Ems tool-implementation

Editor's Notes

• #2: [This presentation is intended to inform employees in operational areas of key environmental interest of the structure and purpose of an environmental management system. his presentation is not designed to be used as is, but rather has been developed as an example and may act as a framework from which to develop a more refined presentation to use for educating staff to the requirements of an Environmental Management System]. This presentation aims to introduce you to the structure and purpose of an Environmental Management System.
• #3: [Explain the italicised words:] An EMS is an integral part of a larger management system of an organisation, and not a separate system. Most organisations will have systems for managing their human resources, business objectives and plans and finances, and many will also have systems for managing the quality of their products and services, occupational health and safety, security, and environmental impact of their activities, products and services. These systems will work more effectively and efficiently if they share processes, such as a planning cycle, establishment of objectives and programs to achieve them, monitoring and measurement, corrective and preventive action for continual improvement, and management review. The environmental policy articulates the overall intentions and direction of an organisation related to its environmental performance as formally expressed by top management. It provides commitment to compliance with legal and other requirements, prevention of pollution, and continual improvement. It also provides a framework for action and the setting of environmental objectives and targets. The EMS is primarily about putting the environmental policy into action. Environmental aspects are those activities, products and services of an organisation that have or can have an impact on the environment. An EMS identifies such environmental aspects and determines which of them can have a significant impact on the environment. This helps an organisation understand how it interacts with the environment. This in turn guides an organisation in determining where environmental controls or improvements are needed, and setting priorities for action to enhance environmental performance.
• #4: The International Organization for Standardization (ISO) is a non-government network of national standards institutes. It develops and publishes international standards. The Joint Standards Australia/Standards New Zealand Committee QR-011, Environmental Management Systems, adopted both of these ISO standards in their entirety in 2004. Therefore, in Australia we refer to the standards as AS/NZS ISO 14001:2004 and AS/NZS ISO 14004:2004. AS/NZS ISO 14001:2004 provides an international standard for the requirements of an environmental management system. Certification of management systems can be obtained from third party auditors.
• #5: The structure of AS/NZS ISO 14001:2004 follows a Plan-Do-Check-Act (or PDCA) management approach. The steps are as follows: PLAN  : Establish the objectives and processes necessary to deliver results in accordance with the specifications. DO  : Implement the processes. CHECK : Monitor and evaluate the processes and results against objectives and specifications and report the outcome. ACT  : Apply actions to the outcome for necessary improvement. This means reviewing all steps (Plan, Do, Check, Act) and modifying the process to improve it before its next implementation. In AS/NZS ISO 14001:2004, the Plan-Do-Check-Act approach is shown as a continual improvement spiral starting with development of the environmental policy. The outcome of management review is a set of changes to the rest of the system designed to improve the system, and ultimately, environmental performance.
• #6: This slide shows that an environmental management system is established and implemented as a set of elements, or components or processes that interact with each other. Each element has inputs from other elements, and provides outputs to other elements. The overall system is all designed to ensure continual improvement. [This may be a good slide to provide in hardcopy for the audience to refer back to throughout the presentation].
• #7: There are a large number of criteria to consider when deciding on whether our organisation should have an environmental management system in the first place, and seek certification to the requirements of ISO 14001 in the second place. [Work through the criteria and discuss relevance to the agency. Ask people if they can think of any more criteria?]
• #8: [s.516a of the EPBC requires all Commonwealth agencies, authorities and companies to report annually on how activities or administration of legislation accorded with the principles of ecologically sustainable development as well as the environmental impacts of their activities and measures taken to minimise the negative environmental impacts].
• #9: If senior managers are keen, they could become members of a steering committee to establish the EMS. [The first three and the last point comes directly from the requirements in the international standard].
• #10: The next series of slides will look at the elements of an environmental management system. It will follow the structure of the international standard, that is, the plan-do-check-act cycle of continual improvement: start with the environmental policy, then move on to planning the EMS, then implementation and operation, then checking, and finish with management review. This first slide deals with the environmental policy.
• #11: Planning the EMS involves three elements of the EMS: Environmental aspects Legal & other requirements Objectives, targets & programs
• #12: An environmental management system (EMS) is the system by which an organisation controls the activities, products and services that cause, or could cause, environmental impacts and in doing so minimises the environmental impacts of its operations. Those activities, products and services are called environmental aspects. This approach is based on the management of ‘cause and effect’ where an organisation’s activities, products and services are the causes or ‘aspects’, and their resulting effect, or potential effect, on the environment are ‘impacts’. Identification of environmental aspects is fundamental to the EMS. Once this is done, the aspects and associated impacts can be analysed to determine risk. The risks can in turn be evaluated to determine which environmental aspects and impacts are significant risks to the environment and/or the organisation. Environmental aspects must be documented and kept up to date. The significant environmental aspects are the focus of the rest of the EMS.
• #13: The environmental policy must include a commitment to complying with legal and other requirements. It is therefore important to identify those requirements, show how they relate to the environmental aspects, and keep them up-to-date. Legal and other requirements must be incorporated in the rest of the EMS. Accordingly, most organisations automatically regard an environmental aspect as significant if there is a legal or other requirement associated with it.
• #14: [Explain what environmental objectives and targets are from the first two points.] Together, objectives and targets must be measureable, where practicable. Ideally, they should be SMART (Specific, Measureable, Realistic and Time-based). To achieve the objectives and targets, the agency needs an environmental program, or action plan, or a set of programs/plans.
• #15: Implementation and operation of an EMS includes the elements mentioned in this slide. We will work our way through these.
• #16: We have already looked at management roles. One vital role is the provision of resources for the EMS. There is no doubt that additional resources will be required. However, if we do it properly, this will be an investment that will yield benefits. The standard requires roles, responsibilities and authorities relevant to environmental management to be documented—they are that important! One of the most important management roles is that of management representative.
• #17: Those positions or roles that have potential to cause a significant environmental impact, that is, are working in areas or jobs associated with the agency’s significant environmental aspects, need to be identified. The people occupying those positions or roles then have to be assessed as competent on the basis of appropriate education, training or experience. Following on from this, the training needs of people in these roles and positions has to be identified, and then training or other action has to be provided to meet those needs. Everyone in the agency is required to have a general awareness of the EMS, especially: The importance of conformity with the environmental policy and other requirements of the EMS Significant environmental aspects and related impacts associated with their work Environmental benefits of improved personal performance Roles and responsibilities relevant to the EMS Potential consequences of departure from specified procedures. We have another template presentation we can adapt to propagate awareness.
• #18: Government agencies generally have good processes in place for internal communication—these need to be tapped into so that information on the EMS can be exchanged both upwards and downwards in the structure. Government agencies also usually have good records management systems—just need to ensure that external communications on environmental issues are appropriately received, documented and responded to. The third point is a requirement of ISO 14001 to document a decision about whether to communicate proactively externally about an organisation’s significant environmental aspects. There are three likely options: Publication of significant environmental aspects on the Internet, or in annual reports, or in some other form. No publication of significant environmental aspects. Dealing with significant environmental aspects on a case-by-case basis.
• #19: There is a minimum list of documentation required for a certified environmental management system: Environmental policy, objectives and targets Description of the scope of the environmental management system Description of the main elements of the environmental management system and their interaction, and reference to related documents Documents and records required by the standard Documents and records determined by the organisation to be necessary to ensure the effective planning, operation and control of processes that relate to its significant environmental aspects. The last point will come up again shortly.
• #20: Document control refers to a procedure for: Document approval Document review, update and re-approval Identification of changes and current revision status Availability at points of use Legibility and identification Identification and distribution of external documents Management of obsolete documents. This is usually easy for government agencies, as most of this will already be in place.
• #21: The first point is simply about the need for operational control (or internal control) of significant environmental aspects to ensure that they are carried out in accordance with requirements of the EMS. The second point is about providing documented work instructions and procedures to control processes and operations which do or could have a significant environmental impact. This is the same as a requirement made two slides ago regarding documentation required for an EMS: “Documents and records determined by the organisation to be necessary to ensure the effective planning, operation and control of processes that relate to its significant environmental aspects.” The international standard clearly puts the responsibility on the organisation to determine when operational procedures need to be documented. You do not have to document everything! Instead, a risk management approach should be used. The criteria that could be considered when adopting a risk based approach to documenting procedures include: Likelihood and consequences of environmental impact Legal and other requirements Size and complexity of the organisation and the need to ensure that a procedure is undertaken consistently throughout the organisation Benefits for training. Finally, operational control procedures are also required for significant environmental aspects of goods and services used by the organisation. These do not strictly have to be documented, but documentation facilitates communication of them to suppliers, including contractors.
• #22: Most large office-based organisations already have an emergency preparedness & response plan as an OH&S requirement. The requirement for an EMS is the same.
• #23: The next step in establishing an EMS is to ensure that there is a way of checking that all is going to plan. This involves: Monitoring & measurement Evaluation of compliance Nonconformity, corrective action & preventive action Control of records Internal audit We will work through these.
• #24: In the context of an environmental management system, environmental performance is the measureable results of an organisation’s management of its environmental aspects. The standard requires an organisation to have a procedure for monitoring and measuring, on a regular basis, the key characteristics of its operations that can have a significant environmental impact. The procedure must include the recording of information to monitor environmental performance, operational controls, and progress on achieving the organisation’s environmental objectives and targets. Any monitoring or measuring equipment that requires calibration or verification must have its calibration and verification maintained, as evidenced by records.
• #25: In addition to monitoring and measurement of operational activities, the standard requires an organisation to periodically evaluate its compliance with applicable legal requirements and with other requirements to which it subscribes, and keep records of the results of the evaluations. This is consistent with that commitment to compliance made in the environmental policy. The distinction between monitoring and measurement on the one hand and periodic evaluation of compliance on the other is not always appreciated: Monitoring and measurement is an ongoing process to collect data required by legal and other requirements. Evaluation of compliance is about analysing and comparing the data collected over a period of time with legal and other requirements. The evaluation can be conducted in a compliance audit.
• #26: Nonconformity is non-fulfilment of a requirement, that is, when something does not go to plan. In the context of an environmental management system, environmental nonconformity occurs when: an environmental control is not implemented or is ineffective, an environmental emergency or accident happens, a licence condition is breached, acceptable levels of a monitored or measured characteristic are exceeded, an environmental objective or target is not met, a neighbour or member of the public complains about an environmental issue from your site, a documented procedure or work instruction is not followed, and so on. Actual and potential nonconformity is identified and suggestions for improvement are made by: Internal audit External audit Site inspections Feedback from external parties Complaints from customers or other stakeholders Suggestions for improvement from staff and contractors Occurrence of environmental emergencies and accidents Testing of emergency preparedness and response Management review Corrective and preventive action are used when a nonconformity is identified, regardless of its source. They involve getting to the root cause of the nonconformity, then determining and taking corrective action to ensure the actual nonconformity does not recur, or preventive action to ensure the potential nonconformity does not occur in the first place. The next slide shows how this works in practice.
• #27: This shows a flowchart of the corrective and preventive action process. The objective of the process is to drive continual improvement of the EMS.
• #28: Our agency has a good records management system—all we need to do is ensure that it is used by the EMS.
• #29: Internal audits of an environmental management system provide information to management on whether the system conforms to planned arrangements and has been properly implemented and maintained. Ideally, an internal audit looks forward and evaluates the effectiveness of a management system in fulfilling the commitments made in the management system policy and achieving the objectives and targets established for the management system. In the early days of establishing the EMS, internal audits will focus on conformity with the international standard so that certification can be achieved and maintained. It is also appropriate to evaluate compliance with legal and other requirements in an internal audit. In a mature EMS, an internal audit program should be established on a risk basis by considering the environmental importance of an organisation’s operations in terms of its environmental aspects and impacts, and the results of previous audits.
• #30: This is the last element of the EMS, but one of the most important. This is where top management: takes a holistic and strategic look at the continuing suitability, adequacy and effectiveness of the environmental management system, and 2. approves actions to improve the system, and in turn improve the environmental performance of the organisation.
• #31: The following 10 steps are involved in establishing and implementing an EMS that is based on the international standard AS/NZS ISO 14001:2004. They could be used as the basis for a project plan. Step 3 could include an initial environmental review. ISO 14004 recommends an EIR when an organisation is establishing an EMS from scratch. The main aim of the review is to consider the environmental aspects as the basis for the EMS. It can also cover identification of legal & other requirements, examination of existing environmental management practices and procedures, and evaluation of previous emergency situations and accidents. We can use ISO 14004 for further guidance on this.
• #34: These steps are in addition to establishing an EMS and may be taken if the decision is made to apply for independent certification of the system.
• #36: There are several resources that can help the agency establish and implement an EMS. A model EMS for government agencies has recently been devised by the Department of Environment, Water, Heritage and the Arts.It comprises: A guide to the EMS An EMS manual with essential procedures A list of legal requirements to be used as the starting point for compiling a register of legal and other requirements. A glossary and reference list to all the relevant standards. Training packages that can be adapted by a government agency, like this package. A decision support spreadsheet. The model has been devised especially for Australian government agencies. It is focussed on a practical system for mostly office-based organisations with relatively low environmental risk. There are three standards directly relevant to environmental management systems: AS/NZS ISO 14001:2004 has the requirements for an EMS—this is the standard to which an EMS can be certified. AS/NZS ISO 14004:2004 has guidelines on principles, systems and support techniques for an EMS AS/NZS ISO 19011:2003 has guidelines for managing internal audit programs as part of an EMS. There are a number of organisations that provide a variety of relevant training. For example, NCS International runs public courses, and can offer in-house courses. Training courses are based on the requirements and guidelines in the international standards. There is also a plethora of consultants willing to assist. However, this can be an expensive trap. Some consultants will provide an organisation with EMS, walk away, and charge a fortune. The risk is that the organisation does not feel that it owns the resulting EMS. The model EMS was devised by NCSI Training & Development to be adapted to an agency by the agency. That way, the agency will own the EMS, but NCSI T&D is still available to assist with the adaptation in an efficient and effective way. As a consultant, NCSI will provide guidance, but agency staff will do all the work. This keeps external costs down. The JAS-ANS website lists accredited conformity assessment bodies that can certify an EMS. NCS International and SAI Global are the major Australian-based players in Australia.
• #37: The next two slides take a realistic view of the additional resources that will be required for an agency to establish and implement an EMS.
• #39: These are all potential barriers to successful establishment and implementation of an EMS. The model environmental management system for government agencies has been put together with these barriers in mind. It is very practical, and is tailored to the requirements of small to large, mainly office-based organisations, with potential for application organisations with substantial field operations.