EMS Development - The Importance of Planning
Prior to the implementation of an EMS, there are several important planning steps that need to be undertaken to ensure the initiative gets off to a strong start. These steps include:
- EMS Objectives, Model, and Scope:
The objectives of the EMS must be clearly established and accepted throughout the organization at the onset. For example, one organization may be primarily interested in developing a compliance-focused EMS that will help ensure that they have identified and are in compliance with all applicable environmental regulatory requirements. For another organization, the goal of ISO 14001 registration may be the primary objective.
Various EMS models exist, all sharing common elements such as defined roles and responsibilities, effective training programs, and systems for communication. Some organizations choose to customize an EMS model to meet specific needs. The scope of the EMS also needs to be determined, including issues related to multiple facilities and locations, areas of overlap between corporate and local operations, leased properties, etc.
- Resources and Schedule:
Another important component of the EMS planning process is identifying and securing the resources needed to move forward with the EMS development and implementation. Although the EMS will result in improved operating efficiencies and associated cost savings that will outweigh the organization's investment, it must be acknowledged that the initial development and implementation will take time and money. The organization must allocate the necessary resources; without this commitment, EMS development efforts will be jeopardized and frustrations will arise. Establishing a 'cross-functional' team to lead the EMS development and implementation efforts is typically an effective strategy. Team members must have their normal workloads reallocated as necessary to ensure they have meaningful participation in the EMS initiative. Finally, a schedule for EMS implementation should be established. Although the initial schedule may require adjustment as the EMS progresses, it is important to establish an end goal to help maintain the discipline required to complete the process.
- Gap Analysis and Implementation Plan:
Once the EMS development objectives and scope have been established, the typical starting point for EMS implementation is an evaluation of the current status of environmental management activities in the organization. These evaluations (commonly referred to as 'gap analyses') identify the current processes for managing environmental issues, including existing policies and procedures, roles and responsibilities, communication systems, recordkeeping, and training programs (see ENSR Insight, Volume 4, 2000, 'Using Gap Analysis to Plan Effective Environmental Management Systems'). The gap analysis compares the processes that are already in place, relative to the specific requirements of the selected EMS model. ENSR recommends performing these evaluations using a streamlined process that identifies 1) the relative strengths of current environmental programs and 2) specific EMS elements that need to be addressed or improved.
The results of the gap analysis are used to develop a detailed EMS Implementation Plan, which is a critical, but sometimes overlooked step in the EMS development process.
Developing the EMS Implementation Plan
The transition from the completion of the gap analysis to the commencement of EMS development represents a critical juncture. Upon reviewing a gap analysis report that highlights a series of 'deficiencies' or areas where the organization's existing systems require improvement, many clients feel overwhelmed with the prospect of addressing all these needs. Numerous EMS initiatives have languished after the completion of the gap analysis due to inertia or lack of motivation to move forward. It is in these instances where the development of a clearly defined and effective EMS Implementation Plan can serve to provide the guidance necessary to get things rolling.
An effective EMS Implementation Plan will provide detailed instructions on how to build each element of the EMS. From the results of the gap analysis, the organization's existing processes and their effectiveness in each of the EMS 'elements' such as Policy, Training, Communication, and Corrective Actions will be detailed. Each element of the existing processes, how well they work, and what is missing relative to the criteria of the EMS model selected (i.e., the 'gaps”) will then be understood. The EMS Implementation Plan takes the gap analysis to the next level beyond the identification of the 'gaps' to provide detailed instructions on how to address them.
To be most effective, the EMS Implementation Plan must be specific and detailed. For example, if one of the gaps identifies the need for a regulatory tracking system, an Implementation Plan that provides an action item to 'develop a system for identifying legal and other requirements' is not valuable. As with any complex effort, the EMS development process must be broken down into specific tasks that are easily implemented. For this example, an Implementation Plan that breaks this task down into the following detailed action steps would be more effective:
- Identify resources for tracking federal and state regulatory requirements-- review EPA and state web sites and evaluate subscription service alternatives.
- Contact City Hall and identify any applicable local environmental regulatory requirements. If applicable, identify the means to access up-to-date information (e.g., web site, annual update of hard copy, etc.).
- Identify any 'other' requirements, e.g., trade associations, corporate requirements.
- Develop, format, and create a legal and other requirements register.
- Develop a procedure for the periodic and regular review of federal, state, and local regulatory requirements (e.g., designated responsibility for quarterly review of regulatory web sites) and means to document.
- Develop a system for periodic and regular update of legal and other requirements register (e.g., designated responsibility for quarterly review and update).
- Establish a link between the legal register update and facility change management processes. Modify capital equipment review and new chemical approval procedures to include a review of potential regulatory requirements and an update of the legal register as appropriate.
By providing a higher level of detail, the original action item 'develop a system for identifying legal and other requirements' is transformed from a vague and intangible task that is unmanageable, to a series of straightforward actions that can be readily accomplished, one step at a time.
EMS Implementation Plan Format
For best results, the EMS Implementation Plan format should be as simple as possible.
A basic 'Action Plan' style table works well. The Implementation Plan should readily accommodate and update an expanding level of detail as each EMS element is addressed. The EMS Implementation Plan should be updated every few weeks during the EMS development effort to document progress and keep the action items on track.
Table 1 is an excerpt from the successful EMS Implementation Plan of a facility developing an EMS in preparation for ISO 14001 registration; but other EMS models could be adapted to the same format.
Table 1: EMS Implementation Plan
- ISO 14001 Clause 4.6: Management Review
System Works Effectively
- A regular management review session is conducted for the facility's quality system.
- Management Team meetings are held periodically.
- Need to develop a management review function specific to the EMS.
Required for ISO 1001 Registration
- Formal management review of the EMS, held periodically to evaluate overall performance, review progress toward meeting the goals and objectives, establish new or modified goals and objectives, review significant environmental issues.
- The management review must be documented (e.g., through meeting minutes).
1. Priority 2
- Consider integrating EMS Management Review function with the quality system management review.
2. Priority 2
- Design the EMS Management Review session so that it covers a review of the policy, objectives and targets (including progress and action plan update), results of EMS and compliance audits, and other issues of significance, including changing circumstances and the commitment to continual improvement.
3. Priority 3
- EMS Management Review must cover all 17 elements of the ISO 14001 standard either all at once or in a sequence.
4 Priority 2
- The Management Review must be documented - consider developing a forum to document the date, attendees, topics of discussion, ISO elements reviewed, and key decisions. Results of the Management Reviews should be maintained as records.
5. Priority 1
- During EMS development, conduct more frequent management briefings (e.g., monthly) to keep the management team current on the status of EMS Implementation and solicit their feedback on the process(es) being developed.
6. Priority 3
- Prepare a tab section for this procedure in the EMS Manual. Include discussion of the Management Review participants, schedule, and documentation.
Managing the EMS Implementation Plan
EMS implementation is a complex process, and may undergo several revisions during the process. As each element is addressed, the action steps will become more specific as the management system design and function become clear.
To make the process more manageable, establishing a priority ranking should be considered to ensure that efforts are expended first on those EMS elements that represent 'critical path' items. For example, for a facility pursuing ISO 14001 registration, the process of identifying environmental aspects is a critical step in EMS development, since much of the EMS is focused on those aspects that have been designated as 'significant.' For an ISO 14001 facility, the EMS Implementation Plan action items under the Environmental Aspects elements should be given a top priority.
Most importantly, the success of the EMS Implementation Plan is dependent upon the leadership and discipline imposed by those driving the effort. A responsible person and a target completion date should be attached to each action item. Although the EMS development effort is best accomplished by a core team of staff representing different affected parts of the organization (e.g., environmental, engineering, human resources, quality), it will be the responsibility of one individual to drive the effort forward, ensuring that action items are completed and priorities are maintained.
Without adequate planning, EMS development can seem overwhelming and complex. An effective way to facilitate EMS development is to create a detailed EMS Implementation Plan, which breaks the process down into clearly defined action steps. Regardless of the format, a clear and explicit action plan will help facilitate the EMS development process.
Tips for an effective EMS Implementation Plan:
1. Include a sufficient level of detail to ensure that each action step is clearly understood. Break larger tasks down into smaller components to enable them to be more easily accomplished.
2. Use a simple format for the EMS Implementation Plan that allows for the itemization of action items to address each EMS element.
3. Establish a priority ranking to ensure that efforts are expended first on those EMS elements that represent 'critical path' items.
4. Keep the EMS Implementation Plan up-to-date. The Plan may need to be revised every couple of weeks as action items are completed.
5. Assign responsible people and target completion dates to each action item, and make sure that proper responsibility and authority have been prescribed to keep the process moving forward. A 'Taskmaster' with adequate stature within the organization may be required to maintain attention and the commitment of resources throughout the EMS development process.