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Implementation Guide Management System document sample
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Environmental Management
System Implementation
The Draft Navy EMS Implementation Guide
25 July 2002 Workshop
Topics
What is EMS? Tami McVey, CNO N451G
Plan/Do/Check/Act Andrew Kissell, NAVFAC, Atlantic
Division
Pre-Planning John Cece, Potomac Hudson
Policy Chris Fafard, Potomac Hudson
Planning Chris Fafard
Implementation Jerry Peters, Potomac Hudson and
Jim Steinberg, NAVFAC, Atlantic
Division
Check & Corrective/ Brian Stockmaster,
Preventive Action NAVFAC, Southern Division
Management Review Brian Stockmaster
Wrap-up Tami McVey
What is an EMS?
Tami McVey
Executive Order 13148—Greening the Government
through Leadership in Environmental Management
• April 21, 2000
• PART 4 — Promoting Environmental Management and
Leadership
• Mandates EMS across ALL 16 agencies in the Executive
Branch
• All facilities by 2005
• Planning based on “Aspects”
Policy and Guidance
• OPNAV 5090.1B, CH-2, Chapter 20, 9 Dec
99
• EQA Guide, 31 Aug 99 (check phase of
PDCA cycle)
• CNO EMS Policy memo, 6 Dec 01
• DOD EMS Policy memo, 5 April 02
• Draft Navy EMS Implementation Guide,
July 02
EMS Definition
OPNAVINST 5090.1B Ch-2
That part of the overall management
system which includes organizational
structure, planning activities,
responsibilities, practices, procedures,
processes and resources for
developing, implementing, achieving,
reviewing and maintaining the
environmental program, and achieving
environmental goals.
Key Components of
Navy & DOD EMS Policies
• Public commitment to environmental compliance, pollution
prevention, and continual improvement of the management
system
• Integrated planning, including goals and targets for reducing
environmental impacts and supporting mission priorities
• Operations to assure attainment of those goals and targets,
and training to ensure individual competence and
responsibility
• Procedures for self-evaluation and corrective action, and
including identified needs in budget processes
• Periodic review of the management system by senior
leadership
Elements of Navy EMS
• Environmental Policy • Implementation
• Planning – Structure, Responsibilities and
– Legal Requirements and Programs
Voluntary Commitments – Training
– Practices,Aspects and Impacts – EMS Documentation,
– Pollution Prevention Document Control and
Opportunities Records
– Objectives & Targets – SOPs
– PPBS
– Emergency Preparedness and
• Evaluation Response
– Monitoring and Measurement • Management Review
– Problem/Cause Identification &
Corrective/Preventive Action
– EMS Review
EMS In-Place by 12/05 means:
• EMS Description Document/EMS Manual
– Environmental policy
– Organizational structure and key responsibilities
– A description of how the organization satisfies EMS
requirements
– Objectives and targets
• At least one documented Management Review
– By Installation/Region Senior Management
Is EMS suitable, adequate, and effective?
Looks at results of audits, extent to which objectives
and targets are met, performance measures
Addresses needs for changes to policy, objectives and
elements of the EMS
Navy EMS to Minimize Risk to Mission
• Our operations and activities that we use to accomplish
mission pose risk to environmental resources
• When we adversely impact environment, we risk
– Regulatory agency censure
– Loss of public support
– Loss of access to training sites
– Shutdown of operations and activities
– Unnecessary cost and wasteful use of manpower
• EMS means:
– Identify impacts to the environment and risk to mission
– Concentrate on reducing risk/improving performance in
highest risk areas first
– Everyone’s job--Practice owner understands how his/her
practice impacts environment & how to control the impacts
Why Implement An EMS?
• Meet DoD/Component requirements
• Address admin and operational deficiencies
• Use data to make risk
management decisions
• Mission integration
• Facilitate turnover
• Increase command level attention
• Assist, train, support vs. police or do
• Analyze & prevent vs. detect & correct
What elements are lacking?
• Inventory of practice impacts/aspects
• Risk analysis integrating mission
• Priorities: targets, objectives, measures of success
• Communication protocols
• EMS Documentation
• Delegation/accountability – Practice Owners
• Senior management review
Keys To Success
• Management commitment
• Buy-in
• Compliance assurance and pollution
prevention
• Training at all levels, frequently
• Clear objectives, reiterated
• Performance and accountability
• Measurement and improvement
Plan, Do, Check, Act
The continual improvement cycle
•Plan
•Act •Do
•Check
NOVs by Root Cause
PPBS
Training
1%
9% System Failure - project
10%
System Failure - action Facility/Equipment Design
9% 16%
Multi-cause
Management Emphasis 6%
16%
Supplies & Contracts
4%
Plans and Procedures
29%
Analysis of all Navy NOVs received Oct 97-Mar 00 (293)
Navy Environmental Compliance Posture
100
80
Detect/correct
plateau
60
Compliance
40
%
20 Claimant $$
RCRA CERCLA
WPCA ECEs FFCA Regionalization
1970 CAAA1980 RCRAA 1990 CAAV 2000
CAA SDWA CWA Base Closures
Paradigm shift EMS
detect analyze
correct prevent
consolidate delegate
comply manage improvement
media focus process focus
separate integrate
dictate involve
inspection accountability
competitive cooperative
police assist
efficiency effectiveness
reactive Transformation plan, do, check, act
fire fighters managers fire preventers
squeaky wheel high risk
How?
Enter the improvement cycle at any point.
•Plan
Policy
Objectives, Targets
Gap, Aspect analysis
Revise targets Requirements, PPBS
Update SOPs P2
•Act
Retrain •Do
Improve policy Document control
Incorp. new standards Delegation, SOPs
Corrective, preventive action Methodology
Communication
•Check
Monitoring, Internal/External assessment, Oversight,
EMS/management review, reporting (measurement)
Risk Objectives
Policy &
Plan Targets
Implementation strategy
Turn-
Do over
SOPs
Training
IAP
Check POUCL
Act
Comprehensive Objectives
Risk
Policy &
Plan Targets
Turn-
Do over
SOPs
Training
IAP
Check POUCL
Act
Risk
Plan Policy S
e
l
e
Turn-
Do over t
i Training
v
e
IAP
Check POUCL
Act
Implementation Strategy
Depends on Goals
• Meet requirements
• Improve practices
• Share responsibilities
• Management involvement
• Integrate w/ mission
• Ease turnover
• Early success
Implementation Strategy
Depends on Available Resources
• Staff
• EFD/A
• Region
• Contract
Models for Export/Adaptation
• Web site as an implementation tool
• Support Team: Region, EFD/A,
Contractor
• EMS Guide
Web Site
• Training Modules by claimant/region
• Skill levels: management, environmental
staff, process/practice owner
• Sample products: POUCLs, Turnover books,
IAPs, SOPs, Policies, Risk analyses, etc.
• Clearinghouse: news, policy, forum
Implementation Support
• Regional POC: consistency, resource
support, advocacy
• EFD/A: on-site assistance, Web site
maintenance, consultation, training
• Contractor: on-site assistance, staff
extension, expertise
EMS Guide
• Step by Step approach
• Policies & Purpose
• Elements and Terms
• Tools & Templates (examples)
• Gap filling orientation
• Integration w/IAP
Pre-Planning
EMS Implementation Strategies
• What ?
– All 16 EMS elements in sequential order
– Start with individual elements
• Where ?
– Limited geographic area
– Select organizations or units
Command Support
• Stress benefits to mission
– Make risk-based decisions
– Improve environmental performance
– Improve public image and relationship with
regulators
– Improve environmental awareness, facilitate
personnel turn-over
• Describe proposed scope and strategy
EMS Team
• Commanding Officer
• Environmental Quality Board (EQB)
• Environmental office
• Environmental POCs
Gap Analysis
• Compare existing environmental policies,
procedures, and programs against the
components/elements of the Navy’s EMS
• Could identify gaps as
– Implemented and documented
– Implemented but not documented
– Documented but not implemented
– Not documented and not implemented
Implementation Plan
• Analyze results of gap analyses and develop
plan to “fill” gaps in EMS
• Plan should contain: what – who - when
• Future DoD metric (hint, hint)
Getting Started
• Do what you can with existing resources
• Everything does NOT have to be done at
once
• EMS = continual improvement
• Deadline is 31 December 2005 – but you
can and should start NOW
Elements of the Navy EMS
• Present each Navy EMS Element
• Based on Draft Guidance
POLICY
Environmental Policy Statement
PLANNING
MANAGEME NT RE VIEW Lega l Requirements
Practices, Aspects, Impacts
Manage ment Review Pollution Prevention Opportunities
Objectives and Targe ts
PPBS
CHECKINGA ND CO RRECTIVE/
IMPLEMENTATION
PREVEN TIVE A CTION
Monitoring and Measurement Structure, Responsibilities, and Progra ms
Problem/Cause Identification and Training
Corrective/Preventive Action EMS Documentation, Document Control, & Records
EMS Review Communication
Standard Operating Procedures
Emerge ncy Preparedness & Response
POLICY
Environmental Policy Statement
PLANNING
MANAGEME NT RE VIEW Lega l Requirements
Practices, Aspects, Impacts
Manage ment Review Pollution Prevention Opportunities
Objectives and Targe ts
PPBS
CHECKINGA ND CO RRECTIVE/
IMPLEMENTATION
PREVEN TIVE A CTION
Monitoring and Measurement Structure, Responsibilities, and Progra ms
Problem/Cause Identification and Training
Corrective/Preventive Action EMS Documentation, Document Control, & Records
Policy EMS Review Communication
Standard Operating Procedures
Emerge ncy Preparedness & Response
Planning
Implementation
Checking & Corrective Action
Management Review
Environmental Policy Statement
• Sets environmental direction and goals
• Basis for objectives and targets
• Most installations have an environmental
policy in place
Policy-First Steps
• Develop or revise environmental policy
statement
• Ensure senior management participation in
process
POLICY
Environmental Policy Statement
PLANNING
MANAGEME NT RE VIEW Lega l Requirements
Practices, Aspects, Impacts
Manage ment Review Pollution Prevention Opportunities
Objectives and Targe ts
PPBS
CHECKINGA ND CO RRECTIVE/
IMPLEMENTATION
PREVEN TIVE A CTION
Monitoring and Measurement Structure, Responsibilities, and Progra ms
Policy Problem/Cause Identification and
Corrective/Preventive Action
EMS Review
Training
EMS Documentation, Document Control, & Records
Communication
Standard Operating Procedures
Emerge ncy Preparedness & Response
Planning
Implementation
Checking/Corrective Action
Management Review
Requirements
• Environmental staff currently track new and
changing environmental requirements
• Installations may not:
– Translate requirements into procedures and
checklists useful to practice owners
– Negotiate/establish responsibilities
– Provide point of use training on
procedures/responsibilities
Requirements-Current Resources
• RECS and NAVFAC
• Internet resources including:
– Federal Register (http:/www.gpo.gov/nara/index.html)
– NFESC (regdesk@nfesc.navy.mil)
– DENIX (http://128.174.5.51/denix/dod/dod.tml)
• NES checklists
Requirements-Relationships
Track Negotiate/Assign Implement
Requirements Responsibilities Checklists
Establish Point of Use
Procedures Training
Plan Do Check
• Most installations do not translate requirements
into procedures, responsibilities, and POU training
understandable and usable by practice owners.
Practices, Aspects, Impacts-
Concepts
Mission
Activities/
Operations
Practices
Aspect Aspect Aspect
Impact Impact Impact
Resource Resource Resource
Practices, Aspects, Impacts-
Inventory
• Installations have an EQA inventory in place:
– Practices
– Practice Owners and Locations
– Compliance Inspection and Oversight Evaluation
Frequencies and Responsibilities
• Need to make comprehensive and add:
– Aspects
– Impacts
Practices, Aspects, Impacts-
Relationships
Inventory Monitoring and
Measurement
Risk-Based Objectives Actions,
Priorities and Targets Projects
Plan Check
• Inventory is basis for risk evaluation and objectives
and targets
• Inventory is basis for EQA Internal Assessment
Practices, Aspects, Impacts-
First Steps
• Update existing EQA inventory with aspects and
impacts information
• Initially may not be comprehensive
• Goal to get EMS implementation underway
• Follow implementation strategy
established in Pre-Planning phase
Risk to Mission
Mission
Activities/
Operations
Practices
Aspect Aspect Aspect
Impact Impact Impact
Resource Resource Resource
Impacts and Risk
Impacts Potential Risks to Mission
Degrade natural Diminished utility for training operations
areas Adverse public perception or noncompliance
Potential mission shutdown.
Noncompliance/ Fines
regulatory Mission stoppage
action Lose access to critical resources
Distraction and ine fficient use of personnel resources
Adverse public Lawsuits
perception Mission stoppage
Lose access to critical training areas
Distraction and ine fficient use of personnel resources
Human health Increased sick time
and safety Personnel injury and death
effects Decreased individu al performance
Practices, Aspects, Impacts -
Risk Ranking
• Evaluate relative risk to mission to
prioritize practices/aspects
• Process should be: repeatable, documented,
defensible, and periodic
• May apply qualitative approach
initially and apply quantitative
method later
Pollution Prevention
Opportunities
• Navy installations have mature P2 Programs
in place
• The practice inventory may suggest P2
opportunities not considered within the
traditional HW/industrial process focus of
P2
Pollution Prevention
Opportunities- First Steps
• Review practice inventory for P2
opportunities
• Apply P2 approach to identify and develop
solutions for:
– Industrial practices not previously identified
– Non-industrial practices
– Environmental aspects
Objectives and Targets
• Objectives define an end-state supportive of
the installation’s environmental policy goals
• Targets are detailed performance standards
that quantify each objective
• Should be achievable and
measurable
• Periodically review and revise
Objectives and Targets-Types
Objective Type Examples
Emphasizing 40% reduction in pounds of hazardous wastes
CNO and DoD disposed by the end of FY05, based on an FY02
metrics baseline.
Zero spills of oil product to U.S. waters.
Improving Develop and distribute SOPs for high risk
management of practices by first quarter FY03.
environmental Revise P2 Plan to incorporate new practices
programs or EMS identified during EMS practice inven tory
elements development by May 02.
Driving Reduce VOC air releases installation wide by
implementation 10% per year through FY07, from FY02 baseline
of risk-mitigation levels.
projects Eliminate oil discharges to Muddy Creek.
Objectives and Targets-
Relationships
Environmental
Policy Goals
Requirements
Objectives Media
Risk-Based and Targets Programs
Priorities Actions,
Projects
Mission, Local
Conditions
Plan Do
Actions and Projects
• Actions - behavioral/administrative initiatives or
outside support within the CO’s means
– Realign existing R/R
– Develop and provide training or procedures
– Secure NAVFAC support
• Projects - initiatives requiring external funding,
requested and justified through PPBS
– P2 investments
– Studies
– Plan development
Actions and Projects-
Relationships
Risk-Based
Priorities
Actions Monitoring and
Objectives
and Targets Measurement
POM Projects
Programs
Plan Do Check
POLICY
Environmental Policy Statement
PLANNING
MANAGEME NT RE VIEW Lega l Requirements
Practices, Aspects, Impacts
Manage ment Review Pollution Prevention Opportunities
Objectives and Targe ts
PPBS
CHECKINGA ND CO RRECTIVE/
IMPLEMENTATION
PREVEN TIVE A CTION
Monitoring and Measurement Structure, Responsibilities, and Progra ms
Policy Problem/Cause Identification and
Corrective/Preventive Action
EMS Review
Training
EMS Documentation, Document Control, & Records
Communication
Standard Operating Procedures
Emerge ncy Preparedness & Response
Planning
Implementation
Checking/Corrective Action
Management Review
Structure: The EMS Team
• Designated by Installation/Regional
Commander
• Includes Senior Management (EQB)
– CO/XO’s of installation and tenants
– Department/Division managers
– Environmental office manager
• Includes Technical Support and EMS
Implementation
– Media managers and other environmental office staff
– Environmental POCs
EMS Team may include personnel from
• Tenants • Quality
• Production • Human Resources
• Maintenance • Environmental
• ROICC • Safety and Health
• Supply • Public Affairs
• Comptroller
• BOS Contractors
Structure: Environmental Office
• Media programs
– Mature
– Already in place
• EMS elements in place
– P2
– Legal requirements
– Emergency response
– PPBS
– Training
Structure: Practice Owners
• “Command, unit, or office that uses a
practice to accomplish its mission”
• Authority to accomplish their mission using
a practice responsibility to control its
aspects
• Accountability = Responsibilities +Authority
4
Accountability = Responsibilities +Authority
EMS Environmental Practice
Team Office Owners
EMS
Elements
4
Media
Programs
Practices
4
Training -Current
• Required by Regulation
– Media related: HW worker, WWTP operation,
asbestos worker, emergency response
• Job Related
– Generally for environmental staff: NEPA,
ERMS, computer skills
Training for EMS Implementation
• Initial EMS Team Training
– Senior Management
– Environmental Support Staff
• Practice Owners Training
– Environmental SOPs
– Video
– Interactive
– Web
EMS Description Document
• Include installation EMS Policy
• Demonstrates & communicates implementation
– Objectives and targets
– Organizational structure and key responsibilities
– EMS elements
– Incorporate or provide a roadmap to information
supporting each EMS element
Communication
• Internal
– Senior management’s role
– Environmental staff translate requirements into
procedures and distribute to practice owners
– Mechanism for practice owners to
communicate with Environmental Office
• External
– Public Affairs Office
Environmental SOPs
• Document for each practice
– Location, owner, POC
– Aspects and potential impacts
Environmental SOPs
• Document for each practice
– Location, owner, POC
– Aspects and potential impacts
– Requirements, Procedures, Responsibilities for
• Operational control
• Communications
• Emergency preparedness and response
• Inspection
• Training
Environmental SOPs
• Document for each practice
– Location, owner, POC
– Aspects and potential impacts
– Requirements, Procedures, Responsibilities for
• Operational control
• Communications
• Emergency preparedness and response
• Inspection
• Training
– Design, capacity, inputs
– Physical controls, P2 options, and BMPs in place
Tailored Environmental SOPs
• Practice owners need to know or provide
– Location, owner, POC
–
– Procedures, Responsibilities for
• Operational control
• Communications
• Emergency preparedness and response
• Inspection
• Training
Emergency Preparedness & Response
• Plans prepared, not distributed
• Training up to date ??
• Distribute procedures in Environmental
SOPs
POLICY
Environmental Policy Statement
PLANNING
MANAGEME NT RE VIEW Lega l Requirements
Practices, Aspects, Impacts
Manage ment Review Pollution Prevention Opportunities
Objectives and Targe ts
PPBS
CHECKINGA ND CO RRECTIVE/
IMPLEMENTATION
PREVEN TIVE A CTION
Monitoring and Measurement Structure, Responsibilities, and Progra ms
Policy Problem/Cause Identification and
Corrective/Preventive Action
EMS Review
Training
EMS Documentation, Document Control, & Records
Communication
Standard Operating Procedures
Emerge ncy Preparedness & Response
Planning
Implementation
Checking/Corrective Action
Management Review
Monitoring and Measurement
• Sampling and analysis
• Internal assessment efforts
• Tracking progress in meeting objectives and
targets
Problem/Cause Identification
Corrective/Preventive Action
• Review results of internal assessment
efforts
• Conduct “problem solving”
Problem/Cause Identification
Corrective/Preventive Action
• Suggested “problem solving” approach
– Define problem
– Analyze root causes
– Develop alternatives
– Select corrective action
– Develop corrective action
– Implement corrective action
– Follow-up
EMS Review
• Answer two questions
– Does the EMS, as described in the EMS
Description Document, meet current Navy
criteria?
– Does the EMS, as implemented, effectively do
what the EMS Description Document says it
will do?
POLICY
Environmental Policy Statement
PLANNING
MANAGEME NT RE VIEW Lega l Requirements
Practices, Aspects, Impacts
Manage ment Review Pollution Prevention Opportunities
Objectives and Targe ts
PPBS
CHECKINGA ND CO RRECTIVE/
IMPLEMENTATION
PREVEN TIVE A CTION
Monitoring and Measurement Structure, Responsibilities, and Progra ms
Policy Problem/Cause Identification and
Corrective/Preventive Action
EMS Review
Training
EMS Documentation, Document Control, & Records
Communication
Standard Operating Procedures
Emerge ncy Preparedness & Response
Planning
Implementation
Checking/Corrective Action
Management Review
Management Review
• Analyze results of following
– EMS review
– Internal assessments
– Status of corrective/preventive actions
– Progress in meeting objectives and targets
• Implement improvements to EMS
– Revise policy
– Revise objectives and targets
– Revise EMS procedures
– Document results
Conclusions
• You already have a lot elements in place
– Requirements
– P2
– Programs
– PPBS
– Emergency Response
– Checking and Corrective Action (EQA
Program)
Conclusions
• Initial EMS improvements you can do
– Designate EMS Team
– Obtain/provide initial EMS training
– Develop/distribute Policy
– Add aspects and impacts to practice
inventory
– Conduct risk evaluation
– Develop objective and targets
– Complete EQA implementation
Questions?
Discussion
