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EMS Manual for Philadelphia Office - Section 1
SECTION 1 — ENVIRONMENTAL MANAGEMENT SYSTEM
This Environmental Management System Manual is a repository for documentation related to the Environmental Management System (EMS) including:
- EMS Procedures that describe how we carry out key tasks within the EMS such as training, identifying environmental aspects, or managing records.
- Programs & Controls that operate under the EMS, such as work plans and programs for achieving EMS objectives and targets and carrying out audits.
- EMS Records or directions that enable individuals to locate appropriate records that confirm the completion of specific EMS activities such as, the identification of Environmental Aspects, EMS training that has been given to specific employees, or the completion of management reviews.
- Definitions, References, and Appendices that contain additional information useful to individuals reviewing the EMS.
This EPA Mid-Atlantic Philadelphia, Pennsylvania Office EMS is managed and maintained by the EMS Coordinator/Management Representative.
A printed or hard copy version of this EPA Mid-Atlantic EMS Manual (Manual) is located in the EMS Coordinators office. However, this is not the controlling copy of the EMS Manual. The controlling copy of this Manual and all other major EMS documentation is on the EPA Mid-Atlantic EMS website at: www.epa.gov/region3/ems/facility
The software that is utilized for the EMS website automatically generates the date when any edits are made and updates this on the bottom of the website files, however due to the need for routine web maintenance and/or other minor editing this date may not be the same as major revision date shown on the document. Starting in December 2004, as significant changes to documents are made the Revision History will be revised to include a brief description of changes and why they were made.This EMS Manual documents the environmental management programs, the operational controls, the EMS audit program, procedures, records and other descriptive information useful to anyone interested in our facility's EMS as well as for our employees/occupants and for those responsible for maintaining this EMS.
Our EMS works on an annual Schedule of planning, doing, checking and acting.
EMS Implementation Start Date: April 2002
EMS Implementation Completion Date: Ongoing
The EPA Mid-Atlantic Philadelphia Office is implementing this EMS; in order to become more fully aware of the adverse environmental impacts of our facility and our activities with a focus on reducing or eliminating those impacts, to reduce the amount and cost of resources by eliminating wasteful practices, and to comply with Executive Order 13148 and the EPA Administrator's Position Statement on EMSs (dated May 15, 2002 and as revised). EPA Region 3 has decided to lead by example and not ask others to do something that we are not willing to do ourselves. For example, in the National Environmental Performance Track Program, EPA recognizes companies who have an EMS as an environmental leader. It is a requirement of Performance Track that the member companies have implemented an EMS program.
D. Background and History of EMSs
Formal Environmental Management Systems emerged in the early 1990s to provide organizations with a proactive, systematic approach for managing the potential environmental consequences of their operations. Such systems have been widely adopted by industry and government and have been effective at improving regulatory compliance and environmental performance.
In April 2000, President Clinton signed Executive Order (E.O.) 13148, "Greening the Government through Leadership in Environmental Management" that established a 5-year EMS implementation goal for all Federal Facilities. President Bush and the current administration have supported this position. EPA, as the principle steward for the environment, has taken a leadership position by developing an EMS implementation initiative.
Phase
1: Planning
The organization identifies how its operations might harm the environment,
and develops methods to reduce this harm.
Phase 2: Doing
The organization implements these methods to reduce harm and operates them
for a designated time period.
Phase 3: Checking
The organization assesses whether the methods that it is operating to reduce
environmental harm and ensure regulatory compliance are proving to be effective.
Phase 4: Acting
The organization determines what changes are necessary based on the performance
assessment of the methods (see Phase 3) designed to reduce environmental harm.
The findings of Phase 4 may indicate that adjustments to methods already in place are necessary or that entirely new methods are needed to achieve established environmental objectives. Output from this phase is fed back into Phase 1 Planning, to make necessary changes and additions designed to bring the EMS to the desired level of effectiveness. This system feedback propels the continual improvement of the EMS.
The EMS continually moves through this cycle, fine-tuning its management of those areas of the organization's operations that harm the environment. This "continual improvement cycle" is a core tenet of the EMS; it allows the system to adapt to the dynamic nature of the organization's operations.
E. Description of EPA Mid-Atlantic Philadelphia Office EMS
The scope of the EPA Mid-Atlantic Regional Office 1650 Arch Street Philadelphia, Pennsylvania Environmental Management System is for our office/facility operations and the commuting and business travel of our employees.
Pertinent facts regarding the EPA Mid-Atlantic office/facility and are located on our EMS website.
Our vision, aspirations and commitment to the environment are specifically expressed in EPA's mission statement and environmental policy. Section 2 below contains the EPA Mid-Atlantic office EMS policy.
EPA Mission Statement
EPA's mission is to protect human health and to safeguard the natural environment - air, water, and land - upon which life depends.
Environmental Hazards
A list of our activities, products or services for EPA Mid-Atlantic office that might result in an environmental risk or impact is maintained on this website.
The EPA Mid-Atlantic Philadelphia, PA Office EMS Policy is signed by the Senior Managers and is located on our EMS website.
Our environmental policy statement is a declaration of our senior management's commitment to the environment, and serves as the foundation for the EMS. Everyone in our organization is expected to be familiar with and understand our policy. Our policy is considered when setting EMS objectives and targets, and it is understood that the implementation of the EMS serves to operationalize the commitments in the policy. Our environmental policy statement is, therefore, a vehicle for communicating our organization's aspirations for environmental protection as well as a functional tool for establishing the operational boundaries of the EMS. Our environmental policy is aligned with our organization's core mission and includes a commitment to continual improvement, pollution prevention, and regulatory compliance. Our environmental policy statement reflects management consensus on its content and aims, and was formally endorsed by having these senior managers be signatories of the Policy.
3. Planning and Environmental Aspects
The EPA Mid-Atlantic Region 3 Environmental Aspects are listed on our EMS website. Procedures for identifying our significant aspects are located in Section 2A.
Our organization's interactions with the environment is shown in our environmental aspects. The EPA Mid-Atlantic Philadelphia Office interactions are identified by reviewing all the activities, products and services of our organization and assessing the possibility each of them have for an environmental impact. Our EMS is designed to control and reduce, where possible, the impacts associated with the identified aspects.
4. Legal and Other Requirements
The legal and other requirements that apply to the EPA Mid-Atlantic Region 3 office are a combination of federal, state and City of Philadelphia statutes, regulations, executive orders, as well as internal EPA policies. Our current Table of Legal and Other Requirements (PDF) (13 pp, 40K, About PDF) is posted on our website.
Our EMS recognizes that certain environmental aspects are significant for an organization because they are regulated or the subject of certain legal or other requirements, which can affect our organization's ability to carry out its mission. These may include federal, state and City laws, regulations, executive orders, as well as, industry standards, and organizational policy, guidance and memorandum. The EPA Mid-Atlantic Philadelphia Office has a procedure to identify these requirements. In most cases it is prudent for all environmental aspects with legal implications to be designated as significant. Procedures for identifying legal and other requirements are located in Section 2B.
Our current Objectives and Targets for the EPA Mid-Atlantic Region 3 are listed on our EMS website. Our procedure for determining our objectives and targets are located in Section 2C. Our objectives and targets are established to address our significant environmental aspects and are integrated at all levels and functions of our organization. Objectives and targets are set by considering, in part, the legal and other requirements, the views of interested parties, as well as, technological, financial and other operational considerations. This ensures that our objectives and targets are robust, that they respond to legitimate concerns, that they are realistic for the organization, and that it is possible to develop strong management programs to achieve them.
6. Management Programs and Work Plans for Achieving Objectives and Targets
The Environmental Management Programs or EMPs contain information describing our program approaches and strategies for achieving our objectives and targets, as well as the performance indicators, and the roles and responsibilities for accomplish tasks, and the competency of individuals associated with those tasks. Our EMPs tie many elements of the EMS together (e.g., significant aspects, objectives and targets, resources, responsibilities, and capabilities) and provide a link to our Work Plans. EPA Mid-Atlantic work groups have written Work Plans to achieve the organization's objectives and targets. The Work Plans contain details on the resources (e.g., financial, human, and technological) and timeframes and milestones to accomplish the objectives and targets. The Work Plans are accessible from links on Objectives and Targets page on our EMS website. The procedure for developing our Work Plans is located in Section 2E. New Work Plans for FY 08-10 are under development.
7. Roles, Authorities and Responsibilities
The roles and responsibilities for activities under the EMS are clearly defined
and as stated above, many of these appear in the EMS programs and operational
controls. While our EMS is largely sustained by the voluntary participation
and commitment of our employees, certain duties are assigned with clear roles
and responsibilities and with attendant accountability for performance and
results. For example, senior management must appoint a EMS Coordinator/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. The EMS Integration Team,
consisting of representatives of all major organizations in our office/facility.
Additional information regarding roles, authorities and responsibilities is
provided in Section 2, F, J, Q, and R. New organizational chart.
8. Training, Awareness, and Competence
Our EMS requires two types of training: general awareness, and competence training. General awareness training for all our employees focuses on the importance of the environmental policy, the role of employees, and the potential consequences of failing to provide environmental care. Competence training is prescribed for our employees that work in proximity to significant environmental aspects and focuses on the possible significant impacts of those aspects, their specific roles and responsibilities, the objectives and targets for those aspects, and the operational controls in place to avert the actualization of the potential impacts. Competence training is detailed in the EMS programs and in the documentation of operational controls. Most of our competency training on our operational controls is done in email messages sent to all our occupants. The EMS Management Representative/Coordinator ensures that both types of training are conducted as appropriate to satisfy these requirements. For additional information and a description of the approach taken to identify EMS training needs, see Section 2F.
Most of the documents comprising the EPA Mid-Atlantic Office EMS are posted on the internet to make them readily accessible in a convenient format for our employee and our external stakeholders. Clearly, effective integrated environmental management demands effective communications to coordinate staff internally and to liaise with external stakeholders. Maintaining employee awareness of EMS initiatives, motivating them, and supplying them with knowledge of their roles and responsibilities all require communication. It is also true that communication is a two-way process; that employees can make recommendations to management and give their views when necessary.
We have tried to consider the views of interested parties in our EMS by first making our information readily available on the internet and meeting with our building manager and the other main tenant in our building. These face to face meetings provided for effective two-way communication between external stakeholders and our facility.
Interested parties can communicate their views to our facility, and we will respond to these parties. The EMS Work Plans provide for outreach to external stakeholders including our building landlord, our building's other tenants, as well as suppliers and vendors, to make them aware of our EMS. For additional information and a description of the approach taken to provide internal and external communications, see Section 2J, K and L.
10. Documentation and Document Control
Our readily available documentation on the internet and document control procedures ensure that we are maintaining information in a manner that would allow someone with a legitimate interest in the EMS to understand how it is designed and implemented. Our web based EMS also provides all the information that is essential for employees to know about EMS issues, as well as providing this information for external parties such as contractor, vendors, other regulators, registrars and other interested parties. This EMS Manual provides an overview or our EMS documentation and refers to and links out to other essential EMS document. However it is likely that some documents will be maintained outside the web based EMS and EMS Manual in which case they will just be referenced in the Manual.
Due to the wide variety of documents used in the EMS it is essential that a formal approach be developed to control and organize them. Our web based system and document control procedure ensures that documents being used are the most up-to-date versions. Since the controlling copy of the EMS is on the web, and printed copies are unofficial, removing obsolete documents from circulation is not necessary. For additional information the creation, review and approval of documents and a description of the approach taken to provide document control, see the Procedures for Document Control in Section 2N.
It is important to control those activities, products or services that might cause a deviation from our organization's environmental policy or result in significant impacts. Our Operational Controls are designed to support the achievement of EMS objectives and targets. Our operational controls specify engineering or administrative measures implemented to reduce the risk that an impact will occur. Our Operational Controls document the who, what, how, when and where for activities we want to manage that are related to our EMS. The procedures for developing our operational controls are located in Section 2D.
12. Emergency Preparedness and Response
Our EMS provides a systematic method to manage known and expected elements of our organization's operations. However, despite best efforts there is the possibility of unpredictable accidents and emergencies. Due to the nature of the activities, products and services associated with office setting of our EPA Mid-Atlantic EMS we have chosen to model our EMS on the basis of a normal condition only.Our Emergency Procedures [may only be viewed by EPA employees] and Occupant Emergency Plan (PDF) (121 pp, 6.0MB, About PDF) [may only be viewed by EPA employees] (OEP) for 1650 Arch Street provide for unexpected occurrences and spell out emergency procedures for occupants to follow. From the perspective of the EMS, it is necessary that measures be included to address the environmental consequences of such occurrences. It is expected that such measures work to control and mitigate those possible environmental consequences. For additional information and a description of the approach taken to provide emergency preparedness and response see Section 2G.
13. Monitoring and Measurement
Monitoring and measurement is fundamental to our EMS, it ensures that management plans; controls, and training are effective. Furthermore, it enables our organization to identify its progress toward achieving objectives and targets, and the reasons for our level of achievement. Without effective monitoring and measurement it would be impossible for us to continually improve - which is the basis of our EMS. We will periodically monitor performance, operational controls, and general conformance with EMS objectives and targets. For additional information and a description of the approach we have taken to provide monitoring and measurement see Section 2I.
14. Nonconformance and Corrective and Preventive Action
When we identify a weakness in our EMS or an ineffective part of our EMS, we will initiate and effect a correction. Our EMS has procedures to receive, document and investigate problems, understand their root causes, and then implement corrective actions that prevent recurrence. For additional information and a description of the approach taken to address non-conformances in our EMS see Section 2P.
The EPA Mid-Atlantic Office understands it is critical to effectively implement and carry out all the various elements of the EMS, and that it is also important to be able to demonstrate that you have done so. We will do this through the creation and management of records of various implementation activities and other EMS results from training, audits and management reviews. Our records will be managed so that they can be easily accessed and retrieved. Document Retention is done in accordance with, "Files and Records Disposition Plan, Office of Environmental Innovation EPA Region 3" posted on the intranet at: http://intranet.epa.gov/r3intran/oirm/recman/Envinn.pdf (PDF) (4 pp, 12K, About PDF) [may only be viewed by EPA employees]. The EPA Mid-Atlantic offices considers all EMS records as administrative records which may be destroyed when they are two years old or no longer needed. For additional information and a description of the approach taken to manage records see Section 20.
The EPA Mid-Atlantic Office will conduct internal EMS audit to test whether the system has been implemented and maintained as designed. An internal audit will assess whether the EMS implemented at the EPA Region III office (Phila.) is conforming to the requirements of EPA EMS audit protocol. It will determine if the EMS has been implemented facility wide and is operating systematically achieving the desired goal. The audit will also fulfill the requirement for periodic evaluations of compliance to legal and regulatory requirements. The audit will test whether the program that has been implemented is actually working as they were intended to work to achieve and maintain compliance. We will use our EMS internal audits to gauge the status on regulatory compliance. For additional information and a description of the approach taken to provide for EMS internal audits see Section 2Q.
Our EMS reserves a special role for senior management, as well it should. Our Management must not only formulate and articulate the environmental commitments of our organization in the environmental policy, but must also render judgment on whether the EMS continues to be suitable, adequate and effective. This is accomplished through the periodic management review that affords our management the opportunity to judge the EMS and its results. On that basis, management is expected to make decisions relative to the EMS so that it continues to perform and deliver as expected.
The Management review is the last phase of our annual EMS cycle. Our EMS works on an annual Schedule of planning, doing, checking and acting.
Revision History
Date of Action
Originally written: January 2003
Revised March 2004, September
2004
Revised December 2004 to address audit findings to clarify the scope of
our EMS
Revised January 2007 to address audit findings to clarify the scope of
our EMS
Revised October 2008 during website update
Author: EMS Team/EMS Coordinator
Reviewed
and Approved: Senior Management
Review History
Reviewed January 2010