Environmental Management Systems

LISA JARVIS

PURPOSE – presentation focuses primarily on

environmental management system (EMS) design

To provide up-to-date, controlled documentation of all programs, procedures, documents, etc.

To provide user-friendly, around the clock access to ensure proper implementation of all EMS programs and procedures.

Proactive approach to help a company address regulatory demands systematically and cost-effectively

Policy and Commitment

Planning

ImplementationEvaluation

Review

EMS under ISO 140015 Main Stages

Continuous Improvement

POLICY – must have the endorsement of

upper management to be effective

Example Company EHS policy is dedicated to: Meeting or exceeding all regulatory

requirements Pollution Prevention wherever feasible Continuous Improvement Consider Environmental factors when

making purchase and operational decisions Establish, track and review specific goals

Identify Environmental AspectsE.g. air pollutants

Determine most important to companyE.g. worker health & safety, compliance and

cost Legal and Other Requirements Objectives and Targets

Objectives – Overall Goal, e.g. minimize useTarget – Detailed, Quantified, e.g. minimize

by 10% by specific date Management Actions to Support

Objectives and Targets

PLAN

Structure and Responsibility Training, Awareness, Competence Communication EMS Documentation Document Control Operational Control Emergency Preparedness and

Response

DO

Example EMS Structure/HierarchyPolicy; System DescriptionOperational and Management ProceduresStandard Operating Procedures or work

instructionsPlans and Reference DocumentsRecords

DO

Environmental Management System (EMS)

Air Pollution Control Programs

Waste Management Programs

Water Pollution Control Programs

Workplace Environmental Health Programs

Other Environmental Program Management

PROGRAMS & PROCEDURESExamples:

Air Pollution Control

Programs

Air Emissions Permit

(Title V Permit)

Prescribed Monitoring and

Analysis

Compliance Plan

Standard Operating

Procedures

Refrigerants Management

Procedure

Risk Management

Plan

CLEAN AIR ACT Example Applicable Legislation:

Title V Operating Permit ProgramAmendments of 1990

○ National Ambient Air Quality Standards (NAAQS)○ National Emission Standards for Hazardous Air Pollutants (

NESHAP) CAA Title I Section 112 40 CFR Part 63

- Maximum Achievable Control Technology (MACT) - the 1990 amendments to the CAA changed EPA's approach to regulating HAPs, so that NESHAPs are now established based on the "maximum achievable control technology" (MACT) for an industry group or source category (for example, hazardous waste combustors).

Risk Management Plan Title III of CAA, 40 CFR Part 68

PROGRAMS & PROCEDURESExamples:

Water Pollution Control

Programs

Wastewater Discharge Permit

(NPDES Permit)

Best Management

Practices Plan

Sludge Management

Plan

Stormwater Pollution

Prevention Plan

Monitoring and Recordkeeping

Data

Oil Spill Prevention, Control and

Countermeasures Plan

Drum Management

Bulk Liquid Handling and

Storage Procedures

CLEAN WATER ACT Example Applicable Legislation:

Code of Federal Regulations - Title 40 - Protection of EnvironmentChapter I - Environmental Protection Agency

○ Subchapter D--WATER PROGRAMSNPDES (CWA Section 402)

○ 40 CFR Part 122Toxic Pollutant Effluent Standards

○ 40 CFR Part 129Water Quality Standards

○ 40 CFR Part 131

PROGRAMS & PROCEDURESExamples:

Waste Management Programs

Hazardous Waste Spill Prevention, Control & Countermeasure Plan

Waste Analysis

Solid Waste Management

Recordkeeping and Reporting

Pollution Prevention Plan

WASTE MANAGEMENTExample Applicable Legislation:

Resource Conservation and Recovery Act (RCRA) Non-hazardous waste/Solid waste 40 CFR Part

239-259 Hazardous waste 40 CFR Part 260 [-279]

○ Details – Part 261 Ignitable Waste (I) Corrosive Waste (C) Reactive Waste (R) Toxicity

Characteristic Waste (E) Acute Hazardous Waste (H) Toxic Waste (T) = Characteristic waste

Specific wastes such as, slop oil emulsion solids from the petroleum refining industry [K049] = Listed waste

Pollution Prevention Act Toxic Substances Control Act

Workplace Environmental Health and Safety Management Programs

Safety and Environmental

Programs

Hazardous Substances Management [Asbestos,

PCB, Solvents, Bloodborne Pathogens

Contractor Safety

Emergency and Disaster

Response

Embryo-Fetus Protection

Radiation Source Control Program

Occupational Health and Industrial Hygiene

Program

Hazard Communication

Program

MSDS Database

Company MSDS

New Product Approval

Procedure

Chemical Inventory

MSDS Update

Procedure

Exposure Standards

Workplace Sampling Program

Respiratory Protection Program

Fit-testing Database

Respiratory Protection Against Airborne Lead

Program

Industrial Hygiene

Database

Hearing Conservation

Program

WORKPLACE ENVIRONMENTAL HEALTH MANAGEMENTExample Applicable Legislation:

Occupational Safety and Health Act Occupational Safety and Health

Administration (OSHA)National Institute for Occupational Safety

and Health (NIOSH)CFR Title 29 Part 1910 - Labor

○ Subtitle B--Regulations relating to Labor, Chapter xvii--OSHA, Department of LaborThe 1910 Standards cover a myriad of topics:

Personal Protective Equipment (PPE), Occupational Noise Exposure, Emergency Planning and Response…

EXAMPLES:

Other Environmental Program Management

Corporate Citizenship Program

Tier II Reports [Inventory of

Substances for Emergency

Responders]

Toxic Release Inventory Reports

Community Relations and Communications

EHS Management

Programs, Procedures and work instructions

Descriptions of Roles, Responsibilities,

Authorities and Lines of Communications

Equipment Calibration Procedure

Environmental Calendar and Training Schedule Compliance Reviews

EMS Manual

Policy

Lists of Objectives and Targets

Environmental Aspects and Impacts Inventory

OTHER ENVIRONMENTAL PROGRAM MANAGEMENTExample Applicable Legislation:

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Hazardous Substances [Superfund]

Superfund Amendments and Reauthorization Act (SARA)Emergency Planning and Community Right-

to-Know Act (EPCRA) [also known as SARA Title III]○ Tier II Report [SARA 311/312] – Inventory of

Substances for Emergency Responders, 40 CFR Part 370

○ Toxic Release Inventory Report – [SARA 313] Tier III Report

Monitoring and MeasurementE.g. Use of Checklists to determine

compliance with applicable regulationsPlating bath temperatureAmount of hazardous waste generatedAmount of solvent used for parts cleaning

Nonconformance, Corrective and Preventative Action

Records

CHECK

EMS Audits Management Review

Determines if original policy is consistent with company values

Possible revisions to optimize effectiveness

This final review stage creates a loop of continuous improvement for a company

ACT

Environmental Management System (EMS) Example

This presentation is an example and not site specific

Each company - industry - site requires specific programs, plans, practices and procedures

Intended for an overview - example - general idea - demonstration purposes only

Environmental, Safety and Health Programs, Plans and Procedures overlap For example, Drum

Management is a stand alone SOP, but also a part of the OSPCC Plan

Again, Best Management Practices (BMP) is stand alone, but also part of the NPDES permit

OSHA 1910, in particular, addresses health and safety, but overlaps with environmental aspects ○ i.e. HazCom, Hearing

Conservation, Respiratory Protection, PPE usage…