wastewater discharger within Anheuser-Busch's 12 breweries. This is attributed to employee awareness of the ISO 14001 "positional impacts", as defined by employee job assignment/duties and codified within written Standard Operating Procedures. These are communicated in training and at the workstation for employee environmental awareness. The company communicates the EMS standards of excellence to their employees and the management is involved in identifying and addressing 'significant impacts' with defined plans prescribed to minimize impacts.

An important element of EMS implementation is operational controls. The purpose of operational controls in an EMS is to ensure that significant environmental aspects are managed in a way that is consistent with the environmental policy, so that the EMS objectives and targets for those aspects are met. At LM Aero-Palmdale, chemical management and disposal are significant aspects and require extensive control. The major elements of the chemical control program involve the Chemical Control Board (CCB) and the chemical control cribs. In addition to pollution prevention projects, the CCB is responsible for approving all chemical purchases at LM Aero-Palmdale. Their review includes an analysis of the ESH risk involved with the chemical, the need for the chemical, and a search for less toxic alternatives. The daily use of chemicals is tracked and managed through a system of chemical control cribs. This daily accounting allows LM Aero-Palmdale to meet the daily volatile organic compound (VOC) tracking requirements of the Antelope Valley Air Pollution Control District Rule 109, the Los Angeles County Fire Department requirement for reporting hazardous materials use, and other regulatory requirements for chemical tracking.

Internally, the package-by-package tracking of chemical use provides operational control. Combined with the approval process of the Chemical Control Board, the cribs ensure that no unauthorized chemicals are being used. The crib process also contributes to meeting pollution prevention goals. The accounting system reduces chemical usage and waste by ensuring that only necessary amounts of chemicals are provided to employees. This also has reduced the amount of chemicals that become waste due to shelf-life expiration.

Another element of EMS implementation is the preparation for and response to emergencies. Although emergency response capabilities are required by regulation, an EMS can improve an emergency response program through better communication, training, annual drills and system audits. San Diego Metropolitan Wastewater Department, Operation and Maintenance Division reported several improvements to the emergency response program as a result of their EMS. They have expanded the employee, visitor, and contractor participation and awareness as a result of meeting the ISO 14001 requirement for periodic testing of emergency response procedures. They have developed new procedures to ensure that current hazardous material inventory and response documentation are available. A third party audit of their EMS identified other areas for improvement including employee awareness, spill response equipment documentation and monitoring, and alarm and announcement system upgrades.

Pentel of America is in the process of developing their EMS and has already seen improvements in how they prepare for and respond to emergencies. As a result of their EMS, an entirely new analysis was performed in each department to identify any potential for emergency events to occur that would have an adverse impact on the environment. In response to that analysis, emergency/accident prevention and mitigation plans and procedures are being developed for all emergency scenarios that were identified.

Implementing pollution prevention programs is another way pilot organizations have improved environmental protection beyond legal requirements. While most of the pilot projects reported some pollution prevention activities prior to implementing their EMS, each stated that EMS implementation has aided their pollution prevention programs. EMS implementation has also increased some pilots' understanding of what constitutes pollution prevention. For example, at Anheuser-Busch, prior to EMS implementation, pollution prevention techniques were thought to be end-of-pipe technology and recycling. After EMS implementation, Anheuser-Busch has adjusted its understanding of pollution prevention to be proactive rather than reactive. Pollution prevention is now centered on reduction and reuse, and has been expanded to include air emission reductions resulting from energy conservation.

Other pilot projects reported that the EMS created a greater emphasis and understanding of pollution prevention throughout the organization. Pentel of America reported that their EMS increased emphasis, visibility, and organization of pollution prevention efforts. At IBM their EMS, "Simply provided additional structure and increased awareness of existing, ongoing pollution prevention opportunities." Similarly, the EMS at Artistic Plating is "continuing to make the company more conscious of pollution prevention opportunities." At LM Aero-Palmdale, the EMS has allowed the full integration of pollution prevention into all business functions in order to reduce environmental impacts.

Environmental Performance Review and Continual Improvement
The ability of an organization to review environmental performance and make system adjustments in order to improve public health and environmental protection on a continual basis is the final indicator of an effective EMS. In an ISO 14001-based EMS, information on environmental performance is collected two ways. One source is through internal or third party EMS audits. The other involves the direct measurement of environmental performance indicators, which are most often related to objectives and targets of the EMS. Management then reviews this information and determines the appropriate response actions to ensure continual improvement in public health and environmental protection.

An EMS audit is a systematic and documented verification process to determine whether an organization's EMS is effective in carrying out the environmental policy, environmental management programs, and progress towards objectives and targets. Under the Anheuser-Busch, Fairfield audit program, teams of corporate environmental staff, on-site environmental staff, and external consultants conduct audits at each facility. The frequency of audits conducted at individual facilities is based on risk. The greater the risk, the more often audits are conducted. Previous audit results, the number of fines and amount of penalties incurred, and the any sensitive issues are all factors influencing the audit schedule.

A performance review is another way to assess an EMS's effectiveness and plan for system improvements. To assess the overall effectiveness of IBM's EMS and to identify opportunities for continual improvement, IBM monitors and measures key characteristics of the site's activities and operations that can have a significant impact on the environment. "Key Characteristics" are defined at IBM to include operation conditions or parameters in the following categories:

• Parameters directly associated with a regulatory permit conditions or discharge limit;

• Parameters associated with the measurement of critical elements of the established objectives and targets, and or

• Critical parameters associated with site significant environmental aspects.

Information on these key characteristics is considered in the annual review and update of aspects, objectives and targets. Programs, procedures and documentation are also reviewed annually and revised, if necessary, based on "lessons learned" and/or other measures of effectiveness.

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