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Revised: Feb 2005 BC Timber Sales Environmental Management System (EMS) and Sustainable Forest Management (SFM) Training for LPC Training for LPC Management and Field Management and Field Supervisors Supervisors

Revised: Feb 2005 BC Timber Sales Environmental Management System (EMS) and Sustainable Forest Management (SFM) Training for LPC Management and Field Supervisors

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Revised: Feb 2005

BC Timber Sales Environmental Management System (EMS) and Sustainable Forest Management (SFM)

Training for LPC Training for LPC Management and Field Management and Field SupervisorsSupervisors

Revised: Feb 2005

Acronyms used in this training

BCTS = BC Timber SalesBA = Business Area, ie: regional BCTS officeLPC = Licencee, Permittee or ContractorLWCP = Licencee With Cutting PermitEMS = Environmental Management SystemEOP = Environmental Operating ProcedureEFP = Environmental Field ProcedureEPRM = Emergency Preparedness & Response

ManualERP = Emergency Response ProcedureSFMP = Sustainable Forest Management Plan

Revised: Feb 2005

1. What’s first - EMS Review

A quick review of the basics of EMS: PLAN – DO – CHECK - RESPONDWhat is ISO 14001, andThe BCTS approach

Revised: Feb 2005

EMS Review

Scope of the BCTS EMS Defining the scope

The activities and locations where the EMS is applied and implemented

Defining the activities Operational Planning (i.e. layout, cruising, etc) Harvesting (i.e. falling, skidding/yarding, processing,

loading) Roads (i.e. subgrade construction, surfacing, culvert

installs) Silviculture (i.e. site prep, planting, surveys)

Defining the locations TSL operational areas Haul routes (under the management of BCTS) Road permit work sitesX Not the LPC’s camps, shops or off-site facilities

Revised: Feb 2005

EMS Review

Why Do We Need an EMS?To protect the environmentTo allow an outside, 3rd party auditor to verify our claims that BCTS protects the environmentTo have an efficient system for improving our business

Revised: Feb 2005

EMS Review

Why Do We Need an EMS?Due Diligence defense considers if the following are in place:

Preventative system (e.g. EMS)Training programsInternal / external auditsRisk assessmentsContingency plans designed to prevent events

BC Timber Sales EMS offers all of these elements

Revised: Feb 2005

EMS Review

What is our EMS?Defines the environmental performance we’d like to achieveDescribes who will do what, when, to achieve itClear roles and responsibilities at all levels of BCTS and for our LPC’sAlways evaluating and improving the system and our performance

Revised: Feb 2005

EMS Review

What is ISO 14001?A standard (ISO 14001-2004) that defines the necessary elements of an effective environmental management systemRecognized internationallyImplementation in Canada overseen by the Standards Council of Canada

Revised: Feb 2005

EMS Review What does ISO Certification mean?

The BCTS EMS meets the ISO 14001 standard

and

Independent auditors confirm that BCTS is following the practices and procedures that are outlined in the EMS

Revised: Feb 2005

EMS Review

ISO 14001 Certification Does Not: Verify our forest management

practices

Verify that our products come from certified forests

Allow us to use a certification stamp on our products

Revised: Feb 2005

EMS Review

Plan-Do-Check-RespondThe EMS is based on a “continual improvement” loop:

Plan DoCheck

Respond

etc…

Revised: Feb 2005

EMS Review

1. The PLAN EMS Policy

States the guiding principles of our EMSCommits to:• Meeting all laws• Preventing pollution, protecting the

environment• Continually improving

Revised: Feb 2005

EMS Review

1. The PLAN Aspects“An element of an organization’s activities that can interact with the environment”

An environmental aspect lies between an activity and an impact:

RoadConstruction

LandslideAlter or Influence:Soil Productivity

and Stability

Revised: Feb 2005

EMS Review

1. The PLANSignificant Aspects

“Significant” or higher risk environmental aspects are given priority. Examples are:

1. Uncontrolled: Fire2. Spillage of: Chemical products3. Spillage of: Fuel / Oil products 4. Improper disposal of: Hydrocarbons 5. Alter or influence: Hydrology

characteristics6. Alter or influence: Species at risk

Revised: Feb 2005

EMS Review

2. DOImplement “Operational Controls”

EFP’s in the fieldEOP’s for BCTS staffPreworks for all LPC’sMonitoring and inspecting of activitiesChecklists guiding key activities

Must know the requirements for the tasks you are doing

Revised: Feb 2005

EMS Review 2. DO

Checklists:CHK-001 Planning Prework FormCHK-002 Harvest & Roads Prework FormCHK-003 Silviculture Prework FormCHK-004 Planning Inspection-Monitoring Form CHK-005 Harvest & Roads Inspection-Monitoring FormCHK-006 Silviculture Inspection-Monitoring FormCHK-007 Incident Report FormCHK-008 Emergency Response Test-Drill Report Form

EFP1 - General2 - Project Supervision3 – Development and Planning4 – Roads, Bridges, and

Culverts5 - Harvesting6 – Fuel Handling7 – Dryland SortEOP1 – Planning2 – LP Operations3 - BCTS Projects4 - LWCP Planning5 - LWCP Operations6 - Incident Reports

Revised: Feb 2005

EMS Review 2. DO

Must be trained for the tasks you are doingTraining requirements are identified in the Training Matrix provided at the BCTS Prework

Revised: Feb 2005

Training Needs Matrix

1. BA Staff

Training Package Content TSMO

pera

tions

Mana

gers

Plann

ing O

ffice

r

Enginee

ring O

ffice

r

Enginee

ring T

echni

cian

Forest

Tec

hnici

ans

Ope

ratio

ns Tec

hnicia

n

Area

Fore

sters

Pract

ices

Fore

ster

Field

Oper

atio

ns

Supervi

sor

Resourc

e Cle

rks

Oth

er fi

eld s

taff

Oth

er O

ffice

Staff

Level 1 EMS / SFM Aw areness x x x x x x x x x x x x x

Level 2 EMS Procedures x x x x x x x x x x xLegal Reqts Fire S100 x x x x x x x x

WHMIS x x x x x x x x x x x x xEmergency ERM x x x x x x x

2. Licencees / Permitees / Contractors

Training Package Content Princip

al

Supervi

sor

Work

er

Truck

Driver

Level 3 EMS/SFM Aw areness / Procedures x x x 4

Legal Reqts Fire S100 1 1TDG Certif ication 2 2 2WHMIS 3 3 3 3

Emergency ERM x xERP x x x 4

1 - At least one w orker onsite carrying out industrial activity under a Timber Sale or Licence during f ire season must have S100 training2 - Applies to personnel transporting Class 3 products in quantities > 2000 liters (TDG reg 1.35)3 - As required by WHIMIS w hen handling or exposed to hazardous substances (eg: fuel, chemicals)4 - Truck drivers and trucking contractors require Level 3 and ERP training w here they have the potential to cause a signif icant environmental impact eg: hauling quantities of fuel greater than 2000 litres, self-loading of logs, off-highw ay, etc.

Revised: Feb 2005

Training Content Guide

TRA

INER

EMS

CA

RD

ISSU

ED?

TRA

INER

S C

AR

D IS

SUED

?

EMS

Aw

aren

ess

SFM

Aw

aren

ess

EFPs

EPR

M

EOPs

Che

cklis

ts

Man

ual

Trai

ning

Met

hods

Supp

lem

enta

ry (T

DG

, WH

MIS

, etc

.)

BA EMS Committee / TSM

CSO All Relevant All All All All All - Relevant

BCTS Field Staff CSO All Relevant All All All All Relevant - RelevantBCTS Admin. Staff CSO All Relevant - - - - Relevant - RelevantLPC Principal / Supervisor

Approved ** Y All Relevant All All Relevant Relevant - Relevant

Worker * LPC or Approved ** Relevant Relevant All All - - - - -Train-the-Trainer CSO Y All All All All Relevant - All All

* Valid only during employment for the LPC who provided the training** Approved = Holder of a Trainers Card or a BCTS staff member approved by the CSO

Level 1Level 2Level 3

Refresher intervals are not defined. It is the responsibility of the LPC and the Workers to maintain the level of training. BCTS will identify LPCs and Workers who have not maintained adequate levels of training in preworks and inspections, and require

Revised: Feb 2005

EMS Review 3. CHECK

Method of Checking

Who is checking

Monitoring (Supervision)

LPC, BCTS

Inspections LPC, BCTS

Performance Reports BCTS

Internal Audits BCTS

External Audits Registrar

Revised: Feb 2005

EMS Review 3. CHECK

Things to Check Who is checking

Conformance to the project plan

LPC, BCTS

Conformance to EMS requirements

LPC, BCTS

Compliance with legal and other requirements

LPC, BCTS

Progress towards EMS objectives

BCTS

Revised: Feb 2005

EMS Review 4. RESPOND

Action Plans are written during inspections – who is to do what, by whenEMS modifications / improvements will be assigned as Action Plans or in annual reviewsIssues will be investigated and Action Plans assigned to address root causesAll actions will be assigned, tracked & followed up

Revised: Feb 2005

EMS Documentation

EMS ManualEMS Manual

Environmental Operating Procedures (EOPs)

Environmental Operating Procedures (EOPs)

Environmental Field Procedures (EFPs)

Environmental Field Procedures (EFPs)

•Policy•Tables (e.g.: Training Matrix)•Environmental Program(s)•Administrative Forms•ERM•Records

•Operational Forms/“Checklists”•Records

Revised: Feb 2005

EMS Documentation

EMS ManualEMS Manual

Environmental Operating Procedures (EOPs)

Environmental Operating Procedures (EOPs)

Environmental Field Procedures (EFPs)

Environmental Field Procedures (EFPs)

•Policy•Tables (e.g.: Training Matrix)•Environmental Program(s)•Administrative Forms•ERM •Records

•Operational Forms/“Checklists”•Records

Revised: Feb 2005

Overview: EMS Manual

Consistent with 16 ISO 14001 elements, Policy to Management ReviewDescribes EMS maintenance responsibilities for BCTS managementFor BCTS staff and LPC’s:

Be trained in and follow relevant procedures (EOP’s, EFP’s, ERP’s)Communicate requirements, communicate problems

Revised: Feb 2005

Key Elements – Chapter 1-601 Introduction Defines the scope

Planning, Harvest, Roads, Silviculture

02 Overview of ISO 14001 Defines ISO 14001Introduces the ISO/EMS cycle

03 Environmental Policy Defines policy components6 overall goals, available to public

04 Environmental Aspects Defines aspect developmentRisk based approach, review annually

05 Legal Requirements Defines applicable legislation to BAMaintain access, “other requirements”

06 Objectives & Targets Defines method & responsibilityWhat’s considered, Who develops

Revised: Feb 2005

Key Elements – Chapter 7-1207 Environmental

Management ProgramDefines implementation of O&T Who, What, When, and How

08 Structure & Responsibility

Provides overview of Who & WhatOrganization charts, table of roles

09 Training & Awareness Defines requirements & methodTraining matrix, who trains, etc.

10 Communication Defines communication processInternal methods, External methods

11 Document Control Defines creation & maintenanceWho develops/maintains, obsolete docs

12 Operational Controls Provides a List of controlsDevelopment & Maintenance

Revised: Feb 2005

Key Elements – Chapter 13 - 1813 Emergency Response Defines emergency components

ERM, ERP; development & maintenance

14 Monitor & Measure Defines monitoring methodsConformance, compliance, inspections

15 Corrective/Preventative Action

Defines reporting & trackingIncident reports, tracking & follow up

16 Records Defines record maintenanceWhat is kept, method & duration

17 Audit Program Defines protocol, scope, & methodInternal audits, timing, action plans

18 Management Review Defines scope and review processPerformance reports, responsibilities

Revised: Feb 2005

EMS ManualEMS Manual

Environmental Operating Procedures (EOPs)

Environmental Operating Procedures (EOPs)

Environmental Field Procedures (EFPs)

Environmental Field Procedures (EFPs)

•Policy•Tables (e.g.: Aspects)•Environmental Program(s)•Administrative Forms•ERM•Records

•Operational Forms/“Checklists”•Records

EMS Documentation

Revised: Feb 2005

EMS ManualEMS Manual

Environmental Operating Procedures (EOP)

Environmental Operating Procedures (EOP)

Environmental Field Procedures (EFP)

Environmental Field Procedures (EFP)

•Policy•Tables (e.g.: Aspects)•Environmental Program(s)•Administrative Forms•ERM •Records

•Operational Forms/“Checklists”•Records

EMS Documentation

Revised: Feb 2005

Overview : Emergency Response Manual (ERM)Addresses 3 types of emergency:

FireSpillLandslide or major erosion event

Provides:Preparedness informationResponse proceduresContact information

References the Emergency Response Plan Form to be completed for each Project

Revised: Feb 2005

EMS ManualEMS Manual

Environmental Operating Procedures (EOPs)

Environmental Operating Procedures (EOPs)

Environmental Field Procedures (EFPs)

Environmental Field Procedures (EFPs)

•Policy•Tables (e.g.: Aspects)•Environmental Program(s)•Administrative Forms•ERM•Records

•Operational Forms/“Checklists”•Records

EMS Documentation

Revised: Feb 2005

EMS ManualEMS Manual

Environmental Operating Procedures (EOPs)

Environmental Operating Procedures (EOPs)

Environmental Field Procedures (EFPs)

Environmental Field Procedures (EFPs)

•Policy•Tables (e.g.: Aspects)•Environmental Program(s)•Administrative Forms•ERM•Records

•Operational Forms/“Checklists”•Records

EMS Documentation

Revised: Feb 2005

Overview: Emergency Response Plan

The ERP must be completed and maintained at the worksiteAll workers must know the location of the ERPAll workers must be able to effectively use the information found in the document

Revised: Feb 2005

Highlights: Emergency Response Plan

Contains names and phone numbers of key personnelContains emergency phone numbers of key agencies (PEP, Fire Reporting Centre, etc)Contains spill response steps for Fire, Spills, and Erosion eventsContains locations of spill and fire equipmentContains test or drill requirements

Revised: Feb 2005

Overview: Environmental Operating Procedures

Document Applies to:EOP 01 – Planning BCTS Staff

EOP 02 – LP Operations BCTS Staff

EOP 03 – BCTS Projects BCTS Staff

EOP 04 – LWCP Planning Licensees w/ cutting permits

EOP 05 – LWCP Operations Licensees w/ cutting permits

EOP 06 – Incident Reports BCTS Staff

Purpose: Define tasks & responsibilities for BCTS operations

Revised: Feb 2005

Overview: Checklist Forms

# Name For:

CHK 001

Planning Prework Form All

CHK 002

Harvest/Roads Prework Form All

CHK 003

Silviculture Prework Form All

CHK 004

Planning Inspection Form All

CHK 005

Harvest/Roads Inspection Form

All

CHK 006

Silviculture Inspection Form All

CHK 007

Incident Report Form All

CHK 008

ER Test & Drill Report Form LPC

Purpose: Checking, Responding, & Data collection

Revised: Feb 2005

Highlights: Prework Forms (CHK 001-003)

Used by BCTS staff during Preworks with Licensees or Contractors and may be used by a LPC if they have no other documentation methodSignificant issues captured at Preworks

Operational requirements (Project Plans)Legislative & Regulatory requirementsContractual or License requirementsEMS requirements

• Training needs• Emergency Response• Fuel Management

Primary benefits of Preworks – outlines the expectations for site specific environmental management to the recipient prior to commencement of work

Revised: Feb 2005

Highlights: Inspection Forms (CHK 004-006)

Used by BCTS staff and can be used by LPC if no other documentation method existsSignificant Issues captured during inspections:

Conformance and compliance to contractual and legal documentsConformance to operational plans

• Site Plans• Road Plans and Profiles

Conformance to EMS requirements• Training and Competence• Emergency Preparedness and Response• Fuel Management

Revised: Feb 2005

Highlights: Incident Report Form (CHK 007)

To be used by LPC and BCTS staff to report incidents and initiate investigationsWhen Incident Reports are required:

Spills over 25 litersFires (Natural, man-caused, or industrial)Erosion events or landslidesNon-complianceSignificant Non-conformance (BCTS staff)

Information captured during Incident reporting and investigations

Description of the Incident (scene details)Determination of preliminary and root causesRecommendations and Corrective Action to mitigate future events

Revised: Feb 2005

Highlights: Test/Drill Report Form (CHK 008)

To be used by LPC to record details of tests or drills conducted for emergency responseRequirement and frequency of tests or drills are outlined at BCTS PreworksInformation captured during Test/Drill reports

Type of test or drill (Fire, Spill, Erosion)Description of the test or drillDescription of the deficiencies during the eventRecommendations for improvement

Revised: Feb 2005

EMS ManualEMS Manual

Environmental Operating Procedures (EOPs)

Environmental Operating Procedures (EOPs)

Environmental Field Procedures (EFPs)

Environmental Field Procedures (EFPs)

•Policy•Tables (e.g.: Aspects)•Environmental Program(s)•Administrative Forms•ERM•Records

•Operational Forms/“Checklists”•Records

EMS Documentation

Revised: Feb 2005

EMS ManualEMS Manual

Environmental Operating Procedures (EOPs)

Environmental Operating Procedures (EOPs)

Environmental Field Procedures (EFPs)

Environmental Field Procedures (EFPs)

•Policy•Tables (e.g.: Aspects)•Environmental Program(s)•Administrative Forms•ERM•Records

•Operational Forms/“Checklists”•Records

EMS Documentation

Revised: Feb 2005

Overview: Environmental Field Procedures

# Name For:

EFP 01 General All workers

EFP 02 Project Supervision LPC supervisors

EFP 03 Development & Planning

Contract workers

EFP 04 Roads, Bridges, & Culverts

LPC workers

EFP 05 Harvesting Licensee workers

EFP 06 Fuel Handling All workers

EFP 07 Dryland Sort Licensee workers

Purpose: Methods to minimize environmental impacts

Revised: Feb 2005

Highlights: EFP 01 - General

General procedures provided to all workers and designed to minimize impacts while conducting License or contract operations for BCTSKey Highlights

Prework awarenessProject Plan awarenessMonitoring the workSite maintenance & Emergency PreparednessStop Work criteria

Revised: Feb 2005

Highlights: EFP 02 – Project Supervision

General procedures provided for all field supervisors and designed to minimize impacts by providing clear responsibilities for those who oversee workers during License/Contract operationsKey Highlights

Prework components and documentationSupervisory responsibilities & Stop Work criteriaMonitoring and InspectionsDocumentation managementEmergency Reporting procedures

Revised: Feb 2005

Highlights: EFP 03 – Development and Planning

General procedures provided to all workers performing operational planning activities and designed to minimize impacts in the field Key Highlights

Project Plan preparationField work requirementsData integration into layout & design workStop Work criteria

Revised: Feb 2005

Highlights: EFP 04 – Roads, Bridges, and Culverts

General procedures provided to workers performing construction, maintenance, inspection and deactivation activities and designed to minimize impacts in the field Key Highlights

Road & Bridge inspection criteriaConstruction, maintenance, deactivation proceduresBridge & Major Culvert installation, maintenance, and removal precautions and criteriaDisposal proceduresStop Work criteria

Revised: Feb 2005

Highlights: EFP 05 - Harvesting

General procedures provided to workers performing harvesting activities and designed to minimize impacts in the field Key Highlights

Procedures and criteria for:• Falling• Yarding, Skidding and Forwarding• Loading, processing, and hauling

Stop Work criteria

Revised: Feb 2005

Highlights: EFP 06 – Fuel Handling

General procedures provided to all workers involved in handling, storing, and transporting of fuel during regular activities and designed to minimize the potential of pollution Key Highlights

Fuel storage and HandlingRefueling requirementsSpill response referencesStop work criteria

Revised: Feb 2005

Highlights: EFP 07 – Dryland Sort and Log Loading

General procedures provided to workers performing sort yard activities and designed to minimize impacts to sensitive areas and watercourses or water bodies Key Highlights

Sort yard operational requirementsStockpiling & disposal of wasteStop Work criteria

Revised: Feb 2005

Other EMS Requirements

Plan DoCheck

Respond

etc…

Revised: Feb 2005

Checking the ProgressThe BCTS staff approach

Monitoring • Informal visits to the worksite to focus on key risk issues• May or may not be documented (CHK 004-006 can be

used for documentation of monitoring)

Inspections• Formal visits to conduct thorough worksite assessments• Purpose: to identify deficiencies and trends, to collect

data • Frequency: as determined by the Risk Ranking

Primary benefits of Inspections – identifying deficiencies and trends, initiating corrective action, ensuring follow up

Revised: Feb 2005

Checking the ProgressThe LPC Approach

Supervising (similar to monitoring by BCTS)• Continual on-site checking of work progress,

conformance to operational and EMS requirements• May be documented in diaries or on forms

Inspections• Formal worksite assessments by the field supervisor• Purpose: to identify deficiencies and trends within the

workplace• Frequency: as determined at the BCTS Prework

Type of Inspections• Operational and EMS

Revised: Feb 2005

Required Records for LPCPrework Records

Indicating points of discussionDate

Inspection RecordsVerify worksite requirements Date and name of Inspector

Training RecordsNames of workersType and date of training

Incident RecordsSpills over 25 liters, Fires, Erosion events, Non-compliancesAt least the Incident details must be completed

Test/Drill RecordsEmergency Response Plan

Revised: Feb 2005

Other EMS Requirements

Plan DoCheck

Respond

etc…

Revised: Feb 2005

Respond – Corrective Action

The BCTS ApproachIf deficiencies or trends are noted during monitoring visits or formal inspections, corrective action will be initiated through: • Documentation on the Inspection Forms• Documentation on the Incident Report Forms• Documentation on Notices to Comply• Issue Tracking System entries (ITS)

If deficiencies or trends are noted during Audits, corrective action will be initiated through Audit Action Plans

Revised: Feb 2005

Respond – Corrective Action

The LPC ApproachDeficiencies or trends noted during routine supervision or formal inspections should be followed up ASAP with corrective action

• Immediate Action (i.e. cleaning up the spill)• Preventative Action (i.e. further training or

change to work procedures)

If noted during inspections, corrective action should be noted on form along with the date when corrected

Revised: Feb 2005

Be Prepared for AuditsSupervisors

Ensure workers are instructed by an authorized trainer as per the Training Needs MatrixMake appropriate documents available at the worksite (ERP, EFP)Conduct Preworks prior to commencement of the projectFollow the procedures outlined in the EFP’s to minimize site deg, contamination, and erosionConduct Inspections at the frequency outlined at the BCTS Prework sessionTake action if non-conformances or non-compliances are discoveredMaintain records as required for the EMS

Revised: Feb 2005

Be Prepared for AuditsWorkers

Know the location of the EFP’s and the ERP and have them readily accessibleParticipate in Preworks prior to commencement of the projectFollow the procedures outlined in the EFP’s to minimize site deg, contamination, and erosionBe able to explain how to respond to spills, fires, and major landslides or erosion eventsMake sure you have spill kits and fire tools available to you and they are in working order

Revised: Feb 2005

EMS SUMMARY• Plan – Know how to operate with regard

to the environment • Do – Follow procedures while

conducting business that protect the environment / achieve your plan

• Check – Take the time to review how you do vs. what the plan states

• Respond – Take action and learn from your performance to do better next time

Revised: Feb 2005

SUSTAINABLE FOREST MANAGEMENT

Revised: Feb 2005

Types of SFM Certifications

CSA Z809(2002) – describes how a sustainable forestry management plan (SFMP) should be developed, implemented, and maintained SFI – similar in scope and application to CSA Z809, AmericanFSC - similar in scope and application to CSA Z809, International

Revised: Feb 2005

CSA Z809 CertificationCSA Z809 SFM Standard is based on a Canadian definition of sustainable forest management (SFM) Requires a SFM Plan (SFMP) be in placeRequires a Management System be in place (i.e. an EMS)Results in certification of a Designated Forest Area (DFA) (therefore, most CSA certifications require cooperation amongst all but the smallest licencees operating in the DFA)CSA Standard includes a substantial commitment to involve the public in developing the SFM plan

Revised: Feb 2005

How SFM Plans intersect with an EMS

The following Management system criteria must be implemented:

Legal requirementsRoles and ResponsibilitiesTraining and AwarenessInternal & External communicationDocument management and controlOperational proceduresEmergency Preparedness & ResponseMonitoring and MeasuringCorrective & Preventative ActionRecord KeepingInternal AuditsManagement Reviews

Revised: Feb 2005

Where a SFM Plan has its impactInfluences higher-level planning by introducing its own criteria for forest managementRequires data gathering and reporting to verify adherence to SFM targetsCan produce changes to operational plans

Modification of block size and shapesIntroduction of additional protective measures for resource features and sensitive zonesChanges in road locations and design

Revised: Feb 2005

How to conform to SFM goals in the forest workplace

Follow the Operational PlansFollow EMS requirements

Environmental Field ProceduresEmergency Response PlansLegislation and RegulationsTraining requirements

Follow Contract & License requirementsFollow Legislative and Regulatory requirements