Cal/EPA Environmental Management System Project
Report to the Legislature: Third Quarterly Update
April through June, 2000
Table of Contents
- Executive Summary
- Introduction
- Public Comment and Hearings
- Selection of Pilot Projects
- Model Pilot Project Work Plan
- Data Collection and Reporting Timeline
- Initial Observations
- National Workshop--Learning together: Environmental Management Systems, Regulatory Innovation, and Sustainability
- Upcoming Activities
- Appendix
Executive Summary
The purpose of this report is to update members of the Legislature on the Cal/EPA Environmental Management System (EMS) Project authorized by passage of Assembly Bill 1102 in July of 1999. This third quarterly report includes descriptions of major accomplishments, including initial observations of results from implementing environmental management systems, and upcoming activities.
An introduction to the EMS project is included in the appendix to this report and in the prior two updates provided to the Legislature, dated December 31, 1999 and March 30, 2000. The appendix includes the purpose of the project, approach, legislative authority, information on the Cal/EPA team, a brief background discussion, the definition of an environmental management system, and description of the working groups.
Major accomplishments this quarter are listed below.
- Cal/EPA requested public comment during May 1 through June 1, 2000.
- Public hearings were held in Northern and Southern California in fulfillment of the legislative requirement for a public hearing.
- Receiving one procedural comment, Cal/EPA announced selection of the pilot projects as proposed and adopted the pilot selection criteria, model pilot project work plan, and monitoring and evaluation parameters.
- The Cal/EPA EMS Project team has made initial observations of results from implementing EMSs, based on preliminary data shared by several of the Cal/EPA pilot projects.
- Cal/EPA planned and hosted the very successful national EMS workshop in San Diego in June, which was co-sponsored by U.S. EPA and the Multi-State Working Group.
The following seven pilot projects were selected by Cal/EPA:
- Anheuser-Busch in Fairfield,
- Wastewater treatment facilities (Central Marin Sanitation Agency in San Rafael and San Diego Metropolitan Wastewater Department, Operation and Maintenance Division),
- IBM Corporation in San Jose,
- Lockheed Martin Aeronautics Company (formerly the Skunk Works) in Palmdale,
- Metal finishing companies (Artistic Plating in Anaheim and Gene’s Plating in Los Angeles),
- Pentel of America, Ltd. in Torrance, and
- Vineyards and wineries (Davis Bynum Winery and Benziger Family Winery in Sonoma County).
Initial observations of results from implementing EMSs, based on preliminary data shared by several of the Cal/EPA pilot projects, are described in this report. Preliminary results include notably positive experiences in the areas of
- compliance,
- compliance and EMS design,
- employee involvement,
- interested party involvement,
- environmental performance and cost reduction,
- pollution prevention,
- public information, and
- supply chain relationships.
Compliance
As a result of its EMS, Anheuser-Busch Incorporated (A-BI) has developed a report that is
used to track timely correction of any deficiencies with regulatory or internal
requirements. Further, root cause analysis conducted by a cross-functional team is used to
mitigate recurring deficiencies. This information is communicated to all affected
facilities through the company’s intranet site. The team has had a significant impact
on A-BI’s ability to make meaningful process changes that reduce the recurrence of
deficiencies.
Compliance and EMS Design
When Central Marin Sanitation Agency (CMSA) began designing its EMS, the first step was to
identify all of the regulations and contracts that govern their wastewater treatment
activities. When the initial list was circulated to the entire working group, it became
evident that only half of the requirements were known. We believe this situation is not
unusual for regulated entities and can result in significant environmental improvements.
Employee Involvement
Prior to the implementation of its ISO 14001 EMS, individual employees at IBM were made
aware of their potential contributions to and impact on the environment through training
associated with their respective job responsibilities. Following implementation of the ISO
14001 EMS, employees additionally are required to complete annual ISO 14001 awareness
training such that the interaction of their activities are more closely tied to the site
EMS and overall environmental performance. This supplemental training has resulted in
employees viewing their potential environmental impacts from a much broader perspective
– one that includes their activities both on and off company property.
Interested Party Involvement
Interested party involvement in the Environmental Management Systems of Cal/EPA’s
pilots has been greatly increased through our sponsorship of two working groups operating
in Southern and Northern California. Over 50 individuals representing environmental public
interest groups, government, the regulated community, environmental consulting, and
academia participate on the working groups. The purpose of the working groups is to act as
a forum for the evaluation, analysis, and discussion of EMSs, in general, as well as
Cal/EPA’s Pilot Project EMSs, individually. In order to establish common
understanding and knowledge of EMSs, Cal/EPA has sponsored three training sessions for
regional working group members. These training sessions have helped pilots and other
members of the working groups develop or refine their EMSs.
Environmental Performance and Cost Reduction
Prior to establishing their EMS in 1991, Lockheed Martin Aeronautics Company–
Palmdale generated 3,692 tons of hazardous waste compared to 448 tons in 1998. Hazardous
waste disposal in 1991 cost the company $1,421,000 compared to $375,000 in 1998. Emissions
of ozone depleting chemicals have been reduced to zero from 403,000 lbs. in 1988. SARA
Toxic Release Inventory chemicals were reduced from 1,430,000 lbs. in 1987 to a level
below reporting requirements by 1998. Volatile organic compounds were reduced from 256,000
lbs. in 1990 to 41,000 lbs. in 1998.
Pollution Prevention
As part of an EMS review of metal finishing processes in their company, Artistic Plating
phased out the use of perchloroethylene in favor of ultrasonic and aqueous cleaners.
Public Information
The City of San Diego Metropolitan Wastewater Department, Operation and Maintenance
Division has achieved the distinction of becoming the first publicly owned treatment works
in the U.S. to certify to the ISO 14001 EMS standard. San Diego is interested in better
communicating the results of their EMS to the public and gaining greater public
involvement and understanding of their EMS. To support this goal, San Diego is exploring
making their EMS information available to the public on their web site, in a format that
the public can easily use.
Supply Chain Relationships
IBM was so persuaded by the environmental benefits of its EMS that it took the leadership
position of encouraging its suppliers to align their EMS with the requirements of ISO
14001 and to pursue registration. In a letter to suppliers, IBM underscored its interest
in doing business with environmentally responsible suppliers.
Planned activities for the next quarter include
- providing training for the working groups on the practical development of EMSs with sustainability components,
- facilitating regional EMS working group meetings to learn about and comment on individual pilot project EMS development and implementation,
- drafting individual pilot project work plans, and
- collecting semiannual update data.
Introduction
The purpose of this report is to update members of the Legislature on the Cal/EPA Environmental Management System (EMS) Project authorized by passage of Assembly Bill 1102 in July of 1999. This third quarterly report includes descriptions of major accomplishments, including initial observations of results from implementing environmental management systems, and upcoming activities.
An introduction to the EMS project is included in the appendix to this report and in the prior two updates provided to the Legislature, dated December 31, 1999 and March 30, 2000. The appendix includes the purpose of the project, approach, legislative authority, information on the Cal/EPA team, a brief background discussion, the definition of an environmental management system, and explanation of the working groups.
Major accomplishments this quarter are listed below.
- Cal/EPA requested public comment during May 1 through June 1, 2000.
- Public hearings were held in Northern and Southern California in fulfillment of the legislative requirement for a public hearing.
- Receiving one procedural comment, Cal/EPA announced selection of the pilot projects as proposed and adopted the pilot selection criteria, model pilot project work plan, and monitoring and evaluation parameters.
- The Cal/EPA EMS Project team has made initial observations of results from implementing EMSs, based on preliminary data shared by several of the Cal/EPA pilot projects.
- Cal/EPA planned and hosted the very successful national EMS workshop in San Diego in June, which was co-sponsored by U.S. EPA and the Multi-State Working Group.
Public Comment and Hearings
Cal/EPA announced a 30-day public comment period and held two public hearings on the EMS Project. Announcements and fact sheets were distributed to a mailing list of approximately 700 interested individuals. Cal/EPA requested comments on the Draft Selection Criteria, Proposed Pilot Projects, Draft Model Pilot Project Work Plan, and the Draft Evaluation and Monitoring Parameters which were made available on-line, at selected repository sites, and by request. The public comment period ran from May 1 through June 1, 2000. Hearings were held on May 22nd at 9:30 a.m. at the Orange County Sanitation District in Fountain Valley and May 24th at 1:30 p.m. at the Public Utilities Commission in San Francisco.
Since only one comment was received, a response to which has been provided, Cal/EPA has formally selected the proposed seven pilot projects and finalized the documents listed above. Success of the Cal/EPA stakeholder involvement process and thorough review by the Northern and Southern California EMS Working Group participants are responsible for the broad acceptance and support of the EMS Project. Final documents are available online at http://www.calepa.ca.gov/EMS/ and are briefly described in the following sections.
A description of the scope and implementation of the EMS Project follows. It includes the pilot project selection, model pilot project work plan elements, and data collection (evaluation and monitoring parameters) and reporting requirements.Selection of Pilot Projects
To create a consistent and transparent selection process, Cal/EPA developed pilot project selection criteria with input from the Northern and Southern California EMS Working Groups. Pilot projects were proposed and selected based on meeting the criteria listed below.
- Pilot projects will have an ongoing or planned EMS that can reasonably be expected to produce greater environmental protection than would otherwise be achieved by the existing regulatory process.
- Pilot projects will engage in a multi-media environmental approach (e.g., air, water, solid and hazardous waste).
- Pilot projects will pursue appropriate pollution and waste prevention opportunities.
- Pilot projects will share information learned from EMS implementation with Cal/EPA, regional and/or local working groups, and the public. Pilot projects agree to provide specific data on the goals, implementation, and performance of their EMS as reported in the national and California supplemental data protocols.
- Pilot projects will participate on the Northern or Southern California EMS Working Group.
- Pilot projects will declare to Cal/EPA any current and past (three years) violations cited by environmental regulatory agencies.
- Pilot projects will address known regulatory deficiencies, as required by the appropriate regulatory agency, through their EMS.
- Pilot projects' top management will make a full commitment to participate in the project through a letter of intent.
- Pilot projects will represent diversity in terms of location/geography, size, industry type or sector, environmental impacts, and in the range of EMS maturity.
The following seven pilot projects were selected by Cal/EPA:
- Anheuser-Busch in Fairfield,
- Wastewater treatment facilities (Central Marin Sanitation Agency in San Rafael and San Diego Metropolitan Wastewater Department, Operation and Maintenance Division),
- Lockheed Martin Aeronautics Company (formerly the Skunk Works) in Palmdale,
- Metal finishing companies (Artistic Plating in Anaheim and Gene’s Plating in Los Angeles),
- Pentel of America, Ltd. in Torrance, and
- Vineyards and wineries (Davis Bynum Winery and Benziger Family Winery in Sonoma County).
IBM Corporation in San Jose,
Model Pilot Project Work Plan
A Model Pilot Project Work Plan has been created to serve as a template for Work Plans that will be written for each individual Pilot Project. The Work Plans will include descriptions of roles and responsibilities, schedules, research objectives, stakeholder involvement, data management procedures, and data assessment and analysis techniques.
A Cal/EPA manager has been appointed to coordinate each pilot project. With the assistance of the Cal/EPA pilot project managers, each facility will prepare a project plan that includes the following elements:
- title and approval sheet,
- distribution list;
- project description;
- goals and objectives;
- roles and responsibilities;
- project schedule;
- stakeholder involvement;
- quality objectives and criteria for measurement of data;
- data collection, management, and quality assessment.
Data Collection and Reporting Timeline
Evaluation and Monitoring Parameters have been adopted by Cal/EPA and are comprised of the national EMS data protocols and a California supplement.
In coordination with other states, detailed data protocols have been developed to collect standardized information on EMS design and performance. The national data protocols are available for review through a web site link at http://www.mswg.org. In order to answer the questions provided in AB 1102, Cal/EPA is supplementing the national data protocols with a few additional questions. Using these combined protocols, also referred to as the Evaluation and Monitoring Parameters, pilot projects are submitting information in the following categories:
- environmental performance,
- regulatory compliance,
- use of pollution prevention techniques,
- continual improvement,
- employee involvement,
- involvement of interested parties,
- quality and quantity of information to the public,
- EMS design, and
- EMS costs and benefits.
California is currently collecting performance baseline and EMS design data for the pilot projects. To determine baseline conditions, pilots are contributing data prior to implementing their EMSs. Descriptive information about EMS design is being submitted to evaluate distinguishing EMS features and superior practices. To assess the short-term results subsequent to implementing an EMS, pilots will provide four semiannual updates.
Cal/EPA reports quarterly on progress to the Legislature and will provide a final analysis of results by January 1, 2002. Initial observations are summarized in the following section.
Initial Observations
This section of the report consists of initial observations of results from implementing EMSs, based on preliminary data shared by several of the Cal/EPA pilot projects. Preliminary results include experiences with
- compliance,
- compliance and EMS design,
- employee involvement,
- interested party involvement,
- environmental performance and cost reduction,
- pollution prevention,
- public information, and
- supply chain relationships.
Compliance
As a result of its EMS, Anheuser-Busch Incorporated (A-BI) has a procedure in place that
addresses violations as well as potential violations regardless of how they are discovered
(e.g., agency inspection, audit, and self-inspection). The procedure includes a process
for actively identifying potential violations, determining the causes of any violations,
as well as preventing recurrences. The first of two key elements is an immediate
correction of any deficiency that is identified. The second element is a deeper analysis
to get at the cause of the problem and to make longer-term adjustments to prevent it from
recurring.
Specifically, A-BI has developed a report that is used to track timely correction of any deficiencies with regulatory or internal requirements. Further, root cause analysis, conducted by a cross-functional team, is used to mitigate recurring deficiencies. Thus, a far deeper analysis of the process-related reasons for deficiencies is performed. This information is communicated to all affected facilities through the company’s intranet site. The team has had a significant impact on A-BI’s ability to make meaningful process changes that reduce the recurrence of deficiencies. This team-based approach to identifying the root cause of a problem could be employed by both private and public organizations.
Compliance and EMS Design
When Central Marin Sanitation Agency (CMSA) began designing its EMS, the first step was to
identify all of the regulations and contracts that govern their wastewater treatment
activities. Initially, two individuals normally tasked with most of the regulatory
compliance reports collaborated on this regulation list. When the list was circulated to
the entire working group, it was evident that the list was incomplete and only about half
of the governing documents were listed and thus only half of the requirements were known.
We believe this situation is not unusual for regulated entities.
The EMS process draws upon many individuals’ expertise and institutionalizes the information in a single document that is implemented throughout the organization. No longer is the approach to operation piece-mealed; rather, a proactive and uniform approach can be utilized. This is especially important with regulatory compliance issues and could quite possibly streamline the process by virtue of identifying and understanding similar regulatory requirements.
Employee Involvement
Prior to the implementation of its ISO 14001 EMS, individual employees at IBM were made
aware of their potential contributions to and impact on the environment through training
associated with their respective job responsibilities. The training provided to employees
consisted of on-the-job and classroom training. For example, personnel were instructed how
to properly store and handle chemicals, how to properly label and manage hazardous waste
containers, how to monitor chemical use in manufacturing tooling to meet air emission
permit requirements, and how to operate the wastewater treatment facility such that
discharges meet permit requirements.
Following implementation of the ISO 14001 EMS, employees continue to receive the training identified above and are required to complete annual ISO 14001 awareness training such that the interaction of their activities are more closely tied to the site EMS and overall environmental performance. This supplemental training has resulted in employees viewing their potential environmental impacts from a much broader perspective – one that includes their activities both on and off company property. Learning more about efforts to educate all stakeholders about their role in implementing and improving an EMS has broad applicability.
Interested Party Involvement
Interested party involvement in the Environmental Management Systems of Cal/EPA’s
pilots has been greatly increased through our sponsorship of two working groups operating
in Southern and Northern California. Over 50 individuals representing environmental public
interest groups, government, the regulated community, environmental consulting, and
academia participate on the working groups. The purpose of the working groups is to act as
a forum for the evaluation, analysis, and discussion of EMSs, in general, as well as
Cal/EPA’s Pilot Project EMSs, individually. In order to establish common
understanding and knowledge of EMSs, Cal/EPA has sponsored three training sessions for
regional working group members. These training sessions have helped pilots and other
members of the working groups develop or refine their EMSs.
The working groups have contributed to the development of the Cal/EPA EMS Pilot Project by reviewing proposed pilot projects, selection criteria, evaluation and monitoring parameters, and the model pilot project work plan. The working group members have already begun learning about and contributing to the EMSs of pilots through facility tours and presentations. The working groups will continue to evaluate our pilots’ EMSs and help us determine if and how an EMS provides greater environmental protection and better environmental information than what is already required by law.
Environmental Performance and Cost Reduction
In the area of hazardous waste reduction and environmental cost reduction, Lockheed Martin
Aeronautics Company (LMAC) – Palmdale has had great success. In 1991, prior to
establishing their EMS, they generated 3,692 tons of hazardous waste compared to 448 tons
in 1998. Normalized for total sales, LMAC – Palmdale generated 4,455 lbs. per one
million dollars in 1992. This was reduced to 634 lbs. per one million dollars by 1998.
Hazardous waste disposal in 1991 cost the company $1,421,000 compared to $375,000 in 1998.
Environmental cost (outside services fees and taxes) was reduced during this period from
$3,340 per million dollars in sales to $966 per million dollars in sales in 1998.
Emissions of ozone depleting chemicals (ODC) have been reduced to zero from 403,000 lbs. in 1988. SARA Toxic Release Inventory (TRI) chemicals were reduced from 1,430,000 lbs. in 1987 to a level below reporting requirements by 1998. Volatile organic compounds (VOCs) were reduced from 256,000 lbs. in 1990 to 41,000 lbs. in 1998.
The reduction of hazardous waste not only reduces risks to the environment and reduces costs, it also improves worker safety. At LMAC – Palmdale, health and safety issues have been integrated into their EMS. For example, implementing the use of pre-saturated wiping cloths in lieu of rag and solvent bottles reduced VOC emissions associated with wipe cleaning operations by 60%. This results in a large reduction in worker exposure. This pollution prevention and worker safety innovation came from shop floor workers involved in the LMAC EMS.
Pollution Prevention
Artistic Plating in Anaheim is in the process of implementing an EMS, using an EMS
template developed by U.S. EPA. Artistic Plating is a medium-sized, 100 employee, metal
finishing facility that performs copper, nickel, brass and chrome electroplating. As part
of an EMS review of their metal finishing processes in their company, Artistic Plating
realized the impact that perchloroethylene was having on the environment and liability and
worker safety risks related to its continued use. Recently, Artistic Plating phased out
the use of perchloroethylene in favor of ultrasonic and aqueous cleaners. Artistic Plating
installed an ultrasonic cleaning tank and a spray washer to use in cleaning parts on the
plating line. Both the tank and the washer utilize aqueous cleaners.
Installation of this pollution prevention equipment will reduce Artistic's air emissions and minimize other environmental exposure risks. Cost of implementation was $130,000.
Public Information
The City of San Diego Metropolitan Wastewater Department, Operation and Maintenance
Division has implemented an ISO 14001 EMS, certified in May 1999, to improve the
management of its environmental aspects and the management of its regulatory requirements.
San Diego has achieved the distinction of becoming the first publicly owned treatment
works to certify to the ISO 14001 EMS standard in the U.S.
San Diego is interested in better communicating the results of their EMS to the public and gaining greater public involvement and understanding of their EMS. To support this goal, San Diego is exploring making their EMS information available to the public on their web site, in a format that the public can easily use. Currently, San Diego is applying for a grant from U.S. EPA to create an external stakeholder web-based browser to access key information from their internal organization’s database. San Diego would like to work with external stakeholders to create a web site that is most useful to stakeholders. The grant specifies that development of greater public information tools be done in partnership with government and non-governmental organizations. San Diego is applying for the grant as an extension of its partnership with Cal/EPA through the Cal/EPA EMS Project.
Supply Chain Relationships
Prior to its pursuit of an ISO 14001 EMS, IBM had integrated many EMS elements into its
day-to-day business activities. However, implementation of its ISO 14001 EMS further
persuaded IBM that such a tool made good sense for the environment and the business. Now
environmental considerations are factored into business decisions at the front-end of the
decision-making.
Though difficult to quantify, this shift has saved IBM both time and money by improving the quality of its business decisions. IBM was so persuaded by the environmental benefits of its EMS that it took the leadership position of encouraging its suppliers to align their EMS with the requirements of ISO 14001 and to pursue registration. In a letter to suppliers, IBM underscored its interest in doing business with environmentally responsible suppliers. IBM’s leadership in promoting the use of EMS by its suppliers may be applicable to organizations with supplier relationships.
The following section briefly describes the recent national EMS workshop, which Cal/EPA planned and sponsored.
National Workshop--Learning Together 2000: Environmental Management Systems, Regulatory Innovation, and Sustainability
California planned and hosted the MSWG national workshop in San Diego, June 5-6, 2000. The workshop was co-sponsored by U.S. EPA and the MSWG. Over two hundred and fifty participants from the U.S and eight other countries attended. Topics included the latest EMS, sustainable development, and innovation projects in the U.S. and internationally. U.S. EPA provided a grant for non-profit public interest groups to attend the national workshop. Electronic proceedings are available at the following web site: http://www.mswg.org.
Upcoming Activities
Planned activities for the next quarter include
- providing training for the working groups on the practical development of EMSs with sustainability components,
- facilitating regional EMS working group meetings to learn about and comment on individual pilot project EMS development and implementation,
- drafting individual pilot project work plans, and
- collecting semiannual update data.
Appendix
The mission of the California Environmental Protection Agency (Cal/EPA) is to improve environmental quality in order to protect public health, the welfare of our citizens, and California’s natural resources. Cal/EPA will achieve its mission in an equitable, efficient, and cost-effective manner. In order to find more effective and innovative ways to achieve superior environmental protection, Cal/EPA established the Environmental Management System Project. Through the evaluation of environmental management systems in pilot projects, community dialogue, and research into other States’ initiatives, Cal/EPA hopes to uncover and highlight systems and practices that will provide better environmental performance and lead us toward a more sustainable California.Purpose of the Environmental Management System Project
The primary goal of the Cal/EPA Environmental Management System Project is to find
effective and innovative ways to achieve superior environmental protection. Increasing use
of Environmental Management Systems (EMSs) by industry and their use as a part of the
regulatory structure by some state governments provides an opportunity to examine the
benefits EMSs may bring in protecting and enhancing California’s environment.
The EMS Project is designed to inform public policy makers and engage stakeholders in determining whether and how the use of an EMS:
- increases public health and environmental protection and
- provides better public information than existing regulatory requirements.
Approach
In order to determine if an EMS provides these benefits, Cal/EPA was given Legislative
authority to conduct up to eight pilot projects. Data on changes in environmental
performance and regulatory compliance, pollution prevention, and stakeholder involvement
will be collected and evaluated, as well as information on the types and quality of
information available to stakeholders. Quarterly progress reports are submitted to the
Legislature, with the final analysis due January 1, 2002.
Success of the Cal/EPA EMS Project is dependent on the participation and contributions of all stakeholders. Facilitating the establishment of partnerships between communities, public interest organizations, industry, government, and academia is a major element of the EMS Project. For this purpose, Northern and Southern California working groups, with representation from these interests, have been established by Cal/EPA to give guidance on the Project, as well as to give suggestions to the pilot projects in EMS design and implementation. A formal hearing was required by the Legislature, and two were held in May, to provide further opportunity for public input to the project.
Legislative Authority
Governor Gray Davis formally established the Cal/EPA EMS Project in 1999, by signing
Assembly Bill 1102. Assembly Bill 1102 was cosponsored by Assembly Members Jackson,
Nakano, Correa, Reyes and Senator Sher. The statute codifies and clarifies existing
practices in Public Resources Code, Section 71045 et. seq. January 1, 2000 is set forth as
the Project's establishment date, and it is due to sunset on January 1, 2002.
Appropriation from the State’s General Fund provides the revenue to support this
work.
Cal/EPA Team
A multi-disciplinary Cal/EPA team administered through the Office of the Secretary manages
the EMS Project. Team members from the Air Resources Board, Department of Toxic Substances
Control, Integrated Waste Management Board, and State Water Resources Control Board serve
as project managers for the pilots.
Background
Over the past 30 years, the first generation of environmental protection laws and
regulations has led to dramatic improvements in air and water quality and in waste
disposal practices. Most laws, regulations, and environmental agencies have been organized
around media (air, water and land) or material type (pesticides, toxic substances and
municipal solid waste). Laws and regulations establishing standards for the responsible
use, control and discharge/disposal of the various pesticides, hazardous materials and
solid wastes have grown in both number and complexity. The logistical, technical, and
legal difficulties in monitoring and enforcing these rules have also increased apace. The
costs to both "control" pollution and to repair the damage caused by prior
practices have increased for both business and government. The result has been much
progress, but also a growing volume of prescriptive regulations that are, at times,
conflicting or duplicative, and that have, by necessity, focused both regulated
organizations and regulatory agencies almost exclusively on keeping pace with updated
regulations and on achieving compliance.
| Current Environmental
Protection Management Technologies and Strategies |
|---|
| Focus on protection of human health Invest
in "end-of-pipe" clean up
Respond to "command and control" regulation
Prepare environmental impact statements |
Over these 30 years, however, much has changed. California’s population, the number of regulated organizations and the production of goods and services have all increased significantly. This has created more sources and greater amounts of both regulated and unregulated materials with potential for environmental impact. For many industries, development time from product concept to market has dropped from years to months or even weeks, each product possibly introducing new hazardous materials and waste streams that regulators must incorporate into the regulatory structure. Environmental aspects and impacts (e.g., global warming, ozone depletion, endocrine disrupters), unrecognized even ten years ago, are creating demands for wide ranging regulation by government and control by industry. There is a growing realization that environmental impacts are not easily contained to a single medium, and that improvement action taken in one medium can cause significant and unintended problems in another. Over this same time period, government’s investment in the people, technologies, and process improvements needed to respond to these changes has not kept pace.
Business organizations have also changed, from almost uniform unawareness of, or disregard for, the environmental carrying capacity of land, air, and water and of the impact they create, to a much wider range of demonstrated environmental responsibility. At one extreme are those companies that continue to violate environmental regulations, for which strong and certain enforcement appears to be the main factor influencing environmental behavior. At the other end of the spectrum, leading edge companies have moved beyond compliance to embrace the concepts of sustainability and environmental stewardship. They have redesigned products and production processes to take their environmental performance far beyond regulatory compliance and have also made dramatic improvements in non-regulated environmental aspects. Most have environmental management systems incorporated into all facets of the company operations. They have made public their environmental performance in annual reports and have opened their environmental management processes to public input. There is increasing evidence not only that many environmental improvements save money over the long term, but that environmentally sophisticated companies consistently outperform their competitors in financial markets.
There is a common set of practices that many of these companies have adopted that fall under the heading of "eco-efficiency."
| Eco-efficiency Management Technologies and Strategies |
|---|
| Integrate environmental management into
the business management system
Target significant environmental improvement
Publicly report on the results |
The broad policy question, which this study seeks to address in part, is how can regulatory agencies best use their resources to significantly strengthen environmental protection while at the same time partner with businesses and non-government organizations to encourage and recognize "beyond compliance" environmental actions? The California EMS Project is a carefully designed study to answer one part of that question.
Environmental Management System Definition
An environmental management system (EMS) is a process by which an organization’s
management identifies regulated and unregulated environmental aspects and impacts of its
operations, assesses current performance, and develops targets and plans to achieve
significant environmental improvements. The EMS may also be expanded to consider both the
environmental impacts produced by suppliers of raw materials and parts, as well as the
impact of the use of the product or service by the customer. A well designed and
implemented EMS results in the integration of environmental management into the
organization’s overall management system by identifying the policies, environmental
targets, measurements, authority structures and resources necessary to produce both
compliance with regulations as well as beyond compliance environmental performance.
EMS Continual Improvement Cycle
EMSs embody the "Plan-Do-Check-Adjust" improvement cycle and typically involve:
- developing an environmental policy,
- developing a stakeholder involvement / communication strategy,
- identifying both the regulated and unregulated environmental aspects and impacts of the organization’s operations,
- determining supply chain relationships and their environmental aspects and impacts,
- identifying legal, regulatory and contractual environmental requirements as well as environmental issues of concern to the local community,
- identifying current performance and establishing objectives and targets for environmental improvement,
- developing the management structure and identifying the necessary resources and responsibilities to meet the targets,
- initiating training and employee awareness activities,
- creating measures to monitor progress in
- targeted environmental performance
- regulatory compliance
- EMS implementation
- developing an emergency preparedness process,
- initiating pollution prevention activities,
- creating process documentation and control procedures,
- performing an EMS system audit,
- conducting a management review of the audit results,
- taking corrective and preventive actions on identified deficiencies.
When fully and conscientiously implemented, an EMS provides the framework for management to collect information on the organization’s impacts on the environment and to turn that knowledge into plans and actions to improve environmental performance and better enable employees to perform their jobs in an environmentally conscious manner.
Implementation of an EMS does not guarantee either improved regulatory compliance or significantly improved environmental performance beyond compliance. Thus, adoption of an EMS is not a substitute for existing regulatory requirements, but it has the potential to provide an organization’s management with a roadmap for environmental improvement. Certainty that the EMS has accomplished improvement requires both rigorous data collection in the targeted environmental areas and a process to make those results visible to interested parties. The data collection protocols, an integral part of the EMS study, focus on obtaining answers to these concerns.
California Working Groups
Northern and Southern California regional EMS working groups--involving community groups,
non-governmental public interest organizations, industry, academia, and local, state and
federal regulatory agencies--have been established to facilitate dialogue about project
design and implementation as well as regional concerns. The working groups are developing
a common understanding and knowledge of EMSs through training organized by Cal/EPA
and funded by a grant from the U.S. EPA Office of Water. Facility tours and presentations
are being provided by pilot organizations. The working groups will be advising pilot
organizations on the development and continual improvement of their EMSs, evaluating the
performance of EMSs, and exploring related public policy issues.
The most recent California Working Group meetings were held in March. The purpose of these meetings was to share information on the draft selection criteria, proposed pilot projects, a model pilot project work plan, and draft evaluation and monitoring parameters as an informal review prior to the May public hearings.
Participation in Multi-State Working Group on EMSs
In late 1996, representatives of several states met to discuss common interests in EMS,
and it became clear that many states, with both Democratic and Republican administrations,
were keenly interested in the EMS developments. These states decided to conduct pilot
programs to understand the relevancy and value to regulatory programs. From these initial
discussions, the Multi-State Working Group on Environmental Management Systems (MSWG)
formed to coordinate the efforts of all its participants in improving understanding of
EMSs.
A Cal/EPA representative chairs the Multi-State Working Group (MSWG) on EMSs, a consortium of 49 member and observer states, four federal agencies and a substantial number of business, public interest groups, and academic institutions.
An open process, involving quarterly meetings and annual workshops, has been established which has strong involvement of public interest groups. Close to seventy-five organizations are participating as pilot projects in the United States. A national database has been established to support ongoing research on the performance of EMSs.
Environmental Management Systems, http://www.calepa.ca.gov/EMS/
General Public Contact, cepacomm@calepa.ca.gov (916) 323-2514