WINTER 2000     Inside: • Mould Litigation and Due Diligence • So What is an EMS? • Ergonomics at Work SO WHAT IS AN ENVIRONMENTAL MANAGEMENT SYSTEM (EMS)? Brodie Anderson, M.E.Des.     You, your customers, neighbors and the people concerned about protecting your interests (your insurers, regulators, investors, etc.) are affected by your companies operations.     In the event of a spill or accident, they will require a statement of the actions your company is prepared to take to safeguard their interests. An Environmental Management System effectively provides the concerned parties with this diligence statement.    An EMS will explain the measures to take to ensure that the health of your workers and the 'health' of the physical environment surrounding your operations meet acceptable standards. AN ENVIRONMENTAL MANAGEMENT SYSTEM     EMS components should prescribe the standards and procedures required to ensure a company's processes and activities that impact the environment are conducted in the intended manner.     An effective EMS integrates a firm's business practices with expected industry standards.     To accommodate annual operational reviews (e.g. budgeting) and to ease external party or investor relations, a company typically prepares and publishes a fully integrated business plan EMS.     Many EMS programs are based on a blend of elements found in international certification systems, industry codes of practice, and specific performance protocols employed in environmental audit systems. EMS – Improving environmental compliance.>>> The salient characteristics common to most include: A Corporate Environmental Policy Commitment Explicit recognition of Environmental Conditions Environmental Performance Targets and Objectives EMS Establishment Procedures Environmental Management Action Plan(s) Environmental Performance Reviews EMS DEVELOPMENT     Intensive development of a standard Environmental Management System (EMS) began during the early 1980's. Business interests attending the Uruguay Round of GATT, who supported the removal of any non-tariff trade barrier, were concerned over the proliferation of inconsistent national and regional EMS standards.     Their agreement with delegates interested in international commitment to environmental protection (the 1992 Rio Conference on the Environment) led to what many hoped would become a single global environmental management system. Their intention was to create uniform and effective environmental management measures that safeguard against negative trade and commerce impacts. CERTIFICATION OF ENVIRONMENTAL MANAGEMENT SYSTEMS     An international ISO 14000 series emerged, covering over 20 separate but related environmental standards – a voluntary program serving to accentuate internal quality policies, manage marketplace expectations and implement an overall strategic environmental quality program.     Although many companies and national regulators wanted ISO 14000 to become "the" industry standard, this system was not designed to supplant any government regulatory requirements nor require conformance to any environmental performance level – other than company commitment to comply with applicable legislation and regulations.     Several countries had their own environmental standard certification systems. The British Standard Institute's (BSI) BS 7750 and the European Union's Eco-Management and Auditing Scheme (EMAS) were two of the first EMS model systems.     Several American systems (American National Standards Institute – ANSI – or those of the Environmental Protection Agency) and the Canadian Standards Association (CSA) environmental system also provide national templates. But no single system is necessarily correct in all aspects for all applications. INDUSTRY CODES OF PRACTICE     Many industrial codes of practice, such as the CERES principles (Coalition for Environ-mentally Responsible Economies),World Business Council on Environment programs (WBCSD) or the International Chamber of Commerce (ICC) Business Charter Guidelines also provide valuable benchmark characteristics.     Several environmental labeling programs also provide further EMS protocol templates. Agreements with public authorities and non-regulatory guidelines also contribute valuable characteristics. ENVIRONMENTAL AUDIT PROTOCOLS     Environmental auditing systems, similar in scope to environmental management certification systems, also provide reference material for the design of an effective EMS. Audit protocols used by the DNV (Det Norske Veritas) – International Environmental Rating System (IERS) system or the European Union Eco-Management and Audit Scheme (EMAS) provide a test of a company's EMS effectiveness and industry conformance. A CORPORATE CONTENT – ENVIRONMENTAL POLICY STATEMENTS     An EMS ideally reflects the company's corporate policy framework and culture. It provides a level of corporate commitment as well as guideline statements to support those initiatives.     The statement commits to environmental protection, compliance with regulations, continuous environmental performance improvement and open communication of performance.     Environmental Policy typically addresses the underlying rationale for environmental initiatives, commitment to resolving main environmental issues. It describes responsibility for environmental policy and Board of Director sanctions. ENVIRONMENTAL PERFORMANCE OBJECTIVES AND TARGETS     Environmental targets usually address broad environmental issues (e.g. energy conservation). Objectives establish specific solution or activity endpoints – i.e. measurable environmental impacts (e.g. solid waste reduction). Both are typically determined in the annual planning cycle.     Operational targets and objectives define the direction and magnitude of environmental attention. They also provide a basis for measuring improvement in performance.     Targets and objectives must meet appropriate criteria. They must be measurable, concrete, attainable, and affordable, as well as clearly defining required authorities. They frequently contribute to sustainable corporate management initiatives. ESTABLISHMENT OF AN EMS     Establishing the EMS requires executive leadership with sufficient responsibility and authority to champion consistent delivery. This leader constantly monitors Health/Hygiene Controls, Environmental Protection and Emergency Preparedness. S/he evaluates achievement of targets and objectives and ensures insurance coverage.     System implementations typically include permit verification, monitoring review, safety evaluation and overall site assessment. EMS performance is reported to Sr. Management, usually involving a review of work instructions, monitoring or control procedures and the verification of compliance.     Environmental performance frequently includes review of waste management, emergency preparedness, issue management and community relations, ordinarily supported by training and awareness programs. ENVIRONMENTAL MANAGEMENT ACTION PLAN(S)     Action planning is central to the entire system. Plans explain a company's environmental challenges, its areas of greatest environmental exposure and the actions required to implement environmental targets and objectives. This places company policies and operating procedures into the intended context.     Detailed operating procedures (e.g. data collection, reporting, tracking, monitoring, recording, inspection, maintenance, calibration, and contractor/supplier requirements) support protocol implementation. This data also supports environmental performance improvement, regulator contact, training, and the preparation of necessary environmental financial plans. IMPLEMENTING CONTINUOUS DUE DILIGENCE ACTIVITY – ENVIRONMENTAL PERFORMANCE REVIEW     Continued environmental performance improvement is achieved through preventing recurrence, evaluating established performance indicators and consistent integration of environmental impact analysis within the annual capital planning exercise.     Evaluation compares actual performance against established objectives, reviewing suitability of environmental statements, environmental priorities, operational procedures and work guidelines. Many organizations have evolved these environmental performance reviews into formal environmental audit procedures.