790 Environmental Management Systems (EMS)

Step 12: Establish Other System-Level Procedures

An Environmental Management System (EMS) must include clear, simple procedures so daily work runs smoothly and risks are controlled. The EMS team must write, approve, and share these procedures. The organization should implement the operational controls identified under Step 10 to minimize environmental impacts.

Other system-level procedures include:

Emergency Preparedness and Response

• Scope: Address onsite hazards such as flammable liquids, storage tanks, compressed gases, and dangerous chemicals.
• Plan Content: Evacuation routes, alarms, spill response steps, fire protection, medical response, and roles during off-hours.
• Equipment: Maintain spill kits, absorbents, fire extinguishers, and emergency shutoffs; inspect on a set schedule.
• Training and Drills: Conduct drills at least annually; train new hires within their first week.
• Coordination: Share site maps and contacts with local responders; review after any incident.
• Records: Keep drill logs, inspection checklists, and incident reports for defined retention periods.

Training and Competency

• Who Needs Training: Employees whose work involves significant environmental aspects (e.g., fueling, solvent use, waste handling, stormwater controls).
• Frequency: New-hire onboarding, job-change training before new tasks, and annual refreshers.
• Topics: Environmental policy, significant aspects and impacts, spill prevention, waste segregation, emergency response, and reporting.
• Competency Checks: Short quizzes, hands-on demos, and supervisor sign-off before independent work.
• Records: Keep attendance, quizzes, and qualification matrices.

Environmental Communications

• Internal: Use toolboxes, dashboards, and intranet posts to share performance, incidents, and changes.
• External: Assign a spokesperson for regulators, community partners, and media; preapprove messages.
• Issue Escalation: Define when to notify management, safety, legal, and operations.
• Feedback: Provide an easy channel for employees to report hazards or ideas; track responses.

Document Control and Records Management

• Control: Assign unique IDs, version numbers, and owners for policies, procedures, SOPs, and forms.
• Access: Store current documents in a single shared location; remove or watermark obsolete versions.
• Retention: Set retention times for training records, inspection logs, waste manifests, monitoring data, and audits.
• Change Management: Require review and approval before publishing updates; record the reason for change.

EMS Audits (Internal and External)

• Schedule: Create an annual audit plan that covers all EMS elements and high-risk operations.
• Auditor Competence: Use trained, independent auditors who are not responsible for the area being audited.
• Method: Use checklists, interviews, and sampling of records; rate findings by risk.
• Reporting: Issue a written report with strengths, nonconformances, and improvement ideas.

Corrective and Preventive Action (CAPA)

• Trigger: Start CAPA for audit findings, incidents, near-misses, complaints, or missed targets.
• Root Cause: Perform a simple analysis (e.g., 5 Whys) before choosing actions.
• Actions: Define interim risk controls, permanent fixes, owners, due dates, and verification steps.
• Effectiveness: Verify results with data or observation; close only when risks are reduced.

Management Review and Reporting

• Frequency: Provide EMS status reports to top management at least semiannually; use a standard format.
• Content: Policy, objectives and targets, KPIs, audit results, incidents, compliance status, resources, and risks.
• Decisions: Record approved changes to objectives, budgets, staffing, and timelines.

Operational Controls and Standard Operating Procedures

• Purpose: Translate environmental requirements into simple steps for daily tasks.
• Examples: Fueling and refueling, solvent handling, stormwater Best Management Practices (BMPs), dust control, and equipment washing.
• Verification: Use checklists and supervisor observations; track completion rates.

Contractor and Supplier Controls

• Prequalification: Screen for environmental performance and proper licenses.
• Onboarding: Provide site rules, emergency procedures, and waste requirements before work starts.
• Monitoring: Perform spot checks; require incident reporting within defined timeframes.

Waste, Hazardous Materials, and Storage Procedures

• Labeling and Segregation: Label containers, segregate incompatible materials, and keep closed when not in use.
• Inspections: Check storage areas weekly for leaks, corrosion, and secondary containment capacity.
• Shipping and Manifests: Verify profiles, manifests, and licensed transporters before shipment.

Performance Measurement and Key Performance Indicators (KPIs)

• Core Metrics: Energy use, water use, fuel consumption, waste generation, recycling rate, spills, and findings closed on time.
• Targets: Set annual objectives with baselines and owners; post results monthly.
• Data Quality: Define sources, calculation methods, and review steps.

Training Matrix Example (Who, How Often, What Topics)

• Operators (fueling, solvents): At hire and annually — spill prevention, PPE, waste segregation, emergency response.
• Supervisors: At hire and annually — incident reporting, corrective and preventive action (CAPA), KPI tracking, coaching for compliance.
• Maintenance and Custodial: At hire and annually — chemical storage, less-toxic products, secondary containment, floor drain controls.
• Fleet Managers: At hire and annually — petroleum reduction strategies, idling limits, preventive maintenance, telematics.
• Procurement: At hire and every two years — environmentally preferable purchasing and supplier screening.

Audit and CAPA Workflow (Simple Steps)

• Plan: Publish the annual audit schedule and scope.
• Perform: Conduct the audit; record objective evidence.
• Report: Issue findings with risk ratings and due dates.
• Fix: Complete root cause and corrective actions.
• Verify: Check effectiveness; close the finding.
• Trend: Review patterns and update procedures if needed.

These system-level procedures give structure and clarity. Each procedure must state purpose, scope, responsibilities, steps, documents used, training needs, and records kept. When the EMS team follows this framework, the organization improves performance and reduces risk.

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