Diploma of Environmental Monitoring & Technology
Study module 5
Environmental Management Systems
Environmental
management systems
Completion Record
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EMS Study module 5
Environmental Management Systems
INTRODUCTION
2
What is an EMS applicable to?
Implementation of an EMS
2
2
COMPONENTS OF AN EMS
4
Environmental policy
Planning
Implementation and operation
Checking
Management review
Benefits of an EMS
4
5
8
10
11
12
DETERMINING ENVIRONMENTAL ASPECTS – EASO APPROACH
12
Planning an EASO
Gathering information
Evaluation of data
Reporting
An example tool for evaluating potential impacts
13
14
14
15
16
ASSESSMENT
17
Required knowledge questions
Assessment & submission rules
References & Resources
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Introduction
An Environmental Management System (EMS) is a framework or tool that assists
organisations in managing the impacts of an organisation's activities on the environment. It
provides a structured approach to planning and implementing environment protection
measures. The US EPA (US-EPA, 2013) states that;
“The assumption is that this increased control will improve the environmental performance
of the company. The EMS itself does not dictate a level of environmental performance that
must be achieved; each company's EMS is tailored to the company's business and goals.”
This results in an EMS being integrated holistically into both a company's daily operations,
long term plans and its short term operations and usually finds itself being integrated with
other quality systems (such as quality assurance and safety).
What is an EMS applicable to?
The Standard states that the methodology of environmental management is applicable to
any organisation that wishes to;
1. establish, implement, maintain and improve an environmental management system,
2. assure itself of conformity with its stated environmental policy,
3. demonstrate conformity with this International Standard by
a. making a self-determination and self-declaration, or
b. seeking confirmation of its conformance by parties having an interest in the
organization, such as customers, or
c. seeking confirmation of its self-declaration by a party external to the
organization, or
d. seeking certification/registration of its environmental management system by an
external organization
Implementation of an EMS
In Australia, the EMS framework most commonly used is the AS/NZS 14001:2004 standard,
which is based on the International Standard (ISO 14001) from 2004. These Standards state
the main stages of an EMS’s implementation, based on the PDCA cycle of Plan: Do: Check:
Act, as described below.
Policy and planning
Senior management commit to environmental improvement and establishes an
organisational environmental policy.
To plan for environmental management, the organisation needs to identify the
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environmental aspects of its operations that might have potentially negative impacts on the
environment (such as air or water pollutants).
The organisation then determines which aspects are significant by choosing criteria
considered most important by the organisation (such as environmental compliance or WHS
concerns).
Once significant environmental aspects are determined, the organisation sets objectives and
targets. An objective is an overall environmental goal whereas a target is a detailed,
quantified requirement that arises from the objectives.
The final part of the planning stage is devising an action plan for meeting the targets. This
includes designating responsibilities, establishing a schedule, and outlining clearly defined
steps to meet the targets.
Figure 5.1 – The PDCA continual improvement cycle as applied to EMS.
Implementation and operation
A company follows through with the action plan using the necessary resources (human,
financial, etc.). An important component is employee training and awareness for all
employees. Other steps in the implementation stage include documentation, following
operating procedures, and setting up internal and external communication lines.
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Checking
A company monitors its operations to evaluate whether targets are being met. If not, the
company takes corrective action.
Management review
Top management reviews the results of the evaluation to see if the EMS is working.
Management determines whether the original environmental policy is consistent with
company values. The plan is then revised to optimize the effectiveness of the EMS. The
review stage creates a loop of continuous improvement for a company.
Components of an EMS
An effective EMS to be developed and implemented, you need commitment from the senior
management of the organisation, operational staff and transparent, usable systems and
procedures. The key components that should be considered when developing an EMS
include (DSEWPC, EMS, 2009);
Environmental policy
This is a statement of what an organisation intends to achieve from an EMS. An example can
be seen in the snippet below from a company called Orica;
Figure 5.2 – A snippet of Orica’s environmental policy [source]
The environmental policy is a public document that outlines an organisation's commitment
to environmental management. The policy also provides an overall indication of key issues
to be addressed.
The structure and content of an environmental policy will depend on the nature and scale of
the business. As a minimum, the environmental policy will have top management support
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and will include the following information:
◗ compliance with relevant environmental legislation and regulations, and to other
obligations to which it subscribes
◗ advocates pollution prevention, and
◗ seeks continual improvement through planning processes, by setting objectives and
targets, and through periodic review and action to enhance the system and its
outcomes
An effective environmental policy will be designed following extensive stakeholder
consultation and will be clear and concise. For large organisations, the environmental policy
is a tool to initiate behavioural and cultural change. The environmental policy is also a
communication tool for stakeholder engagement.
In keeping with the PDCA cycle, the environmental policy will change over time as a
reflection the dynamic nature of management, changes to environmental issues and society
values.
The policies can be viewed from two perspectives; cynical or practical. A cynical assessment
would be to describe the policies as a corporate ‘greenwash’, a simple thing to say to put
people’s minds at rest, whereas from a practical perspective, an environmental policy is the
actually the ‘tip of the iceberg’ of the overarching environmental management strategy that
ends with practical environmental protection measures being implemented on the ground
by operators in the business.
An environmental policy is a corporate commitment from the senior management that the
organisation will act in an environmentally friendly manner. The document itself is not as
important as the commitment to the objective by the people involved.
Planning
Identifying aspects
Identification and documentation of the actual and potential environmental impacts of an
organisation's operations need to be undertaken. This can be achieved through undertaking
an environmental audit, the results of which are fully documented.
There are an innumerable number of tools available for conducting environmental audits for
the purposes of examining the aspects of the environment that can be affected by a
company or organisation. Any that are used should comply with AS/NZS ISO 19011:2003
Guidelines for quality and/or environmental management systems. An example of the NSW
Compliance Audit tool is seen in the figure below.
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EASO…
The Australian Standards produce a guideline for undertaking an Environmental Assessment
of Sites and Organisations (EASO). Refer to AS/NZS ISO 14015:2003 for details.
Control versus influence
Environmental aspects in an organization can fall into two broad categories or types;
◗ Those that can be controlled directly (i.e. pollutants)
◗ Those that can be influenced, or be influenced by (i.e. raw material ingredients)
Careful consideration so also be given to the following;
◗ legal or contractual authority
◗ its policies
◗ local or regional issues
◗ obligations and responsibilities to interested parties
◗ implications on its own environmental performance
To identify and have an understanding of its environmental aspects, an organization should
collect quantitative and/or qualitative data on the characteristics of its activities, products
and services such as inputs and outputs of materials or energy, processes and technology
used, facilities and locations, transportation methods and human factors (e.g. impaired
vision or hearing). Standard AS NZS ISO 14004 – 2004 states that;
“In addition it can be useful to collect information on;
◗ cause and effect relationships between elements of its activities, products, and
services and possible or actual changes to the environment
◗ environmental concerns of interested parties
◗ possible environmental aspects identified in government regulations and permits, in
other standards, or by industry associations, academic institutions”
Where do we get this information from?
The Standard(s) provide a list of potential sources of information that help identify the
organisations environmental aspects, but in terms of pollutants, it is all done from
monitoring which obviously relates to the role of the environmental technician.
Other sources include historical data, manufactures manuals, Australian Standards,
(M)SDS’s, Codes of Practice and many others.
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Legal requirements
Any organization needs to establish, implement and maintain procedures that monitor
compliance with relevant statutory instruments that will;
◗ identify and have access to the applicable legal requirements
◗ to determine how these requirements apply to its environmental aspects
This will ensure that the applicable legal requirements and other requirements to which the
organization subscribes are taken into account in establishing, implementing and
maintaining its environmental management system. Examples of these could include;
◗ Legislation and regulations
◗ EPA Licences
◗ Local council requirements
◗ Waste reduction targets
◗ Judgements from courts
Other than what’s listed, any similar requirement that the organisation needs to commit to
will be included. Typically, information such as this is stored in ‘registers’ in the organisation
and it is obviously related to the compliance audit.
Objectives and Targets
An environmental audit forms the basis of determining an organisation's environmental
objectives and targets. An organisation can find benefits in adopting more stringent longer
term objectives to encourage it to improve its performance. To continually improve, targets
should be regularly reviewed.
The objectives and targets need to be measurable and consistent with the environmental
policy, including the commitments to prevention of pollution, to compliance with applicable
legal requirements and with other legal requirements and to continual improvement.
Figure 5.3 – An example of using baseline data to meet objectives resulting in targets.
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The use of performance indicators
The need to establish, implement and maintain a programme for achieving the
organisations objectives and targets are a basic requirement in any EMS. Logic dictates that
if you are trying to prevent environmental damage, then you need both goals and targets to
achieve, and therefore you must have a baseline of data to make objectives from. These
programmes will generally include;
◗ designation of responsibility for achieving objectives and targets
◗ the means and time-frame by which they are to be achieved
The Standard recommends using environmental performance indicators such as;
◗ quantity of raw material or energy used
◗ quantity of emissions such as CO2
◗ waste produced per quantity of finished product
◗ efficiency of material and energy used
◗ number of environmental incidents (e.g. excursions above limits)
◗ number of environmental accidents (e.g. unplanned releases)
◗ percentage waste recycled
◗ percentage recycled material used in packaging
◗ number of service vehicle kilometres per unit of production
◗ quantities of specific pollutants emitted, e.g. , SO2, CO, VOCs, Pb, CFCs
◗ investment in environmental protection
◗ number of prosecutions
◗ land area set aside for wildlife habitat
Implementation and operation
Resources, roles and responsibility
Ensuring the availability of resources essential to establish, implement, maintain and
improve the environmental management system is critical to the success of any EMS. The
precise definition of ‘resources’ will depend on the organisaiton, and the reason for
implementing the EMS, as well as the numbers and skill levels of the personell involved, but
could include;
◗ human resources
◗ specialised skill sets
◗ organizational infrastructure
◗ technology
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◗ financial resources
◗ Legal skill sets and resources
Roles, responsibilities and authorities need to be well defined, documented and
communicated in order to facilitate effective environmental management. This involves the
organisation's top management appointing a specific management representative who,
irrespective of other responsibilities, shall have defined roles, responsibilities and authority
for;
◗ ensuring that an environmental management system is established
◗ reporting to top management on the performance of the EMS
Competence and training
An EMS requires people with an environmental skill set. This could mean hiring the right
people, but can also man training to ensure competence. This will unsure that;
◗ conformity with the environmental policy and procedures and with the
requirements of the environmental management system
◗ the significant environmental aspects are identified
◗ the roles and responsibilities in achieving conformity are maintained
◗ the potential consequences of departure from specified procedures are understood
Staff should undergo environmental awareness training to familiarise them with their
responsibilities for implementing the EMS and with the overall environmental policy and
objectives of the organisation. This provides staff with the necessary skill and motivation for
the effective implementation of the EMS.
Consultation
Staff and community consultation should be undertaken before, during and after
establishment of an EMS. This is necessary to ensure that all staff are involved in, and
committed to the EMS. It can also help to improve public perception of the company, one of
the benefits of implementing an EMS.
Documentation
All objectives, targets, policies, responsibilities and procedures should be documented along
with information on environmental performance. Documentation is useful for verifying
environmental performance to staff, regulators and the community. The control of
documents and versions should also be maintained for legal reasons.
Operational and Emergency Procedures
All procedures should be reviewed to ensure they are compatible with the organisation's
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environmental objectives and targets. Any changes should be included with the
documentation.
Environmental emergencies should have full procedures. Sometimes these are stipulated,
such as with the EPA Pollution incident Response Management Plans (PIRMP). The
operational conditions of the organisation need to be considered, including;
◗ acquisition, construction or modification of property and facilities
◗ contracting
◗ customer service
◗ handling and storage of raw materials
◗ marketing and advertising
◗ production and maintenance processes
◗ purchasing
◗ research, design, and development engineering
◗ storage of products
◗ transportation
◗ utility processes (e.g. energy and water supply, recycling and waste)
Checking
Review Audits and Monitoring Compliance
Review audits should be undertaken regularly to ensure the EMS is achieving its objectives
and to refine operational procedures to meet this goal. In order to ensure regulatory and
other requirements are being met, it is often necessary to undertake regular environmental
monitoring.
Compliance auditing
Compliance with statutory instruments is obviously critical as failure to comply can result in
significant consequence for the organisation. The compliance audit tool mentioned earlier is
one example of an audit tool that allows for compliance monitoring.
This type of auditing not only ‘screens’ the organisation for the obligatory statutory
instruments but also examines the following key operational compliances features;
◗ Conformity
◗ Non-conformity
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◗ Corrective action
◗ Preventative action
Figure 5.4 – Snippet of the NSW DECC Compliance Audit handbook.
Management review
An important component is continual improvement. An EMS comes into its best use when
used to review progress towards the targets and objectives set by a company to protect the
environment. The procedures set in place to meet these objectives should be constantly
examined to see if they can be improved or if more effective systems can be introduced.
Input to management reviews shall include;
◗ results of internal audits and evaluations of compliance
◗ communication(s) from external interested parties, including complaints
◗ the environmental performance of the organization
◗ the extent to which objectives and targets have been met
◗ status of corrective and preventive actions
◗ follow-up actions from previous management reviews
◗ changing circumstances
◗ recommendations for improvement
The outputs from management reviews usually include any decisions and actions related to
possible changes to environmental policy, objectives, targets and other elements of the
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environmental management system, consistent with the commitment to continual
improvement.
Benefits of an EMS
An EMS can assist a company in the following ways:
◗ minimise environmental liabilities
◗ maximize the efficient use of resources
◗ reduce waste
◗ demonstrate a good corporate image
◗ build awareness of environmental concern among employees
◗ gain a better understanding of the environmental impacts of business activities
◗ increase profit by improving environmental performance
Determining environmental aspects – EASO approach
Why the focus?
As is frequently detailed, this resource is designed to focus on the work performed by
environmental technicians. As such we need to focus on the determining of environmental
aspects, as this is related ultimately related to the environmental monitoring and to parts of
the Environmental impact Assessment processes. What follows is some of the tools that can
be used to determine this information.
The Standard AS NZS ISO 14015 - 2003 describes the overall process for conducting the
environmental assessment of sites and organisations.
Figure 5.5 – The overall EASO processes from the Standard
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The process of an Environmental Assessment of Sites and Organiations, or EASO, is designed
to provide a starting point for determining the environmental impacts that the operations
on a site or in an organisation have on the environment. The purpose of the assessment is
to be compliant with statutory instruments, but as mentioned earlier, the overall process of
environmental management does yield other direct and passive benefits to an organisation.
The general process for undertaking EASO is as follows;
◗ Planning
◗ Gathering and validating information
◗ Evaluating the data
◗ Reporting the outcomes
You should be able to see that even this process follows the PDCA cycle closely. It is these
key points that are outlined below. The Standard also states that the assessment may also
include the identification of business opportunities.
Planning an EASO
If the assessment is not planned properly, it is doomed to fail. The objectives of the
assessment need to be identified which could include just the impacts or just the possible
business opportunities or both.
The scope of the assessment also requires establishing, which means drawing boundaries
around the focus of the assessment areas, such as defining the categories of environmental
aspects to be assessed. Types of boundaries include;
◗ Areas of operation (i.e. boilers, transfer systems and tank farms)
◗ Categorising environmental aspects (air, water soil etc)
◗ Physical boundaries (i.e. land boundaries, council boundaries etc)
◗ Commercial boundaries (individual clients or products)
◗ Temporal restrictions (if operations are shift based or short term continuous)
◗ Compliance and consequence (focus only on licencing operations)
It is important to view this from both sides of the organisational fence, i.e. attempt to define
what needs to be assessed, but simultaneously view those operations, areas and times that
do not require assessment.
Other aspects to be planned include the assessment criteria which can include the current
and foreseeable statutory requirements, any and all organisational policies, procedures and
plans developed as part of the EMS and well as technological criteria such as volumes,
masses that are either based on current output or maximum output values based on the
engineering designs of the site or organisational design.
When all of the above is considered, the last stage of the planning is to draw up the actual
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assessment plan which would have the following key considerations;
Identifying the stakeholders involved
The assessment objectives and scope
The assessment criteria
The required resources for assessment
Organisational roles and responsibilities
The schedule of the assessment process
An outline of the reporting requirements
Gathering information
Once the assessment is planned, the next step is to collect all of the assessment
information, which is based on validated information gathered on the environmental
aspects through reviewing existing documents and records prior to and during a site visit, as
well as observing activities and physical conditions, and interviewing relevant people.
The process of gathering information on environmental aspects should be consistent with
the objectives, scope and assessment plans, ensuring that the information is sufficient,
relevant and accurate for the purpose of the assessment.
What information should be recorded?
The Standard outlines many examples of the types of information that can be collected
Refer to Practical help box No. 1, 2 & 3 from the Standard.
There are many tools available to help collect and gather information. These can include;
◗ Observation record sheets
◗ Matrix or spreadsheet designs
◗ Interview record sheets
◗ Videos, followed by video analysis
Evaluation of data
Once the gathering of the data has been completed, the information needs to be evaluated
to determine the actual or potential impacts to the environment. This process consists of
two steps;
◗ identifying environmental issues, and
◗ determining business consequences
At the discretion of the client, these two steps may be carried out by different parties,
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particularly when the client may require other expertise (e.g. technical, legal or financial) to
determine the business consequences. Consider the figure below;
Figure 5.6 – Copy of Figure 2 from the Standard. The numbers relate to section of the
standard.
Reporting
The final report will be consistent with the requirements of the organisation and follow their
structures and style guides. The content of the report and should present information in a
manner designed to understand the significance of the findings. To do this, the assessor
should distinguish fact from opinion, clearly identify the basis for the findings and indicate
the relative uncertainty associated with any finding.
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If defined in the scope, the report should provide sufficient documentation, including
references and key information, to support the findings contained in the report and to
enable re-evaluation of the assessment either at a later date or by another party.
Confidentiality should therefore be respected and appropriately safeguarded by the
assessor(s) and any report recipients.
An example tool for evaluating potential impacts
Examples of how certain activities in an organisation relate to or generate environmental
aspects from are contained in the tables from 14004 – 2004, part of which is below;
Figure 5.7 – Copy of Table A1 from the Standard
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Assessment
Required knowledge questions
This section provides formative assessment of the theory. Answer all questions by typing
the answer in the boxes provided. Speak to your teacher if you are having technical
problems with this document.
◗ Type brief answers to each of the questions posed below.
◗ All answers should come from the theory found in this document only unless the
question specifies other.
◗ Marks shown next to the question should act as a guide as to the relative length or
complexity of your answer.
A different assessment approach to assessment…
Because an EMS is a well-defined management structure, assessing students by simply
questioning the above information is somewhat pointless, so your assessment will involve
an analysis of a corporate document. An EMS is generally not visible to the public, so we will
use a Environmental Management Strategy which was a compliance procedure for the
approval of Orica’s Ammonium Nitrate Emulsion (ANE) plant at Richmond Vale (near Kurri
Kurri, NSW). Download the following documents and answer the following questions which
relate to matching the aspects of Orica’s EMS to the Standard and other methods.
1. How does the Orica EMS (O-EMS) apply the following sections of the Australian Standard
for EMS structure? For each section listed below, identify the corresponding section
form the Orica EMS and provide a brief explanation of the content.
The first question has been answered as an example of the required depth for each answer.
a. Which section of the O-EMS applies to Section 4.1 of the Aus. Std.? [0mk]
The implementation of a fully documented continual improvement program has been
demonstrated by section 1.1, 1.2 & 2.3. The creation of the Orica EMS by itself is an
application of section 4.1.
This answer is as deep as required for the question. It should not take longer than five lines
to answer any of the questions posed, but just quoting a section number is not an answer
and will be marked accordingly (as 0).
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b. Which section of the O-EMS applies to Section 4.2 of the Aus. Std.? [1mk]
Click here to enter text.
Assessor feedback
c. Which section of the O-EMS applies to Section 4.3.1 of the Aus. Std.? List the
nine environmental aspects that Orica identified from their assessment. [2mk]
Click here to enter text.
Assessor feedback
d. Which section of the O-EMS applies to Section 4.3.2 of the Aus. Std.? Also
identify the six pieces of legislation, regulation or EPI that Orica needed to
comply with? [7mk]
Click here to enter text.
Assessor feedback
e. Which section of the O-EMS applies to Section 4.3.3 of the Aus. Std.? Also
identify the three items that Orica objectives were based around. [4 mk]
Click here to enter text.
Assessor feedback
f. Using Table 2 from the O-EMS, what are Orica’s targets with regards to their
Environmental Protection Licence objectives? [1mk]
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Click here to enter text.
Assessor feedback
g. Which section of the O-EMS applies to Section 4.4.1 of the Aus. Std.? [1mk]
Click here to enter text.
Assessor feedback
h. Which section of the O-EMS applies to Section 4.4.2 of the Aus. Std.? [1mk]
Click here to enter text.
Assessor feedback
i.
Which section of the O-EMS applies to Section 4.4.3 of the Aus. Std.? [1mk]
Click here to enter text.
Assessor feedback
j.
Which section of the O-EMS applies to Section 4.4.4 of the Aus. Std.? [1mk]
Click here to enter text.
Assessor feedback
k. Which section of the O-EMS applies to Section 4.4.5 of the Aus. Std.? [1mk]
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Click here to enter text.
Assessor feedback
l.
Which section of the O-EMS applies to Section 4.4.6 of the Aus. Std.? [1mk]
Click here to enter text.
Assessor feedback
m. Which section of the O-EMS applies to Section 4.4.7 of the Aus. Std.? [1mk]
Click here to enter text.
Assessor feedback
n. Which section of the O-EMS applies to Section 4.5.1 of the Aus. Std.? [1mk]
Click here to enter text.
Assessor feedback
o. Which section of the O-EMS applies to Section 4.5.2 of the Aus. Std.? [1mk]
Click here to enter text.
Assessor feedback
p. Which section of the O-EMS applies to Section 4.5.3 of the Aus. Std.? [1mk]
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Click here to enter text.
Assessor feedback
q. Which section of the O-EMS applies to Section 4.5.4 of the Aus. Std.? [1mk]
Click here to enter text.
Assessor feedback
r. Which section of the O-EMS applies to Section 4.5.5 of the Aus. Std.? [1mk]
Click here to enter text.
Assessor feedback
s. Which section of the O-EMS applies to Section 4.6 of the Aus. Std.? [1mk]
Click here to enter text.
Assessor feedback
2. Generally speaking, how would Orica have used the EASO approach in the construction
of this document? Which section of the Orica document would the EASO have applied
to? [2mk]
Click here to enter text.
Assessor feedback
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Assessment & submission rules
Answers
◗ Attempt all questions and tasks
◗ Write answers in the text-fields provided
Submission
◗ Use the documents ‘Save As…’ function to save the document to your computer
using the file name format of;
Yourname-EMS-SM5
◗ email the document back to your teacher
Penalties
◗ If this assessment task is received greater than seven (7) days after the due date, it
may not be considered for marking without justification.
Results
◗ Your submitted work will be returned to you within 3 weeks of submission by email
fully graded with feedback.
◗ You have the right to appeal your results within 3 weeks of receipt of the marked
work.
Problems?
If you are having study related or technical problems with this document, make sure you
contact your assessor at the earliest convenience to get the problem resolved. The contact
details can be found at;
◗ www.cffet.net/env/contacts
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References & Resources
References
You are not required to read these references unless the question you are answering
requires it. Note that some of these resources might be available from the links provided in
the resources (below), your teacher or the library.
Bates, G. (2010). Environmental Law in Australia. Australia: LexisNexis-Butterworths.
EDO, NSW. (2005). Environmental law Toolkit - NSW. 5th Ed. Sydney, Australia: The
Federation Press.
Farrier, D. (. (2011). The Environmental Law Handbook. Sydney: Thomson Reuters.
Fisher, D. (2010). Australian Environmental law: norms, Principles and Rules. Australia:
Lawbook Company.
Lipman, Z. E. (2009). Environmental and Planning Law in New South Wales. Sydney,
Australia: The Federation press.
StandardsAustralia. (2004). AS/NZS ISO 14001:2004 Environmental Management Systems:
Requirements with guidance for use. Australia: Standards Australia.
Resources
◗ Information on environmental law can be found at the EDO here.
◗ Current Commonwealth legislation can be found here.
◗ Current State legislation can be found here.
◗ NSW environmental planning materials can be found here.
◗ NSW environmental protection information (EPA) can be found here.
◗ Commonwealth EPBC Act website is here.
◗ Local Government information can be found here.
Chemical, Forensic, Food & Environmental Technology [cffet.net]
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