The investment of time and resources can produce a worthwhile environmental program with long-standing benefits for waste management organizations.

By Steven G. Rowley

The systematic management of an organization's quality, environmental, health, and safety risks is a trend that is gaining momentum in a variety of industries, including waste management. Across the country, there are many waste management organizations that are contemplating the implementation of an environmental management system (EMS), are implementing an EMS, or have just completed the process in recent years. There are numerous considerations that an organization needs to be aware of as it plans the resources necessary to develop, implement, and maintain an EMS.

It is true—some organizations may already have many practices and procedures in place that address the requirements of ISO 14001. Often a gap analysis will be conducted to determine which current practices address ISO 14001 requirements and those that need to be established. The gap analysis may conclude that the system is nearly in place and will only require minor modifications to bring it into conformance with the standard. However, this is seldom the case for organizations that have modeled their systems after ISO 14001 or the plan-do-check-improve model on which the standard is based. This false sense of comfort can result in underestimating the internal and external resources needed to implement an EMS and the time frame required to effectively develop and implement the system. Thankfully, attaining ISO 14001 certification is not a rubber-stamp process; otherwise it would have no value.

Most gap analyses fail to evaluate the degree to which programs and procedures have been implemented and the time and resources required to “fix” the failed programs and procedures that will be incorporated, wholly or in part, into the EMS. In most cases, it is better to not have a system in place than to have a poorly implemented one. The latter scenario is more difficult to address because it entails addressing cultural issues that might have developed over a period of time.

Gannett Fleming, an international consulting engineering and construction management firm, is experienced in implementing EMS systems for a variety of companies. In some cases, the organization's top management is stunned to learn the state of its existing systems relative to its expectations. Oftentimes, it is discovered that programs and procedures are outdated and inconsistent with the actual work practices, emergency plans contain call lists with names of employees who have long since left the company, regulations and permit requirements applicable to the organization are overlooked resulting in noncompliance conditions, and product specifications are not consistent with customer requirements in many cases.

What to Do

Spend extra time evaluating the existing management system in order to more accurately evaluate the implementation effort. Consider having a qualified consultant conduct a gap analysis and prepare a detailed cost estimate, which identifies both the internal and external resources necessary to implement the system. The gap analysis must address more than where a “gap” exists; it must also identify what level of effort will be required to fill the gap. It must give full consideration to the organization's available resources and implementation schedule.

Don't forget the implementation part, as many do. A nearly equivalent amount of time is required to implement the EMS as is required for its development. In order for an EMS to be recommended for certification, the organization must be able to demonstrate that it has been implemented through a presentation of records and other objective evidence. Many registrars have specified a minimum time frame that the system must be implemented in prior to conducting a certification audit. It is most commonly three to six months.

In nearly all implementation projects, there are certain areas that commonly require more effort than others: document control, operational control, and auditing. It is critical that adequate resources have been allocated to address these areas.

Document Control

This is an area that is deficient in most organizations prior to implementing the EMS. Some common problems include the existence of multiple revisions of procedures and policies; not knowing the locations to which procedures have been distributed; procedures having been prepared in numerous formats; forms not being controlled and in many cases not providing for collecting the necessary information; and procedures not being periodically reviewed to ensure that they are current and accurate.

Controlling EMS documentation can be a challenging and time-consuming requirement of the standard. Accordingly, limiting the amount of hard-copy documentation in circulation and employing a system of electronically controlled documentation can facilitate document control. If possible, making documentation available to work activities through an intranet or shared drive in a read-only format with limited access for editing is recommended. However, many organizations, including waste management facilities, do not have the means to access electronic documentation in all areas where it is needed. It is acceptable to maintain hard copies of EMS documentation in various locations as long as provisions for document control have been implemented. Creating a spreadsheet that describes the documentation, its locations, and a document owner responsible for its periodic review/update is an effective practice.

Operational Control

Operational controls are those documented procedures required to address the organization's significant environmental aspects. In most cases, these procedures exist yet are not documented. Documenting the procedures establishes consistency in work practices and ensures consistency in training new employees.

The process of documenting the necessary procedures can be time-consuming and is best accomplished with the assistance of an outside party using the input of those involved in the work practice and comparing the procedure to regulatory and/or operational requirements. This effort requires preparing draft procedures for review and comment prior to their finalization. Particularly at a waste management facility, which has many operational requirements, documentation is one of the more time-consuming efforts in the implementation process. The rule of thumb here is to estimate on the high side when calculating the time required for this task. Multiple drafts and reviews may be necessary to ensure that procedures are accurate and consistent with the management system requirements.

Auditing

Prior to certification, an organization will need to demonstrate that it has audited its entire EMS. This will require auditing all elements of the EMS and all activities within the project scope. Audits can be time-consuming; however, they are vital to the ongoing maintenance of the EMS and serve as the basis for continual improvement. Don't put the audits off or deemphasize their importance.

A registrar will pay particular attention to this area of your EMS, ensuring that audits are being conducted by appropriately qualified personnel in accordance with an established program. Audits are typically performed by facility personnel and/or others from within the organization with outside assistance, as needed. Qualifications are established through any variety of criteria established by the organization. Onsite audit training, which covers basic audit techniques, is recommended. This is based on the organization's EMS and includes conducting actual audits of the EMS as part of the training.

The standard also requires that periodic compliance audits be conducted as a means to monitor the organization's performance against applicable legal requirements. A compliance audit will require less time and planning than an EMS audit, but it will have associated costs, whether conducted internally or by an outside, contracted party. This is a requirement that is often overlooked, requiring last-minute planning to address this element. Understanding this requirement in advance will help in the planning process.

One important task in preparing to implement an EMS is the preparation of a detailed implementation plan and schedule. Take the time to develop an implementation plan, which is as detailed as possible and includes specific responsibilities and time frames for task completion. And most importantly, hold each other accountable to the schedule. Once you begin extending time frames, you are going to impact the overall implementation project. Developing and implementing an EMS is unique in the sense that you can't make up lost time by condensing a task into a shorter time frame. One reason is that the process requires the involvement of numerous personnel, who will need to adjust their schedules to account for such scheduling changes. Secondly, and as previously mentioned, implementation takes a certain amount time and cannot be reduced to expedite the process. There are various ways to keep an implementation schedule on track:

• Use a team approach—the team should meet at established times to steer the process and ensure that the implementation stays on track.
• Meet with top management frequently throughout the implementation process to report on the progress of the project.
• Schedule firm dates for the completion of the certification audits—these audits are completed in two parts, a document review and an implementation assessment, typically scheduled two to three months apart. There is no greater motivation than putting the audit dates on a calendar and preparing for those dates. This may be the single best assurance for maintaining a project schedule.

Once you have implemented your EMS, you are not finished; as a matter of fact, you just crossed the starting line. You have established a new way of managing your environmental affairs, which will have far-reaching effects throughout the entire organization. In time, managing the EMS will not and should not be a secondary or ancillary consideration but the norm for managing your operations. In order to maintain the EMS over the long-term, resources need to be allocated both internally (auditing, meetings, data management, and improvement projects) and externally (auditing, registration maintenance, and consulting). Accordingly, annual budget setting needs to account for environmental management needs, which may go beyond the normal environmental planning inherent to the solid-waste industry.

In closing, EMS implementation is a worthwhile investment; however, it is one that requires careful resource planning to ensure that the process is positive and productive. The main steps are to conduct a gap analysis, understand the elements of the ISO 14001 standard and the related requirements, maintain a project schedule, and realize the process is ongoing.

Steven G. Rowley is project manager with Gannett Fleming Inc. in Valley Forge, PA.

MSW - September/October 2004