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. Longwood'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.
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 Longwood, we decided to start off with the Physical Plant. Once an EMS is established for the Physical Plant then we will expand the fenceline to encompass all of campus.
Current Longwood Environmental Management System Fenceline:
The fenceline for the EMS is defined as the Heating Plant and steam tunnels extending to the building pressure reducing valves; sawdust storage; sawdust transportation; Physical Plant operations including plumbing, HVAC, electrical, carpentry, key shop, paint shop, motor pool, and stockroom; and Landscaping and Grounds Management.
The creation of a strong EMS Steering Committee is important to having a strong EMS. The EMS Steering Committee includes as many people as necessary to cover a wide array of perspectives so that nothing is overlooked, but not so many that the team becomes excessively large. The Committee plays a vital role in determining aspects, impacts, and significance ranking. They also monitor the daily functioning of the EMS at their facility. Therefore, the team's active input and involvement is critical.
Longwood's EMS Steering Committee is comprised of:
- Dick Bratcher, Senior Management Representative
- Melissa Pelletier, EMS Management Representative and Team Leader
- Ben Myers, Task Force Liaison
- Ray Heinrich, Task Force Liaison
- Ken Copeland, Internal Auditor
- Jerry Jerome
- Kelly Martin
- Tracey Neihouse
- Louise Waller
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 within the designated fenceline at the facility, products produced within the fenceline at the facility, or any services provided by the facility that are relevant to the designated fenceline should be noted.
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 have 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. 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 key characteristics related to that aspect as well as potential impacts 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. This list is not exhaustive, as each fenceline impacts the environment in different ways.
Once all the ways a facility impacts the environment have been identified, the EMS Steering Committee 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 while remaining practical. This is done by determining ways to mitigate any negative qualities associated with the identified aspects and their key characteristics. Significance ranking is the relative importance of one aspect and/ or key characteristic as compared with another. As an example not necessarily specific to Longwood's current EMS fenceline, the potential for a large gasoline spill is much more environmentally significant 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.
Significance ranking is extremely arbitrary, so having a well-defined set of ranking criteria is a good way to systematically evaluate impacts.
Documentation plays two key roles in an EMS. First, an organized system of documentation helps Longwood keep track of all of its environmental recordkeeping requirements. Environmental regulations require that Longwood document and maintain certain records and documents pertaining to certain activities related to the environment, submit reports, and keep certain records for a minimum of three years. An EMS documentation system organizes these records in a central location so they can easily be accessed anyone at all, from an auditor to an interested citizen, need or ask to see them.
Second, a well-organized system of documentation ensures that the most recent version of any document is the one being utilized. All documents required by the EMS are controlled documents. They are required to have a standard header so they can be easily identified.
Longwood's standard header includes:
- Longwood University
- Title of the document
- The document number
- The originator of the document
- Who approved the document
- The revision number of the document
- The document's issue date
- The document's review date
- 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: for instance, changes may have been made to the facility, or the staff contact information may have changed. These issues can create real problems during an emergency. By requiring that all EMS documents are reviewed periodically, Longwood can ensure that all of their EMS documents are up-to-date and accurate.
As part of the EMS, roles and responsibilities are designated for each fenceline. This designation allows relevant 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 personnel 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.
A nonconformance is a deficiency somewhere in the EMS Fenceline. As part of the EMS, fenceline staff are expected to report deficiencies and staff at a facility should immediately notify their supervisor in the event of any observed nonconformance.
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 concerned citizens, fenceline personnel, other 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.
Periodically, EMS and Compliance audits must be completed to confirm the appropriateness and accuracy or the EMS as well as the compliant status of the facility. 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 while adhering to compliance regulations. 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 EMS audit should indicate whether the EMS was implemented properly and if it is being adequately maintained. The purpose of the EMS 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.
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.