Purpose

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Environmental Management
Environmental Management Systems (EMSs) have become a valuable tool for increasing the utilization of resources by organizations throughout the world. An EMS is simply a methodical approach to minimize the adverse environmental impacts of an organization. The most effective EMSs integrate environmental compliance and pollution prevention with the business management concept of continuous improvement. The continuous improvement model most frequently recognized is “Plan, Do, Check, Act.”¹

By integrating environmental compliance, pollution prevention and a continuous improvement model, any organization can develop an EMS that will eventually enable them to perform in a business model that exceeds the minimal regulatory requirements and has become known as “beyond compliance.” Performing beyond compliance often leads to significant cost savings that can become a competitive advantage for an organization. These cost savings are realized when an organization begins to implement pollution prevention initiatives to reduce the cost of operations and, possibly, their regulatory obligations. To continually improve their environmental performance, an organization will retain the original pollution prevention initiatives that provided environmental, operational and/or economic benefits and continue searching for additional opportunities. This can lead to doing more than the regulations require – performing beyond compliance.

Regardless of current compliance status, any organization that desires to obtain a potential competitive advantage can develop an EMS. While an organization that needs to improve their performance from noncompliance to compliance may initially experience some additional costs, the additional costs do not compare to the potential liability of noncompliance. As an organization moves from noncompliance to compliance, they begin to reduce their adverse impacts on the environment and improve their economic stability by reducing their potential risk of significant fines and penalties, as well as criminal and civil lawsuits. In contrast, organizations that are already in compliance will be able to more quickly gain the competitive advantage that can be provided by an EMS. But, organizations satisfied to simply comply with their regulatory obligations will never achieve the competitive advantages or opportunities to become more sustainable that can be presented by an EMS.

The development of an EMS, therefore, is a logical step for any organization that wants to increase the efficiency at which they utilize their financial, technological and human resources while minimizing their impact upon the environment. It is important to realize that for an EMS to be effective, it must be integrated within the customs and culture of the organization. In other words, the environmental considerations should become a part of the routine day-to-day business activities and operations of the organization.

Many private and public sector organizations have successfully implemented EMSs into their business activities and moved beyond compliance. The Department of Environmental Protection (DEP) believes that a college or university that engages an EMS would be beneficial to both the clientele and staff of the facility as well as nearby residents and the Commonwealth as a whole.

Strategy to Utilize EMSs
Not all EMSs provide the same level of environmental benefits and protection. In order for an EMS to be useful as a planning and operating tool, it must be founded upon the principles of environmental compliance, pollution prevention and continuous improvement, and it must be integrated within the performance expectations of an organization. The key components of a successful EMS is its adherence to the three ‘C’s. These are:

Conformance
     Meets the requirements
     (Implements the “shalls” of your criteria)
Consistency
     Various elements inter-related
     (i.e.: significant aspects reflected in emergency planning, etc.)
Continual Improvement
     Mechanisms in place to improve
     (Including fixing non-conformances and improving performance)

ISO 14001 is an international standard that describes the necessary components for an effective EMS. Although certification to ISO 14001 is not a domestic or international trade requirement of any government, many companies are placing certification requirements on their suppliers and business associates to reduce their exposure to environmental liability.

Certification to the ISO 14001 standard can be obtained by the use of an accredited registrar, or through self-declaration. Regardless of the manner in which an organization is certified to ISO 14001, the standard provides a useful platform for the development of an EMS and is therefore used herein.

The most logical way to ensure these expectations is to have the EMS conform with the ISO 14001 standard and to contain the following components:

• Policy (What the organization wants to do, “commitments”)
• Planning
  • Aspects (The organization’s environmental character)
  • Legal and Other Requirements (Knowing what laws and regulations apply)
  • Objectives and Targets (Improvement goals)
• Implementation/Operation
  • Structure and Responsibility (Deploying the system throughout the organization)
  • Training Awareness and Competence (Deploying the system throughout the organization)
  • EMS Documentation
  • Document Control
  • Operational Control (Ongoing control of significant aspects)
  • Emergency Planning and Response (Management and planning for unexpected occurrences)
  • Communication
• Checking/Corrective Action
  • Monitoring and Measurement (Ongoing evaluation of the system, including legal compliance)
  • Conformances, Corrective and Preventive Action (Ongoing fixes to the system)
  • Records
  • EMS Audits (Periodic spot checks of system)
• Management Review (Fixing problems, continual improvement)

Implementation
In order to follow the ISO 14001 framework, an analysis of a hypothetical college/university campus was undertaken by the team. Although efforts were taken to be as inclusive as possible, it is to be realized that there is considerable variety possible based on such variables as:

• Size;
• Location;
• Age of Campus; and
• Surrounding Community.

The analysis progressed through the following levels:

These are the functions and efforts that go on at the college and university. They should be all-inclusive – covering physical plant operations, education, purchasing, etc. Each and every one of these activities interacts with the environment to varying degrees.

There are generally several aspects to each activity. They relate the activity to its interaction with the environment. For example, if we use the activity of driving a car, its aspects would include consumption of a fossil fuel, release of pollutants to air, etc. Where possible, aspects should be identified for the entire life cycle of the activity from raw material to waste streams. It is necessary to understand the aspects in order to assign impacts. It is very important to remember that aspects are value neutral: they are neither good nor bad, but exist independently of this concept. Goals will be formulated to address the aspects, to improve or eliminate negative impacts, and enhance positive impacts. Avoid the urge at this point in the analysis to skip directly to impacts. Managing impacts alone is costly and inefficient unless you understand the underlying activity that caused it to occur. Determining the aspects first will help in capturing all of the impacts and provide a superior direction for planning. In order to be most effective at this step keep the following in mind:

• Be comprehensive in your inventory and do not be concerned with potential problems or solutions.
• Consider all aspects – good, bad, current, and potential.
• Sort lists by activity, this will simplify planning later.
• There is no right or wrong way to do this step, group as you see fit.

Impacts are any change to the environment, whether adverse or beneficial, wholly or partly resulting from an organization’s activities, products, or services. These can include but are not limited to health concerns, toxicity, employee exposure, resource depletion, storage or transportation concerns, regulatory requirements, environmental improvement, etc. These impacts do have values associated with them and can be good, bad, or neutral.

Do not be concerned at this point with problem solving. Be as comprehensive as possible in considering all of the associated impacts. Impacts will repeat under various aspects, just as various aspects repeat under each activity. This process inherently moves from the few to the many and back to the few.

An aspect will be evaluated for its significance using the following criteria and scoring. It is understood that the overall score may not be representative of the complete picture. For example, an aspect may score very high on severity, but low on public perception and frequency, thereby appearing to be insignificant although the environmental damage would be unacceptable. Therefore, in order to be significant, an aspect must have a total score greater than an established threshold OR any one category scores the maximum number of points. However, regardless of score, regulated issues are identified under legal and other requirements and are addressed accordingly.

The criteria represent the various issues associated with an aspect and how they relate to actual or potential environmental impact. Aspects that are deemed significant will be addressed by the management system, including operational controls and objectives and targets.

It is assumed that each institution has a system in place already to plan and implement policy and procedure, and this document will not presume to cover this area. We do stress that an EMS works best when it is periodically reviewed, and that these reviews occur annually at a minimum. As goals are met, the entire process should be reviewed again, as the significance criteria will bring new projects to the fore. It is important to remember that this process is likened to an upward spiral rather than a flat circle and each time through the process brings new environmental improvement.