While the specific components of an EMS (as defined under the ISO 14001 specification, EMAS Regulation or in a license) may vary, the general structure behind the EMS concept is largely the same. The components of a typical EMS are illustrated in the diagram below.
A typical EMS incorporates the following elements.
- Baseline Environmental Review/Audit
- Environmental Policy
- Environmental Objectives and Targets
- EM Programme
- Implementation and Operation
- Operational Control
- Emergency Preparedness and Response
- Responsibility Allocation
- Awareness and Training
- Check and Review
- Checks and Corrective Action
- Ongoing Review & Improvement
A summary of each of these components is below
Baseline Environmental Review/Audit
At the beginning of an EMS development, a baseline environmental review/audit is normally conducted in order to determine the status of the organisation’s environmental performance. This audit should feature a comprehensive identification and evaluation of all the significant environmental impacts and issues relevant to the organisation’s activities at the site. The size of an audit and time scale for conducting it will largely be determined by the size of the organisation and complexity of the site activities. For EPA licensed sites, the collation of data and completion of the application process is largely similar to conducting a baseline environmental audit.
The issues to be considered in an audit will vary depending on the organisation, its location and the type of activities conducted.
Typical factors normally considered in an environmental audit include the following:
- Compliance with environmental legislative requirements
- Air emissions (sources, composition, quantity, abatement systems, emission points, receiving environment)
- Water emissions (sources, composition, quantity, abatement systems, disposal routes, receiving environment)
- Waste generation, collection and disposal
- Waste management /minimisation practices
- Energy usage and conservation measures
- Storage, handling and containment of hazardous/potentially hazardous substances
- Raw material usage especially for non-renewable resources
- Flora, fauna and landscape
- Surrounding land-use activities
- Environmental sensitivity associated with the site or its location, such as adjacency to a stream or overlying an aquifer
- Previous site uses and any residual contamination
Audits are normally conducted via site surveys, discussions with relevant site personnel and other third parties as relevant. Depending on the site requirements, environmental monitoring of, for example, surface water, groundwater, soil or air may be conducted. The baseline audit should be comprehensively documented as it provides the basis for the development of the remaining EMS components. There are currently three international standards in the ISO 14000 suite (ISO 14010 – 14012), providing guidance on environmental auditing.
Based on the findings of the Baseline Environmental Review/Audit, the environmental improvements necessary should be clear. The next phase is to plan a way forward for ensuring that improvement measures are implemented in a realistic and timely manner. This involves specifying an Environmental Policy, defining objectives and targets and devising an Environmental Management action Programme.
Based on the audit, an environmental policy statement is developed to define the overall environmental aims of the company. This is typically a one-page statement, stating the actual, realistic (not aspirational) environmental aims, committed to by the senior management and signed off by the head of the company.
Environmental Objectives and Targets
Based on the audit, a schedule of objectives and targets is established for a specified time scale, following on from the policy. Initially, the objectives are largely based on environmental legislative requirements, such as the conditions of a license, where these are not already in place. As the aim is to improve environmental performance over time, objectives and targets will be revised and updated over time, in light of license reviews, site requirements etc.
Environmental Management Programme (EM Programme)
Finally, the EM Programme is developed as an action plan for achieving the objectives and targets. It includes information on the means, time-frame and allocation of responsibility necessary to achieve these.
Implementation and Operational control
Practical operational control seeks to oversee site activities, which, if they were not controlled, could have a significant adverse environmental impact. Typical operational control measures include
- Operation of site-related technology in line with relevant license requirements or best practice
- Development and use of operational procedures for operations, monitoring and so on
- Implementation of environmental monitoring programmes as defined in relevant licenses or in line with best practice.
Emergency planning and response
As environmental impacts can occur as the result of an emergency situation at an industrial facility (e.g. spillage of a hazardous substance, fire generating contaminated fire water or explosion releasing a toxic gas), these potential scenarios are identified and appropriate control measures are put in place to limit and mitigate the likely environmental impacts.
Within the EMS, the role of an Environmental Manager/Officer for the site is allocated. This person champions the EMS development and takes responsibility for the day-to-day running of the EMS once implemented. Specific requirements for site management and staff as required under the license would be incorporated in this section of the EMS.
Awareness and Training
Procedures for identifying the environmental training needs of personnel and providing training as relevant are put in place.
A programme is developed to ensure appropriate internal and external communications regarding environmental issues relevant to the site. This incorporates all relevant stakeholders and should ensure appropriate access to information on the organisation’s environmental performance is made available. Typically, the Environmental Policy Statement is used to disseminate information to the public on the company environmental aims. Dependant on license requirements, a variety of environmental performance data, such as environmental monitoring data, records and annual environmental reports are made available to the Regulatory Authority and are in the public domain. It is increasingly common for companies to include environmental performance information in Annual Reports, provide specific Annual Environmental Reports and include environmental information on their websites.
Checks and corrective action
Checks are normally conducted on an on going basis to ensure that the EMS is operating effectively and to ensure corrective action is taken if EMS elements are not appropriately implemented.
Review and improve
Inherent in the EMS concept is the requirement for on-going assessment of operations with a view to improving environmental performance over time. Once the EMS is operational, reviews are conducted at a suitable frequency in order to ensure the on going suitability and effectiveness of the EMS. After the review process, the Policy Statement, Schedule of Objectives and targets, EM programme and other aspects of the EMS may need to be updated. This review will not normally be as comprehensive as the baseline environmental review, but many of the same issues will be considered.
To facilitate implementation, the essential elements of the EMS are documented in electronic or paper-based format. This may be in the form of an Environmental Management Manual and as part of the existing site operational documentation. As resource conservation is likely to be a key aim in an EMS, the documentation should not be highly paper intensive.
Records and reporting
Within the EMS documentation, a records and reporting system, typically based on regulatory authority requirements, is developed. Examples of such records and reports include
- Records of all environmental monitoring
- Records of the waste generated and associated disposal and/or recycling routes
- Relevant licenses and/permits for waste contractors used
- Records of environmental audits and reviews
- Environmental performance reports.