Post on 25-May-2015
description
Environmental Management Systems
LISA JARVIS
PURPOSE – presentation focuses primarily on
environmental management system (EMS) design
To provide up-to-date, controlled documentation of all programs, procedures, documents, etc.
To provide user-friendly, around the clock access to ensure proper implementation of all EMS programs and procedures.
Proactive approach to help a company address regulatory demands systematically and cost-effectively
Policy and Commitment
Planning
ImplementationEvaluation
Review
EMS under ISO 140015 Main Stages
Continuous Improvement
POLICY – must have the endorsement of
upper management to be effective
Example Company EHS policy is dedicated to: Meeting or exceeding all regulatory
requirements Pollution Prevention wherever feasible Continuous Improvement Consider Environmental factors when
making purchase and operational decisions Establish, track and review specific goals
Identify Environmental AspectsE.g. air pollutants
Determine most important to companyE.g. worker health & safety, compliance and
cost Legal and Other Requirements Objectives and Targets
Objectives – Overall Goal, e.g. minimize useTarget – Detailed, Quantified, e.g. minimize
by 10% by specific date Management Actions to Support
Objectives and Targets
PLAN
Structure and Responsibility Training, Awareness, Competence Communication EMS Documentation Document Control Operational Control Emergency Preparedness and
Response
DO
Example EMS Structure/HierarchyPolicy; System DescriptionOperational and Management ProceduresStandard Operating Procedures or work
instructionsPlans and Reference DocumentsRecords
DO
Environmental Management System (EMS)
Air Pollution Control Programs
Waste Management Programs
Water Pollution Control Programs
Workplace Environmental Health Programs
Other Environmental Program Management
PROGRAMS & PROCEDURESExamples:
Air Pollution Control
Programs
Air Emissions Permit
(Title V Permit)
Prescribed Monitoring and
Analysis
Compliance Plan
Standard Operating
Procedures
Refrigerants Management
Procedure
Risk Management
Plan
CLEAN AIR ACT Example Applicable Legislation:
Title V Operating Permit ProgramAmendments of 1990
○ National Ambient Air Quality Standards (NAAQS)○ National Emission Standards for Hazardous Air Pollutants (
NESHAP) CAA Title I Section 112 40 CFR Part 63
- Maximum Achievable Control Technology (MACT) - the 1990 amendments to the CAA changed EPA's approach to regulating HAPs, so that NESHAPs are now established based on the "maximum achievable control technology" (MACT) for an industry group or source category (for example, hazardous waste combustors).
Risk Management Plan Title III of CAA, 40 CFR Part 68
PROGRAMS & PROCEDURESExamples:
Water Pollution Control
Programs
Wastewater Discharge Permit
(NPDES Permit)
Best Management
Practices Plan
Sludge Management
Plan
Stormwater Pollution
Prevention Plan
Monitoring and Recordkeeping
Data
Oil Spill Prevention, Control and
Countermeasures Plan
Drum Management
Bulk Liquid Handling and
Storage Procedures
CLEAN WATER ACT Example Applicable Legislation:
Code of Federal Regulations - Title 40 - Protection of EnvironmentChapter I - Environmental Protection Agency
○ Subchapter D--WATER PROGRAMSNPDES (CWA Section 402)
○ 40 CFR Part 122Toxic Pollutant Effluent Standards
○ 40 CFR Part 129Water Quality Standards
○ 40 CFR Part 131
PROGRAMS & PROCEDURESExamples:
Waste Management Programs
Hazardous Waste Spill Prevention, Control & Countermeasure Plan
Waste Analysis
Solid Waste Management
Recordkeeping and Reporting
Pollution Prevention Plan
WASTE MANAGEMENTExample Applicable Legislation:
Resource Conservation and Recovery Act (RCRA) Non-hazardous waste/Solid waste 40 CFR Part
239-259 Hazardous waste 40 CFR Part 260 [-279]
○ Details – Part 261 Ignitable Waste (I) Corrosive Waste (C) Reactive Waste (R) Toxicity
Characteristic Waste (E) Acute Hazardous Waste (H) Toxic Waste (T) = Characteristic waste
Specific wastes such as, slop oil emulsion solids from the petroleum refining industry [K049] = Listed waste
Pollution Prevention Act Toxic Substances Control Act
Workplace Environmental Health and Safety Management Programs
Safety and Environmental
Programs
Hazardous Substances Management [Asbestos,
PCB, Solvents, Bloodborne Pathogens
Contractor Safety
Emergency and Disaster
Response
Embryo-Fetus Protection
Radiation Source Control Program
Occupational Health and Industrial Hygiene
Program
Hazard Communication
Program
MSDS Database
Company MSDS
New Product Approval
Procedure
Chemical Inventory
MSDS Update
Procedure
Exposure Standards
Workplace Sampling Program
Respiratory Protection Program
Fit-testing Database
Respiratory Protection Against Airborne Lead
Program
Industrial Hygiene
Database
Hearing Conservation
Program
WORKPLACE ENVIRONMENTAL HEALTH MANAGEMENTExample Applicable Legislation:
Occupational Safety and Health Act Occupational Safety and Health
Administration (OSHA)National Institute for Occupational Safety
and Health (NIOSH)CFR Title 29 Part 1910 - Labor
○ Subtitle B--Regulations relating to Labor, Chapter xvii--OSHA, Department of LaborThe 1910 Standards cover a myriad of topics:
Personal Protective Equipment (PPE), Occupational Noise Exposure, Emergency Planning and Response…
EXAMPLES:
Other Environmental Program Management
Corporate Citizenship Program
Tier II Reports [Inventory of
Substances for Emergency
Responders]
Toxic Release Inventory Reports
Community Relations and Communications
EHS Management
Programs, Procedures and work instructions
Descriptions of Roles, Responsibilities,
Authorities and Lines of Communications
Equipment Calibration Procedure
Environmental Calendar and Training Schedule Compliance Reviews
EMS Manual
Policy
Lists of Objectives and Targets
Environmental Aspects and Impacts Inventory
OTHER ENVIRONMENTAL PROGRAM MANAGEMENTExample Applicable Legislation:
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Hazardous Substances [Superfund]
Superfund Amendments and Reauthorization Act (SARA)Emergency Planning and Community Right-
to-Know Act (EPCRA) [also known as SARA Title III]○ Tier II Report [SARA 311/312] – Inventory of
Substances for Emergency Responders, 40 CFR Part 370
○ Toxic Release Inventory Report – [SARA 313] Tier III Report
Monitoring and MeasurementE.g. Use of Checklists to determine
compliance with applicable regulationsPlating bath temperatureAmount of hazardous waste generatedAmount of solvent used for parts cleaning
Nonconformance, Corrective and Preventative Action
Records
CHECK
EMS Audits Management Review
Determines if original policy is consistent with company values
Possible revisions to optimize effectiveness
This final review stage creates a loop of continuous improvement for a company
ACT
Environmental Management System (EMS) Example
This presentation is an example and not site specific
Each company - industry - site requires specific programs, plans, practices and procedures
Intended for an overview - example - general idea - demonstration purposes only
Environmental, Safety and Health Programs, Plans and Procedures overlap For example, Drum
Management is a stand alone SOP, but also a part of the OSPCC Plan
Again, Best Management Practices (BMP) is stand alone, but also part of the NPDES permit
OSHA 1910, in particular, addresses health and safety, but overlaps with environmental aspects ○ i.e. HazCom, Hearing
Conservation, Respiratory Protection, PPE usage…