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Companies are confronted with environmental issues on a daily basis. Many of these issues are difficult to address, particularly for smaller companies with limited technical, legal, and personnel resources. All companies, however, regardless of size could benefit greatly from a sound system for tracking and managing their environmental responsibilities. In order to be effective, the system must promote environmentally sound operations and provide you with peace of mind when meeting your environmental responsibilities. The information and references in this chapter will assist you in understanding:
Environmental Management Systems Understanding and complying with environmental regulations can be a challenge for any company, regardless of the size of the company or availability of an environmental staff. A comprehensive Environmental Management System ("EMS") is essential for effectively and efficiently addressing all the company’s environmental matters. The key to achieving an environmentally sound operation is to closely adhere to an established, efficient, and cost-effective environmental management system. The information in this chapter describes the important principles of such a system - ISO 14001. ISO 14001 guidance is an EMS framework that is recognized worldwide as a standard for environmental management effectiveness, and it is a system that can help any company achieve sound environmental operations. The structure of an ISO 14001 EMS is derived from the Plan-Do-Check-Act ("PDCA") continuous improvement cycle, also referred to as the Deming cycle. The PDCA cycle is a method that aids management in the pursuit of continuous and never-ending process improvement. With continuous improvement as its backbone, an ISO 14001 EMS is structured and well-suited to assist companies in improving their management of environmental matters. Refer to Figure 1.1 to gain a better theoretical understanding of the relationship between the PDCA cycle and the principles and elements of an ISO 14001 environmental management system. The information in this figure can also help you to better understand how process tools, such as the problem solving process, and pollution prevention process are derived from the same PDCA cycle. Thus, understanding the PDCA cycle is key not only in developing and instituting a useful management system, but also in utilizing helpful process tools.
ISO 14001 Environmental Management System Framework The ISO 14001 EMS framework is anchored by five guiding principles for achieving your company's environmental and economic goals. The principles, which reflect the PDCA cycle, are:
Each principle has several elements, and these elements can help you to address the requirements of a specific principle. The following are brief narratives that explain each of the elements of the ISO 14001 principles. Note: You can gain a copy of the ISO 14001 Standard by contacting ANSI. ANSI can also help you find resources needed for ISO 14001 third-party audits, certification, and training. Environmental Policy One of the most important elements of the environmental policy is top management involvement. Top management needs to be proactive and deeply involved in drafting an environmental policy that:
Once the environmental policy is in place, a company must plan for system development and the changes that inevitably follow. This is accomplished through the Planning principle of the EMS. Planning The Planning principle of the ISO 14001 system corresponds to the Plan of the PDCA cycle. It is within this principle that a company actually plans a strategy for change. Companies that choose to follow the structure of the ISO 14001 system must establish and maintain:
In short, this principle lays a foundation for future ISO 14001 principles by identifying a company's environmental aspects, determining if there are legal or other requirements attached to the aspects, establishing objectives and targets to meet these requirements, and establishing a program (this EMS) for achieving those objectives and targets. As you have read, the Planning principle places an emphasis on meeting your regulatory requirements, which should be a high priority for every company. With EMS Planning complete, you need to determine how the plans will be implemented and how they affect your operations. This may be accomplished through the elements of the Implementation and Operation principle. Implementation and Operation The Implementation and Operation principle of the ISO 14001 system corresponds to the Do of the PDCA cycle. The elements of this principle will help your company implement your EMS plans. To implement the plans, your company should:
This principle, in essence, allows a company to move forward and carry out its EMS plans by establishing and maintaining procedures that need to be followed by all company personnel. Adherence to these procedures will help ensure that the environmental policy, objectives, and targets are being met. Now that you have put most of the EMS in place, you will need to check and make sure the system does what you intend it to do. This can be accomplished through the elements of the Checking and Corrective Action principle. Checking and Corrective Action The Checking and Corrective Action principle of the ISO 14001 system corresponds to the Check of the PDCA cycle. The elements of this principle will help your company:
An important point to understand in this principle is that conformance / non-conformance deals strictly with how well your EMS adheres to the ISO 14001 Standard. This is only an issue if your facility is, or soon will be, a Certified ISO 14000 facility. Many companies follow the ISO 14001 framework without ever planning for certification. Thus, they are not actually required to address non-conformances, although it is a good idea that they do because in signals a breakdown of the EMS. Another important point for Ohio companies deals with self-audits. In 1996, Ohio enacted a law (ORC §3745.70 through §3745.73) that offers protection to companies that self-disclose violations (or potential violations) of environmental rules and/or regulations and make a "good faith" effort to come into compliance. If companies discover potential violations through the audit function of an EMS, it is possible to obtain immunity from civil and administrative penalties if they follow specific procedures and the company takes steps to "achieve compliance as quickly as practicable." The information contained in the self-audits may also be entitled to a privilege from discovery or admission as evidence in the context of civil, criminal, and administrative environmental proceedings. To obtain the "immunity" and "privilege," companies must follow a series of steps outlined in the law, including:
Any chemical company that suspects the need to use this environmental audit protection should seek competent legal advice. Fortunately, the legislature was very clear about its intent; if you discover your own violation and intend to make a reasonable effort to correct the problem, you should be protected from additional penalties. This Checking and Corrective Action principle completes the bulk of the substantive requirements of your EMS. The final ISO 14001 Standard requirement is to establish a top management review process of the EMS. Management Review The Management Review principle of the ISO 14001 system corresponds to the Act of the PDCA cycle. Management review is essential to ensure your company's top management periodically reviews the EMS for continuing suitability, adequacy, and effectiveness. The burden falls on top management to recommend changes to the EMS in light of audit results or changing circumstances. You should understand that the ISO 14001 Standard is not regulated by local, state, or federal agencies. Following the Standard is strictly voluntary. ISO 14001 is merely a framework for companies to use in designing and implementing an effective environmental management system. Further, EnviroChem Ohio neither promotes nor disparages actual ISO 14001 Certification. EnviroChem Ohio does, however, strongly suggest that your company's EMS include much of the principles and elements of the ISO 14001 Standard.
ISO 14001 and EnviroChem Ohio EnviroChem Ohio does not, by itself, meet all the requirements of ISO 14001. However, many EnviroChem Ohio chapters do relate to several of the Standard requirements. Refer to the matrix shown in Figure 1-2 to identify which ISO 14001 principles and elements are, at least in part, addressed by EnviroChem Ohio.
EnviroChem Ohio Chapter Layout As you read through Chapters 3-6 you will notice that they have a similar chapter layout. The layout follows a methodology that simplifies the process of determining and managing environmental regulatory compliance. The following process depicts this methodology:
Conducting a survey or inventory of your facility is the first step in determining your regulatory responsibilities. It is during this step that you can determine your facility's emissions, waste streams, and usage of water and chemicals. With this data and information in hand, it will be much easier for you to determine if you need any permits. Determining permit applicability is crucial in determining your regulatory status. In many instances, most of your regulatory requirements will be borne out of permits dealing with air, hazardous waste, or water issues. Additional regulatory requirements will need to be addressed if you determine that permits are required. The permits will normally state your specific reporting, recordkeeping, and notification requirements. Even if you do not need permits, your operations may still require reporting, recordkeeping, or notification. Such is the case with hazardous chemicals and substances under SARA Title III ("EPCRA"). The final part of each chapter is a section that lists additional information sources. Much of the information in this Guide was derived from these sources. You should exhaust these specific resources if you require more information dealing with the corresponding chapter. This basic process is followed closely in Chapters 3 through 6. Understanding this process, and thus the chapter layouts, should help you be more efficient when searching for and utilizing information in each of the chapters.
Getting the Most Out of EnviroChem Ohio EnviroChem Ohio is structured in a way that can readily meet the needs of any user. If your facility is serious about developing an EMS, we recommend that you follow the ISO 14001 Standard or retain experienced services, or both. Chapter 1 alone does not give you enough information to develop and implement an EMS without additional assistance. Chapter 2 outlines the theory and practical nature of Pollution Prevention. In reading Chapter 2, you will again see a reflection of the PDCA continuous improvement cycle (see Figure 1-1). As explained in the preceding section, Chapters 3-6 follow the same format. Knowing and understanding this format, you can quickly and easily find the information you need without wasting time searching through unneeded information.
How to Maximize the Effectiveness of EnviroChem Ohio You should first read through this entire guide to get a feel for its format. Once you have read through EnviroChem Ohio, go back to the chapters that that you feel you need the most help, and begin working through the process outlined in each of the chapters. To get started with EnviroChem Ohio you should:
Keep in mind, it is your responsibility to work through all the process diagrams included in EnviroChem Ohio's chapters. Once you have addressed and completed all that is asked of you in all of the chapters, your facility will be well on its way to becoming an environmentally sound operation.
Sources of Additional Information Technical Assistance Ohio Chemistry Technology Council TechSolve, Inc. (formerly the Institute for Advanced Manufacturing Sciences
(IAMS)) Cleveland Advanced Manufacturing Program (CAMP) Edison Industrial Systems Center (EISC) Other Internet References: |
