Environmental Management Systems
Deuth suggests any company pursuing the development of an EMS should begin with a “gap analysis,” which takes an organization through all of its environmental systems to see what systems are already in place and where there may be holes.
If a company already has some specific environmental requirements, such as a visible emissions test procedure, there may already be a system in place to keep track of test results. This procedure would be evaluated to determine whether it is sufficient or needs to be changed and how this existing process can be worked into an overall EMS program.
“The gap analysis lets a company know where it stands among the confines of an environmental management system and the ISO 14001 standards as it begins development of its system,” Deuth says. Each NSSGA module includes a basic outline of a system template and includes four sections, which lead an organization through setting up requirements for each specific topic and the benchmarks required, depending on the level of EMS that is being chosen.
“It gives a set-up and an example of how someone might approach development of that module template, but there are several different ways it could be implemented,” Deuth says. “Every facility is different and finds things of higher and lower importance.” For example, if neighbors often complain about dust, this area may be a higher concern for a facility where this occurs. “As part of the Aspects and Impacts module, facilities will evaluate and rank each risk area based on importance,” Deuth explains. How to benchmark and measure the success of compliance is a subjective system. “The template directs the user to decide how to measure objectives and targets developed for each aspect and impact,” she says. “It might be as simple as having someone go out and drive the property boundaries on a weekly basis to see if there are issues with dust outside of the property boundary and then logging it.”
For noise complaints, benchmarks could include setting an acceptable level and then going out in the facility with a noise monitor and logging each complaint received. “You could establish a way for neighbors to let you know when noise is a problem, or you could also come up with some creative way to monitor noise,” Deuth says. “The beauty of the system is that it’s customizable and allows you to make your own decision based on what is appropriate for your particular company or facility.”
Making it your own
When developing the EMS templates and instruction documents for NSSGA, Trinity worked with a group of the association’s members to develop modules and instructions that were relevant to producer operations. The template was created to provide NSSGA members with a written framework that can be used in sections or in its entirety to develop a voluntary EMS program, Deuth says. Although the template is based on an Environmental Protection Agency (EPA) model and on the internationally recognized ISO 14001 environmental management systems, she says, the template is in the form of modules to allow producers to choose individual modules and adapt them to best fit their company’s needs and stated environmental goals and principles.
“The templates can be used by themselves or in combination with other procedures and systems that facilities may already have in place,” Deuth says. “It can be manipulated to correspond to company needs or used as a reference for a company that wants to develop their own format of an EMS.”
The template is a tool that companies can use to develop and implement an EMS, Deuth says. However, there are several implementation options and 14 modules that may be used. The original NSSGA EMS template contained 13 modules, but it was updated in 2005 to conform to the updated ISO 14001 standards to include an additional compliance module. “If a facility does not have many procedures in place, [it] may decide to use all of the modules in the template to make a complete EMS,” Deuth says. “If all of the EMS elements are not needed, a facility may use only a few modules from the template. They may use the modules to fill gaps in an environmental system that is already in place.”
Modules may also be combined or separated depending on the needs of the company. Additionally, the template, which was originally developed in 2003, can be used as a starting point to meet ISO 14001 standards. The NSSGA EMS template was comprised of the following 14 key elements, based on the Plan-Do-Check-Act model:
• Gap Analysis;
• Environmental Policy;
• Environmental Aspects;
• Legal and Other Requirements;
• Objectives and Targets;
• Structure and Responsibility;
• Training, Awareness, and Competence;
• EMS Documentation;
• Document and Record Control;
• Operational Control and Monitoring;
• Emergency Preparedness and Response, EMS Audit, and Management Review; and
• Compliance Evaluation.
The template contains a module in Word document format so it can be customized, along with a set of detailed instructions for each of the 14 key elements. The instructions describe what is required for each template procedure and give example approaches, Deuth says. Each module corresponds to one or more of the EMS requirements in the ISO 14001 standard so that the template can be used as an aid toward ISO 14001 certification. A modular format allows organizations to choose an implementation path that fits its current needs with potential implementation options such as selecting a few modules to begin an EMS; choosing modules to fill gaps in the current EMS; developing an EMS using all 14 modules; and using the NSSGA template as a starting point to meeting the ISO 14001 Standard.
“Each module provides an instruction document that includes example approaches to develop the EMS,” Deuth says. “However, it is up to the facility to determine what benchmarks they will utilize within their own program.”
A company that implemented an EMS during a four-year period (during which its production increased by 20 percent) showed a 38-percent decrease in waste, a 28-percent decrease in recycled waste, and a 9-percent decrease in electricity usage, according to the former Blue Circle Industries.
“Environmental Management Systems can aid the aggregate industry by improving environmental programs that are already in place and improving environmental performance at facilities that lack a developed environmental program,” Deuth says. “Facilities that implement an EMS may see benefits such as improved environmental performance, improved compliance, reduced liability, reduced wastes, improved employee awareness of environmental responsibilities, an improved public image, and a competitive advantage. Facilities with an EMS may also qualify for recognition and incentive programs or, ultimately, get their program certified as ISO 14001 compliant.”
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