Failures and Successes When Implementing a Non-ISO 14001 EMS at a University and Medical
Center
A Wee Bit of History
• Back in the early 2000s, EPA inspected a number of Region I and II College & Universities
• Resulted in Consent Agreements with agreements to develop an EMS at several schools.
• Environmental Programs decided to be proactive and develop an EMS before Region IV started inspections
Starting the Development Process
• Received special project $$$$ from University
• Hired new employee (actually stole her from safety group)
• Utilized students to facilitate the adoption of the Duke University Environmental Policy – signed Earth Day 2005 (18 month process)
Developed an EMS Vision
Duke has created a comprehensive environmental initiative to incorporate environmental issues into campus decisions and actions – everything fromthe paper you print on to the way buildings are designed.
Set Overall Project Goal
Develop an performance-based EMS to:
• focus environmental initiatives within key areas,
• measure improvement and routinely track and report progress.
EMS Development Objectives
• Develop a campus-wide system that can be utilized by all stakeholders.
• Create an initiative to integrate environmental performance into the campus work culture.
Engaged Campus Organizations
• EMS Planning Committee
• OESO • EMAC – the Environmental
Management Advisory Committee
• DUGI – Duke University Greening Initiative
• EA – Environmental Alliance
• Facilities Management Department
Duke’s Strategic Partnerships
NC DENR Environmental Stewardship Initiative
Labs 21
U.S. Green Building Council Member
EPA’s Green Power Partnership
EPA’s College and Universities Sector Strategies Program
Hospitals for Healthy Environment (H2E)
Camp, Dresser and McKee CDM
Balanced Scorecard Strategic Focus
CustomersCustomersInternalBusinessPractices
InternalBusinessPractices
Learning & Growth
Learning & Growth
Financial Financial
Strategy
A Framework to Integrate Environmental Performance into Management Decisions The Balanced Scorecard
The Balanced Scorecard -• Translates vision and strategy
into operational terms• Focuses, links and aligns an
organizations actions and strategic plans to the institution’s goals
• Makes strategy everyone’s job• Makes strategy a continual
process
Vision & Strategy
Feedback andlearning
Planning andtarget setting
Communicatingthe vision
Review
Focuses, links and aligns an organizations actions and strategic plans to the institution’s goals
Environmental Balanced Scorecard Strategic Focus
ComplianceComplianceConservation & Preservation of
Resources
Conservation & Preservation of
Resources
Learning & AwarenessLearning & Awareness
Sustainability Sustainability
PerformanceStrategy
StewardshipStewardship
Translating the Vision -Focus Performance Improvement in 5 Key Areas
• SUSTAINABILITY – Meet the needs of the present without compromising the ability of future generations to meet their needs.
• COMPLIANCE – Achieve and sustain compliance through good management practices.
• STEWARDSHIP – Less overall environmental impacts by developing & promoting practices that maximize beneficial effects and minimize harmful effects of research, operations, & activities
• RESOURCE CONSERVATION – Utilize, conserve, and restore natural resources in ways that ensure long term social, economic, and environmental benefits.
• EDUCATION & RESEARCH – Increase faculty, staff, and student awareness; enhance environmental educational offerings, support research and disseminate information regarding research opportunities.
Defining Strategic Measures
Sustainability
Compliance
ResourceConservation
Awareness
Stewardship
Sustainability
Compliance
ResourceConservation
Awareness
Stewardship
GHG Reduction
Reduced Solid Wastes/Increased
Recycling
ReducedHazardous
Wastes
Reduced water Consumption
Energy Use
GHG Reduction
Reduced Solid Wastes/Increased
Recycling
ReducedHazardous
Wastes
Reduced water Consumption
Energy Use
Performance Improvement
Areas
Institutional Success Measures
Environmental Performance-Based Organization
Office of the President
Office of the President
EnvironmentalPolicy
EnvironmentalPolicy
Key performanceareas
Key performanceareas
Senior Vice President’s
Office
Senior Vice President’s
Office
Environmental Management
Advisory Committee
Environmental Management
Advisory Committee
Environmental Project Implementation
Teams –OESO, DUGI, Procurement, Labs,
Academic Units, Departments, ,etc.
Environmental Project Implementation
Teams –OESO, DUGI, Procurement, Labs,
Academic Units, Departments, ,etc.
Success indicators
Success indicators
OESOOESO
Improvement projects and initiatives that
align with performanceareas & link to indicators
Improvement projects and initiatives that
align with performanceareas & link to indicators
Align with focus areaAlign with focus area
Link to Success indicator
Link to Success indicator
Opportunitiesidentification
EMS website
Stakeholderinput
Audits &assessments
Support
Annual report
Annual report
Developsprojects
Developed Implementation Plan
Implementation Action Items• Distribute implementation guide,• Build remaining system components, • Launch awareness campaign,• Develop communication strategy,• Complete website,• Develop annual environmental report• Complete linkage of EMS and EMAC to the administration• Develop a long-range funding plan
Pilot Projects• Mercury Reduction Initiative• Recycling Initiative• Energy Use Reduction in Laboratories• Water Use Reduction In Dormitories
Successes & Failures
• Environmental Policy signed • Pilot projects were implemented • EMS was reviewed by State Environmental Stewardship
Initiative – panned plan for not conforming specifically to ISO 14001.
• EMAC committee never truly ‘bought in’ to the EMS process.
• Chairman not engaged• Committee eventually fell apart
• With no committee and “driver” for project, lost support and Campus-wide EMS faded into history
If first you don’t succeed…..
• EPA College & University Initiative required an EMS or audit the facility every two years……
• New EMS Team formed in 2012 – 3 OESO personnel and 1 outside consultant
• Restated Campus-Wide Performance Goal • To achieve, exceed, and sustain long-lasting compliance to
relevant and applicable environmental rules and regulations
• Stated from start – compliance to ISO 14001 not a goal…..a functioning EMS is
Environmental Compliance Management System
• Focus on meeting and exceeding compliance hence the ECMS name
• Elements of system– Environmental Policy– Planning– Implementation and Operation– Checking and Corrective Actions– Management Review
Environmental Compliance Management System
• Recycled and updated a number of processes and plans developed during original EMS development
• Additional Items developed • extensive Regulatory Compliance Calendar• Training Matrix• Numerous SOPs (i.e. internal audit, operational control)
• The ECMS management will remain within OESO EP not with a committee
ECMS Organizational Structure
Roles
Advisory Committee
OESO
Departments/Facilities
Admin.
Performance Goal
Oversight
Planning and Managing
Implementing Projects
Approves and Monitors
Recommends processes for improvement
Operational objectives to meet goal
Roles
• OESO– Development and implementation of ECMS– Link between OESO activities and ECMS activities– Work with departments to determine potential
compliance issues and develop corrective action plans– Overall regulatory compliance
• Advisory Committee– Provides guidance and recommendations– Reviews ECMS materials and reports– Be an advocate
Roles
• Department/Facility– Work with OESO personnel to determine
compliance issues– Participate in compliance surveys– Implement Corrective Action Plans
ECMS Implementation
• Target specific processes to improve consistent with the overall goal to achieve long lasting compliance
• Implement at a department or facility level
Preliminary Evaluation of Areas with Highest Risk
• OESO did evaluation of risks in a number of areas, taking into account:– EPA audit results – Internal laboratory audits – IECP Compliance audits
Example ScoresRegulation Probability
of ViolationImpact of Violation
Potential Env. Impact
Impact on Public Image
Cost Ease of Implementation
Total
Non-lab waste Practice
3 3 2 2 2 2 14
Aerosol Cans 2 2 1 2 2 3 12
Improve Aerosol Can Management• Compliant disposal of aerosol cans• Change in DENR interpretation to include all
discarded cans
Improve Management of Non-laboratory Generated Hazardous Waste
• Paints, inks, solvents, etc. generated by paint shops, facilities, transportation, grounds, golf course, and gardens
Pilot Selection
• Departments or facilities candidates that generate discarded aerosol cans and/or non-lab hazardous waste – FMD – E&O– Transportation
Pilot Implementation
• Implemented Aerosol Can Recycling Program within E&O and FMD
• Conducting surveys throughout E&O and FMD to determine potential environmental compliance issues
• Developed corrective actions plans for non-compliance issues found during surveys.
• Majority of non-compliance issues corrected and department continued compliance plans implemented
Ongoing Plans
• Expand Aerosol Can Management to additional departments
• Complete surveys of FMD & E&O• Begin survey of Transportation and Dining• Meet with Advisory Committee at least once
per year to review ECMS program and compliance status
Successes & Failures
• Slow process but definitely have upper management buy in – Advisory Committee engaged in process
• Departments understand need for the new system
• Departments are willing to implement or make changes to processes for improved compliance
• Implemented changes to Laboratory Audit Program to ensure environmental compliance