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The Big E’s:

Which One’s Right for the Environment–
Environmental Management Systems, Assessments, Reviews, or Results Programs?*

*Answer: They All Are.

by Helen Waldorf

Business leaders today have to watch their P’s and Q’s where the Big E is concerned: the Environment. Helen Waldorf of the Massachusetts Department of Environmental Protection describes the many environmental programs available that help achieve compliance with regulations, including a draft Guide to Environmental Management Assessment from ASTM Committee E50 on Environmental Assessment.

The Battle of the Ecronyms: EMS, EMA, EPA, and ERP

Some of the more popular topics for discussion about the environment are the various “ecronyms,” acronyms that represent systematic, organizational, self-evaluation programs. These systems all help move a company or facility toward reduced negative impacts on the environment and ensure continued compliance with legal requirements and community standards. To understand this new trend it may be useful to compare and contrast 1) ISO 14001 Environmental Management Systems, 2) a new guide under development in ASTM Committee E50 on Environmental Assessment called Environmental Management Assessment, 3) Environmental Protection Agency and Federal Facility programs and 4) the Massachusetts Environmental Results Program.

EMS: Environmental Management Systems and ISO 14001

The International Organization for Standardization’s (ISO’s) international advantage, sophistication, scale, and marketplace recognition basically can’t be beaten on the EMS landscape. Many U.S. state and federal regulators recognize ISO’s standard as the most complete and thorough, if not the only, framework for an EMS. International trade may require organizations to be ISO certified, and some large corporations, such as auto-makers, require it of their vendors. Why is this? From a dramatic business standpoint, no CEO wants to be faced with a “Bhopal” or “Valdez” incident—the loss of life, damage to the environment and business delivery interruption, not to mention the money damages and poor public image. Simply put, ISO-flavored EMS, especially in large or complex organizations, works because it reduces fear. You will hear many presentations on EMS, and ISO in particular, begin with “I sleep better at night because we have an EMS!”

Why does EMS help managers sleep? Why does it work? Part of the answer lies in its use of human interaction. An EMS requires awareness and accountability from all persons in an organization and, from board room to boiler room, each individual has a role in managing and reducing impacts on the environment. Many organizations believe that most of their employees would literally stand in line to participate in protecting the environment. EMS is similar to community crime prevention. There will always be crime in the city and the need to arrest and prosecute criminals. But the police have also found that prevention programs, where everybody in the neighborhood gets involved, has a phenomenal effect on the reduction of the crime rate. Just ask New York City! In similar fashion, an EMS identifies and prevents pollution and reduces the risk of noncompliance in the future.

While a full-blown ISO 14000 analysis may take up to 18 months, depending on the size or complexity of the organization, the value of the analysis is unmistakable. Even simple changes in the organization’s operations can make huge differences in reducing the environmental footprint. For example, the Massachusetts Department of Environmental Protection’s Wall Experiment Station does thousands of analyses of soil and water samples each year. During its environmental improvement program, the laboratory discovered a simple but elegant fact. If they systematically reduced sample size coming into the lab, hazardous waste production went down dramatically. This was true even though the staff’s improved work management found and collected even the tiniest waste streams in the laboratory processes. The Wall Experiment Station uses the ISO EMS model and participates in EPA’s pilot EMS program to achieve these and other benefits. Click here for a more complete and entertaining introduction to ISO’s quality and EMS standards. For a review of EMS pilot projects click here. Or see the National Sanitation Foundation Guide, Second Edition, or the Wisconsin Department of Natural Resources’ new EMS Web site.

EMA: Environmental Management Assessment—Streamlined Compliance Priority Approach

This ASTM guide, now under development in Committee E50, may be a good first step for small businesses or others just getting started. The controversy may lie with those who say “We don’t need another standard, we have ISO.” There are several reasons why a new ASTM guide will be a good, useful tool to have around on the “Big E” landscape.

How will the Environmental Management Assessment (EMA) Guide be different from other “Big E’s”? The first item is its emphasis on environmental compliance in the United States. Furthermore, the guide contains a simple but unique priority system, based primarily on federal and state enforcement programs. It uses commonly agreed upon priority systems of setting base penalties for noncompliance, and then groups these general requirements into three tiers for iterative compliance evaluation. It reverses the penalty equation into a compliance equation. For example, actual, unpermitted releases of hazardous materials almost always show the highest penalties in enforcement cases. This is because many regulators use similar guidelines in environmental enforcement the way judges use sentencing guidelines. While each enforcement case is unique, such guidelines are a place to start. In this example, prevention of releases of hazardous materials will be a “Tier 1” assessment activity in EMA. It would be followed by a pollution prevention evaluation to determine if the hazardous material could be eliminated or reduced in the facility’s process, yielding less risk, liability, and potential enforcement.

EMA will collapse, simplify, and streamline a dozen or more common EMS steps into three: compliance evaluation, pollution prevention, and continuous improvement. The point of the assessment is to do an initial evaluation of “How am I doing?” in the environmental department and “What more do I need?” Appendices to the guide will include examples of evaluations for traditionally small facilities such as printers, dry cleaners, laboratories, and service stations. Even the most ardent ISO supporter would have to admit that full-blown compliance and certification with 14001 may be overkill in some situations. Some smaller sized facilities may find an elaborate set of steps too daunting for a first effort at organizing environmental issues. The E50.04 task group (part of Subcommittee E50.04 on Performance Standards Related to Environmental Regulatory Programs) now writing the EMA guide intends this as a first step and gradual introduction to EMS concepts. It hopes that many facilities with a variety of compliance problems will take the bait and buy into a more thorough standard such as ISO 14001. For more information contact the author or Dan Smith, manager at ASTM.

EPA and Federal EMS Programs—A Place to Start for Government Facilities and Others

There are four varieties of EPA programs, containing lots of “Big E’s.” The first applies to federal facilities, and is intended to “green the government through leadership in environmental management.” On Earth Day 2000, the president signed Executive Order 13148. This essentially requires all federal agencies and installations, including the military, to put an EMS in place by Dec. 31, 2005. Federal installations use the Code of Environmental Management Principles, which contains many of the standard elements of an EMS. This includes management commitment, compliance assurance, pollution prevention, enabling systems, performance, accountability, measurement, and improvement. The check or audit of a federal facility is done through an Environmental Management Review (EMR) in which EPA advises, assesses, and assists in the implementation of environmental programs, at the request of the facility. Click here for Federal facility information.

The second variety of EPA program is intended to promote EMS in non-federal organizations. The Design for Environment (DfE) has process mapping and technical methods intended to improve small business performance. It features compliance assistance and uses ISO 14000 as a guideline. More information can be found at the U.S. EPA Design for Environment site or the Office of Wastewater Management EMS site.

The third EPA “flavor” is the compliance-focused EMS used in its enforcement program. This means EMS requirements are included in a consent order with companies having prior instances of noncompliance. Many states, including Massachusetts, are evaluating and implementing similar enforcement tools to encourage a systematic compliance approach—pollution prevention and continuous improvement. Readers interested in the use of EMS in EPA enforcement programs should contact the applicable regional office.

Finally, EPA renewed its attempts to encourage EMS by establishing the National Environmental Performance Track (NEPT) in the spring of 2000. By December, over 200 private and public organizations had signed up as charter members for phase one of the program, the Achievement Track. The program recognizes and rewards top environmental performers who have committed to a systematic approach, one complete cycle of an EMS and sustained compliance with environmental requirements. Rewards include a lower priority for inspection and future regulatory breaks, such as better loan terms on water projects and consolidated permitting. This spring, EPA will expand the program to phase two, the Stewardship Track. For more information consult.

ERP: Environmental Results Program—A Place to Go for Regulatory Agencies and Small Business

Five years ago the Massachusetts Department of Environmental Protection (DEP) created a new way of regulating some selected industrial sectors, where predominantly small businesses exhibited difficult permitting and compliance issues. The program is dubbed the Environmental Results Program, or ERP, and now applies to photo processing, dry cleaning, and printing. ERP replaced the traditional permitting and approval program with a mandatory, multi-media, self-certification process. Each facility must fill out and sign a worksheet, certifying compliance and reviewing pollution prevention opportunities. ERP has other features including a systematic approach, and a performance measurement step, which lends itself to continuous improvement. The program also facilitates compliance assistance through workbooks and industry-specific workshops. DEP and industry trade associations share the goal of using training and compliance materials that explain the environmental regulations in a simple, streamlined way. DEP even translated workbooks into Korean to reflect the dry cleaning industry profile.

This unique regulatory program features some new concepts. For example, ERP requires that a senior company official attest to compliance with air, water, and waste regulations. For any non-compliance, the same official must submit and then commit to implement a return to compliance plan. The facility must now take more responsibility for its compliance and corrective action, rather than waiting for an inspection by DEP. The ERP measurement element also provides the industry and regulatory agency with information on Environmental Business Practice Indicators. These are key measures of performance, including traditional record keeping requirements, as well as the facility’s annual improvements in pollution prevention. Such indicators measure pollution prevention benefits, such as substitution of low volatile solvents, improved silver recovery from wastewater, or recovery of perchloroethylene dry cleaning fluid. EPA and other states are now evaluating the ERP paradigm for possible application elsewhere in the United States. Click here for more information.

Big E’s New Way of Doing Business

All the big E’s are steps in the right direction. They all systematically evaluate compliance, perform pollution prevention, and lead an organization into continuous environmental improvement. While there are different kinds, flavors, and uses of alternative systems, the increased reliance on EMS-like models by industry and government may ultimately lead to widespread use of environmental evaluation and improvement systems. The trend appears to tip the balance in favor of self-policing using a “plan-do-check-act” model to evaluate compliance, prevent pollution, and continuously improve the environment around the organization’s footprint. There may come a time when EMS certification, audits, assistance, and correction may stand side by side with traditional permitting, inspection, and enforcement as alternative compliance methods. //

Copyright 2001, ASTM

Helen Waldorf is deputy director for compliance and enforcement in the Business Compliance Division, Bureau of Waste Prevention, Massachusetts Department of Environmental Protection. She is a member of ASTM Committee E50 on Environmental Assessment, and serves as membership chair and task group leader for a new environmental management assessment guide.

For a helpful selection chart of assessment products and their attributes, click here.