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Environmental Management System

The Main Parts of an Environmental Management System (EMS)

 

  • Environmental Policy
    • The creation of an environmental policy is the starting point for any EMS. Without the commitment of upper management, there is no force behind an EMS. UVa's environmental policy shows the University's commitment to reducing its negative impacts on the environment and striving to be environmentally friendly in its operations. Read UVa's Environmental Policy here.
  • Fenceline
    • After the adoption of the environmental policy, the next step is to identify the fenceline where the EMS will be implemented. For industry or a small college, the fenceline is usually the entire facility and covers all of their operations. For an operation as large and complex as UVa, it was decided to break up the University into many smaller fencelines, such as invividual deparments, and implement piece by piece. All of the pieces will add up into one complete EMS covering the whole University. The term fenceline is used interchangeably with the term facility for UVa's EMS Implementation.
  • EMS Team
    • The creation of a strong EMS Team is important for having a strong EMS within a fenceline. The EMS Team includes as many people as necessary to fully cover all of the operations within the fenceline. The team should have as many different types of positions as possible, from mechanics to managers. The goal is to include as many perspectives as possible so that nothing is overlooked but not so many people that the team becomes excessively large. The team plays a vital role in determining aspects, impacts, and significance ranking. They also monitor the daily functioning of the EMS at their facility, so the team's active input and involvement is critical.
    • At UVa, the EMS Team includes at least one representative from Environmental Health & Safety to implement the EMS, steer the team, and help keep the EMS working smoothly.
  • Identification of Aspects and Impacts
    • When initiating an EMS at a facility, all of the fenceline's activities must be identified in order to properly evaluate how the facility interacts with the environment. Activities that occur at the facility, products produced at the facility, or any services provided by the facility should be noted. Also, any inputs to the facility must be listed. Inputs range from electricity and water to paper and chemicals. For UVa's evaluation, every single input wasn't listed individually. For example, rather than wasting time listing pens, pencils, and staples, an inputs category was created for 'office supplies'. This concentrates the initial focus on the big, important inputs that could significantly impact the environment. This isn't to say pens and pencils can't be part of an EMS, but at a facility as large as UVa, attempting to document every item that is purchased by each facility would be extremely tedious.
    • After the fencline's activities and inputs have been identified, the next step in the process is the identification of the fenceline's aspects. Aspects are any part of a facility's activities that has the ability to interact with the environment. Some examples of aspects include energy consumption, waste creation, water usage, air emissions, the creation of the potential for spills, etc. This list is by no means exhaustive. While some aspects, such as energy consumption and waste creation are universal across all facilities, each facility will likely have some unique aspects to be identified.
    • Upon identification of all of the facility's aspects, the next step is to identify the impacts of the aspects on the environment. In terms of an EMS, an impact is any change in the environment (good or bad) resulting from a facility's environmental aspects. Impacts include depletion of natural resources associated with electricity or fuel usage, the need for landfills to hold waste, the creation of waste water, air pollution caused by emissions, etc. This list is not exhaustive, as each fenceline impacts the environment in different ways.
  • Significance Ranking
    • Once all of the ways the facility impacts the environment have been identified, the EMS Team has to determine which of these impacts are most significant. The point of the EMS is to try to make your facility as environmentally friendly as possible and practical. This is done by determining ways that to reduce the identified impacts. Significance ranking is the relative importance of one impact when compared with another. Clearly, the potential for a large gasoline spill is much more environmentally significiant than the amount of waste created by using office supplies. The focus would be to try to fix any potential ways of spilling gasoline first. Once that problem has been addressed, the issue of trying to reduce the amount of office waste created could be addressed.
    • EMS Teams at UVa rank their significant impacts based on:
      • Severity of impact
      • Scale of impact
      • Frequency of occurrence
      • Worker exposure/safety
      • Implement ability/cost of change
      • Associated legal requirements
    • Significance ranking is extremely arbitrary, so having a well-defined set of ranking criteria is a good way to systematically evaluate impacts. Specifics of UVa's significance ranking criteria can be found here (Word).
  • Documentation
    • Documentation plays two key roles in an EMS. First, an organized system of documentation helps UVa keep track of all of it's environmental recordkeeping requirements. Environmental regulations require that UVa document certain activities related to the environment, submit reports, and keep certain records for a minimum of five years. An EMS documentation system organizes these records in a central location so that they can easily be accessed if an inspector asks to see them. An organized documentation system also helps UVa's Environmental Compliance staff keep track of deadlines for submission of environmentally related reports.
    • Secondly, a well-organized system of documentation ensures that the most recent version of any document is the one utilized by staff. All documents required by the EMS are controlled documents. They are required to have a standard header so they can be easily identified.
    • UVa's standard header includes:
      • UVa's logo
      • title of the document
      • the document number
      • the author of the document
      • who approved the document
      • the revision number of the document
      • the document's issue date
      • document's review date
      • the page number and total number of pages in the document
    • Some departments, such as Housing, already have a standard department header and have chosen to use their existing header on their EMS documents. As long as all EMS documents for the deparment have a standard header, it is acceptable for some departments to deviate from the UVa standard header. Departures from the standard header are considered on a case-by-case basis.
    • The purpose of including the issue and review date on the document is to allow the reader to know whether or not they have the most recent copy of the document. The review date means that the document must be reviewed periodically to ensure it is accurate. Too often important documents, such as emergency response plans, are created and placed in a binder on a shelf in someone's office. It may sit there for years gathering dust until it is needed. By the time it is needed, it is often out of date, changes have been made to the facility, the staff contact information has changed. These issues can create real problems during an emergency. By requiring that all EMS documents are reviewed periodically, UVa can ensure that all of their EMS documents are up-to-date and accurate.
  • Roles and responsibilities
    • As part of the EMS, roles and responsibilities are designated for each fenceline. This designation allows facility staff to take responsibility for the function of the EMS at their facility. The EMS clearly establishes who is in charge of performing activities that could have a significant impact on the environment. This way if a problem occurs related to the activity or a significant impact is discovered, the responsible staff can easily be identified. Often when accidents occur, valuable time is wasted while responders try to determine who is in charge and who the appropriate people to talk to are.
    • Also by designating roles and responsibilities, a chain of command is established to ensure that tasks are completed on time. In large organizations, it is easy for people who are not part of the staff of a particular fenceline to have trouble discerning who reports to whom and who has authority over whom. Within the EMS, the chain of authority is clearly established. If a task is not completed on time, the person's supervisor can be notified and this notification process can be escalated upward until the task is accomplished.
  • Training
    • As part of the EMS all students, faculty, and staff will receive some form of EMS training. Students will be made aware of the EMS, but due to the size of the University, giving thorough EMS Awareness Training to each student would be time-intensive and impractical. Faculty and staff will receive EMS Awareness Training. The EMS Awareness Training will include an introduction to the University's Environmental Policy. Spreading the word about the policy is important because it reminds people that this is an official University policy that show's the University's commitment to the environment. The training also gives a general introduction to what an EMS is, the parts of an EMS, and how to be involved in the EMS. Some people may be more directly involved in or affected by the EMS than others, but everyone plays a role. Without input from a variety of sources and without support from staff at the facility, the EMS can't function effectively.
    • The EMS also provides and opportunity to remind facility staff of other required training they may need to receive. Regulations require that students, faculty, and staff receive spill training, biological training, radiation safety training, confined space entry training, etc., as it relates to their particular job. While the University already has an excellent training program, the EMS provides another mean for the University to stress the importance of this training and ensure that the appropriate people are trained in a timely manner.
  • Nonconformances
    • A nonconformance is a deficiency somewhere in the EMS. As part of the EMS, fenceline staff are expected to report deficiencies. A deficiency does not mean the EMS does not work. Instead, it means an error was made somewhere that needs to be fixed. The nonconformance could be something as simple as not identifying a significant aspect during the implementation process or something as consequential as an accident caused by not following a procedure. Nonconformances can be reported by staff within the University or could be revealed during the course of an EMS audit. Upon identification of a nonconformance, the problem should be fixed as soon as possible to ensure the University stays in compliance.
    • Staff at a facility should immediately notify their supervisor in the event of any observed nonconformance!
  • Audits
    • Periodically audits must be completed on the University's EMS to confirm its appropriateness and accuracy. This means checking to make sure all of the required parts of an EMS are in place at the facility and that EMS procedures are being followed. The audit should identify any nonconformances that haven't previously been noticed by staff members. Noncompliances, instances where the University is not in compliance with applicable regulations, will also be identified. The findings of the audit should indicate whether the EMS was implemented properly and if it is being adequately maintained. The purpose of the audit is not only to notice things that are wrong with the EMS, but also it is a learning tool to make the EMS better.
  • Management Review
    • The purpose of management review is to ensure that the EMS is effective, adequate, and suitable to the University. "Management" does not necessarily mean the highest level of management at the University. At UVa, an EMS Steering Committee was created for the role of management review. The Steering Committee consists of members of the University staff who are knowledgeable about the environmental compliance requirements of the University but who are not involved in the implementation of the EMS. The Steering Committee can then offer unbiased opinions on the current state of the EMS and offer suggestions for improvement.

 

Contact EHS with Environmental Management System related questions or comments at storm-water@virginia.edu.
EHS Environmental Management System website questions or comments should be directed to Jess Wenger at jsw6d@virginia.edu or 982-5540.