Section 3

SECTION 3 — IMPLEMENTATION AND OPERATION

3.1 RESOURCES, ROLES, RESPONSIBILITY AND AUTHORITY

Roles and responsibilities for activities under the EMS must be clearly defined and as stated above, many of these appear in the EMPs. While an EMS is largely sustained by the voluntary participation and commitment of members of the organization, certain duties are assigned with clear roles and responsibilities and with attendant accountability for performance and results. For example, top management must appoint a management representative to be responsible for leading the creation, implementation, and maintenance of the EMS. Other roles are assigned to members at various levels and functions throughout the organization where significant environmental aspects are present.

EMS Coordinator

The EMS Coordinator is responsible for reviewing and updating this manual each year. The EMS coordinator reports directly to the Administrative Team on all EMS processes, and directs the activities of the EMS programs at the R6 Lab. EMS Team Leads submit reports, plans, proposals, and like items through the EMS Coordinator. After discussion, the EMS Coordinator will present them to the Management for approval.

The Branch Chief at the Houston Lab appoints the EMS Coordinator and ensures that EMS implementation continues and personnel are continually trained in the EMS processes. It is highly encouraged that EMS Team Leads positions are rotated annually whenever possible to ensure EMS policies and procedures are being carried out as planned. EMS Coordinator and Team Leads can access to their appropriate EMS folders on the Shared directory to ensure that all EMS documents are continually maintained.

The following Individuals and groups have specific responsibilities within the structure of the EMS:

R6 Lab EMS Responsibilities

Individual / Group	Responsibilities
EMS Coordinator	Implement and maintain the EMS for continued conformance to ISO 14001. Reports directly to R6 Lab Management. Coordinates EMS activities through the EMS Team Leads at the lab.
EMS Alternate Coordinator	Assist the EMS Coordinator with overall program.
EMS Team Leads	Directly participate in the development, implementation and operation of their SEA. Responsible for their EMPs & OCs.
EMS Team Members	Assist their EMS Team Lead in carrying out the tasks.
SHEM	Responsible for health, safety and environment of the lab
EMS Internal Audit Group	Conduct internal audits to determine system conformance. Reports directly to EMS Coordinator for all EMS activities.
R6 Lab Management	Final responsibility for environmental compliance and decisions regarding the allocation of EMS resources (i.e., Top Management).
Environmental Management Contractors (outside)	Assist as needed with EMS tasks.
Supervisors/Team Leaders	Ensure that staff is aware of and complying with EMS policies and procedures. Participate in and provide resources for all EMS activities and decisions. Supports EMS Coordinator and Team Leads.

3.2 EMS TRAININGS

Purpose

The purpose of this procedure is to ensure that the R6 Lab employees receive periodic environmental awareness training and to identify and provide appropriate training for those employees whose work activities are related to the SEAs. The provision of such training is necessary to ensure operation of the lab in accordance with the EMS and to achieve the objectives and targets established as part of the EMS. This procedure outlines training currently offered to the lab employees as well as training currently under development as part of our EMS implementation process.

Awareness Training

Awareness training ensures that all employees understand the environmental policy, the role of employees in furthering the policy, and the potential consequences of failing to provide environmental care.

General environmental awareness training is provided to all employees as part of the EMS initiation. New employees receive environmental awareness training as part of the new employee orientation process. On a periodic basis, determined by management, all employees receive refresher training to ensure a continuous level of environmental awareness.

The objective of general environmental awareness training is to make all the R6 Lab employees aware of:

• The existence of the R6 Lab EMS and its scope
• The R6 Lab Environmental Policy and its core principles and commitments
• The significant environmental aspects identified for the R6 Lab
• The importance of conformance with the environmental policy and established procedures
• Employee roles and responsibilities in achieving established objectives and targets
• The potential consequences of departure from specified operating procedures
• Who to contact if they have suggestions or become aware of problems

Awareness training programs are reviewed and updated on an annual basis.

Competency Training

Competence training is prescribed for employees whose work interacts with or influences the R6 Lab significant environmental aspects. Competence training ensures that employees understand (a) how their work interacts with the significant aspects, (b) the possible influence and consequences of their actions on those aspects and the environment, (c) their specific roles and responsibilities in controlling the significant aspect and achieving any objectives and targets established for those significant aspects.

The need for competence training is established through a needs assessment that identifies those employees level of competence of and training provided to such employees, and defines any additional training that may be needed.

When required, such training will occur before the employee begins the assigned function.

In general, competence training will focus on:

• The significant environmental impacts, actual or potential, of their work activities and the environmental benefits of improved personal performance.
• The proper procedures for environmental monitoring or measuring.
• Employee roles in achieving conformance with the environmental policy and procedures and with the requirements of the EMS.
• The potential consequences of departure from specified operating procedures.
• Internal audit training and implementation training of EMS operations are coordinated through the EMS Coordinated as needed.

Some types of training are employed in the R6 Lab EMS:

Type of EMS Training	Training Recipients	Training Purpose
EMS Internal Audit (given by external party)	EMS Internal Audit Group	Planning and conducting internal EMS audits
EMS Awareness (given by EMS Coordinator)	All staff permanently stationed at the Region 6 Lab	EMS Policy, Implementation of EMS, Roles and Responsibilities, Targets and Objectives, etc.

3.3 EMS COMMUNICATIONS

Purpose

The purpose of this procedure is to establish methods and responsibilities for communicating environmental information, including information about the EMS, throughout the R6 Lab. Ongoing awareness of the EMS is achieved using several modes of communication.

Procedure

EMS Awareness sessions are conducted for all individuals whose duty station is the R6 Lab. These sessions are designed to cover basic information about the general structure and purpose of EMS, as well as specific information regarding the R6 Lab EMS. All R6 Lab personnel are encouraged to participate by offering ideas to improve environmental performance. Other forms of awareness communication include e-mail updates that indicate EMS status.

The EMS Coordinator establishes lines of communication to ensure the regular collection of data needed to continuously evaluate R6 Lab environmental performances. This is done by ensuring that procedures for monitoring and measuring performance include requirements for reporting such data, and specify how frequently, in what format, and to whom such data is to be reported.

The EMS Coordinator may regularly initiate efforts to communicate information about R6 Lab environmental performances to relevant employees and management. Such communication may range from short email notices to selected employees concerning one aspect of the EMS to more detailed communications that may involve all the R6 Lab employees, such as rollout of new Environmental Management Programs.

Management also communicates with all the R6 Lab employees the results of regular Management Reviews of the EMS.

All employees are responsible for communicating information that could affect the environmental performance of R6 Lab, in either a positive or negative manner. Employees shall use their judgment in determining the most appropriate method of communication, including:

• Reporting to their immediate supervisor or manager
• Reporting through the “suggestion box”
• Reporting directly to the R6 Lab staff or contractors with specific environmental responsibility, including (i) the EMS Coordinator, (ii) those with designated responsibility under the R6 Lab EMPs

In the event of any serious environmental incident or threat, or any other incident with potentially serious environmental implications, all employees shall follow the communications procedures established under the R6 Lab Emergency Preparedness and Response Plan.

3.3.1 Responding to External Interested Parties

Purpose

The purpose of this procedure is to ensure that the R6 Lab receives, documents, and responds to relevant information requests from external interested parties in a consistent and timely fashion. This procedure addresses the lab correspondence to external parties.

Definitions

Interested party - Any person, organization, or group expressing interested in R 6 Lab EMS.

Procedure

EMS members may assist in responding to external interested parties concerning the R6 Lab EMS.

Inquiries from interested parties may reach the R6 Lab in a variety of ways: mail, telephone or e-mail. The lab internet EMS website instructs interested parties to submit inquiries related to R6 Lab EMS using the email address miner.lc@epamail.epa.gov. All messages regarding the R6 EMS must be directed to the EMS Coordinator.

The EMS Coordinator reviews each inquiry and determines whether and how to respond. The EMS Coordinator makes a notation in the external inquiry log to indicate whether a response was provided and the nature of any such response. In addition, The EMS Coordinator notes any follow up communication with the external party in the log.

All external communications from interested parties will be considered when defining SEAs, establishing and reviewing environmental objectives and targets, and for management review.

3.3.2 External Communication of R6 Lab EMS and SEAs

Purpose

The purpose of this procedure is to ensure that the R6 EMS Policy, Manual and Progresses are communicated to external interested parties. Several modes of communication are used to communicate among the levels and functions of the lab and other stakeholders up-to-date on EMS activities.

Procedure

R6 Lab communicates its EMS Policy and Manual to external interested parties using the following means:

• The R6 Lab EMS website lists the EMS Policy and Manual. An email address is provided to allow external interested parties to submit questions or input regarding the R6 Lab EMS.
• The EMS Coordinator regularly corresponds with external parties to exchange information about the R6 Lab EMS.

Communication approaches may include:

• Reporting
• Training events
• Newsletters
• Management briefings,
• Meetings of EMS workgroups, Auditors, SHEM, etc
• Presentations at meetings/conferences

Any written inquiries from external parties regarding R6 EMS are forwarded to the EMS Coordinator. The EMS Coordinator is responsible for coordinating a response (e.g. in consultation with the Lab Director). A documented response is provided to the external party in a timely manner.

The R6 Lab EMS teams provide important communications regarding the environmental performance of the R6 Lab EMS. It is the responsibility of the EMS Coordinator to ensure that information is disseminated to EMS stakeholders.

3.3.3 Communicating with Suppliers and Contractors

Purpose

The purpose of this procedure is to communicate relevant information of the R6 Lab EMS, including EMS policies and procedures, to suppliers and contractors who work with the lab.

Procedure

R6 Lab personnel shall follow established EPA guidelines for all procurement of EMS related items. This includes communication guidelines established by EPA R6 and Headquarters.

The EMS Team reviews all aspects of R6 Lab operations involving contractors or suppliers that may interact with the EMS or affect environmental performance. This review may involves staff from the R6 lab contracting/purchasing, and includes but is not limited to:

• Work performed by contractors or suppliers, or products or services provided by contractors or suppliers, that may interact with the Houston’s SEAs.
• Work performed by contractors or suppliers, or products or services provided by contractors or suppliers, that could create an Environmental Aspect.

For those contractor or supplier services or products identified as “environmentally sensitive” as a result of this review, the Contracting/Purchasing officer (with support from the EMS Team, as needed) meets with the contracting or project officer, responsible for managing the contractor or supplier, to communicates these issue. As part of this meeting, the group will develop a strategy for addressing the contractor or supplier issue. Strategies may include:

• Contacting the contractor or supplier to convey the concerns about the activity, product, or service in question.


• Providing the contractor or supplier with information to assist them in understanding and addressing the issue.


• Initiating a modification to a contract or purchase specification to address the issue. Such modification could include a requirement for contractors or suppliers to take part in the EMS awareness training

To support building awareness about the EMS among contractors and suppliers, the EMS Teams and the Contracting/Purchasing Officer may provide copies of a printed brochure to contractors and suppliers. The brochure explains the EMS and the roles and responsibilities of contractors and suppliers in furthering the goals of the EMS.

3.4 EMS DOCUMENTATION

Purpose

The purpose of this procedure is to ensure that EMS documents are controlled so that only the latest Authorized Versions of the EMS documents are in use. Each EMS Team is responsible for the review, revision, and implementation of the EMPs, OCs, and other EMS documents related to their SEA.

The EMS Team and other stakeholders periodically review all EMS documents. In general, the EMS Manual is written and revised by the EMS Coordinator and offered for comments to the entire R6 Lab.

Definitions

Official versions of all EMS documents maintained electronically by the EMS Coordinator and Team Leads on the shared directory and made available to employees through the LAN intranet.

Approach

All EMS documents are created using possible established templates to ensure consistency in their appearance and format.

All EMS documents are dated to identify when they were created. This ensures that only the most current versions are in use.

All EMS documents include a signature box to identify the individual responsible for the document. All EMS documents identify those R6 Lab employees (by name or job function) who must be informed of revisions made to the document, and provided current versions of the document when changes are made. Notification of changes, and transmission of revised documents, is done by email.

Official copies of EMS documents are those versions signed in ink by the author. Official copies of all EMS documents are kept and maintained by the EMS Coordinator.

All official copies of EMS documents include a version tracking page that identifies the date of the revisions, and the nature of the revisions.

When revisions are made to any EMS document, one copy of the superseded version is selected by the EMS Coordinator and filed for two years or as otherwise required by law. After two years, files shall be copied electronically for future reference.

All current versions of EMS documents are posted to the R6 Lab EMS Intranet site in non-editable PDF format. The EMS Coordinator is responsible for providing PDF versions of all documents to the EPA EMS webmaster. All staff are instructed where to find EMS documents on the R6 Lab EMS Intranet site during Awareness Training Sessions, and through other EMS communications.

The key EMS documents include:

Examples of Key EMS Documents

EMS Document	Document Control Code (example)	Document Purpose
EMS Manual	R6-MD-H-EMS-MAN-FY10 (fiscal year)	To describe the overall structure and function of the EMS.
EMP Programs	R6-MD-H-EMS-CM-EMP1-100304	To document the specific content of the EMP and OC with the latest approved date.
Internal Audit Plans	R6-MD-H-EMS-AD-INT-100304	To define audit scope, criteria and logistics with the reported date

The electronic versions of current EMS documents are maintained on a local area network directory that is accessible to all R6 Lab staff. The main folder is titled Environmental Management System. Sub-folders under the main folder are clearly labeled (e.g., EMS Policy or EMS Manual). Obsolete documents are removed from the current EMS folder and archived by the EMS Coordinator.

EMS Procedure for Records Management

Purpose

The purpose of this procedure is to ensure that EMS records are properly identified, retained and maintained. A document control system is utilized to ensure that only the most recent versions of the EMS Manual, Policy and Programs are available for reference.

Procedure

The specific records associated with each significant environmental aspect are listed on the EMP including the location and the owner of each record. In general the EMS Coordinator maintains the EMS records (e.g., EMS policy, aspect analysis data, EMS Team meeting minutes) and the Facility and SHEM maintain the facility level records (e.g., building performance data, facility O&M contractor training). The disposition of EMS records follows the EPA record control policies.

• All EMS records will be identified as such with a notation or cover page.
• Records shall be legible, identifiable, and easily retrieved for review.
• Records shall be maintained for all projects that have active environmental management programs. At a minimum, this includes: training records, internal audit records, and management review records.

3.5 EMERGENCY PREPAREDNESS AND RESPONSE

Purpose

To establish and maintain procedures to identify potential for and respond to accidents and emergency situations, and to preventing and mitigating the environmental impacts that may be associated with them.

Procedure

In the event of a chemical spill, response procedure can be found in the Share Drive:

R6 Laboratory Chemical Hygiene Plan

• IV. Components of the Chemical Hygiene Plan
Spills and Accidents, pg 33. S:\Health & Safety\SHEM Manager\Health & Safety\Chemical Hygiene Plan

Responses to other emergency situations such as: Fire, Bomb Threat, Severe Windstorm/Tornado Sighting, Hurricanes, earthquakes, Civil Disturbances, Brown-outs/Power loss, and Hostage Situations - can also be found in the Share Drive:

Occupant Emergency Action Plan (OEAP), Appendix A-E

S:\Health & Safety\FIRE and Security\OEAP