Similarities and Differences

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Nov 8, 2013 (3 years and 9 months ago)

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Similarities and Differences
Among Environmental
Management Systems

Richard N. Andrews


Professor of Environmental Policy

Director, National Database on Environmental Management
Systems

University of North Carolina at Chapel Hill


MSWG Conference on “Learning Together,” June 4, 2001

NDEMS: A Joint Project of

The University of North Carolina at Chapel Hill

and


The Environmental Law Institute


Supported by the

U.S. Environmental Protection Agency


In cooperation with

the Multi
-
State Working Group (MSWG) on

Environmental Management Systems

National Database

on Environmental Management Systems

Purpose

To determine effects of ISO and other
environmental management systems on


Environmental performance/conditions


Economic performance


Regulatory compliance


Pollution prevention


Engagement with stakeholders

National Database

on Environmental Management Systems

Database Scope


50+ pilot facilities in 12 economic sectors


Business and government, large and SME


Implementing EMSs (ISO 14001 and others)


In 10 states



(AZ, CA, IL, IN, NC, NH, OR, PA, VT, WI)



Baseline (3 years) EMS design updates

National Database

on Environmental Management Systems

EMS Planning Process

Scope of EMS
Activities
Aspects
Impacts
Significance
e
Objectives
Targets
Environmental Policy
Need for Empirical Research


Actual use of ISO 14001 EMS procedure:


What activities, products, services included in
EMS scope?


What environmental aspects, impacts?


Which designated as significant, by what
processes and criteria?


What objectives and targets?


Implications for business, public expectations

Presentation


Comparison of EMS planning documents


Data from 40 facilities so far


Data Source: National Database on
Environmental Management Systems (NDEMS)

Should Expect Variation


Differences in sectors, operations


in size, scale, complexity


in environmental conditions


in competence, perceptions, priorities,
teamwork


in interpretation of the ISO 14001 standard

What Have We Found?

Activities


ISO 14001 Guidance
:


An organization should identify the various
activities
,
processes
,
products

or
services

that
are included in the scope of the EMS


Distinguishing them in such a way that they are
“large enough for meaningful examination and
small enough to be sufficiently understood.”

Activities: Findings


Great variation in characterization, detail


Majority defined activities as production
processes, on
-
site operations, business
functions


Examples:


Manufacturing, maintenance, construction,
housekeeping, grounds
-
keeping, transportation,
waste management

Activities: Findings


Some (15) identified more specific
processes and equipment operations


Examples:


Boilerhouse operations, rinsing, stripping,
molding, cleaning, extrusion, polishing , de
-
icing, forklift operation, aircraft refueling


A few (6) listed specific chemicals used:


Nitric acid, chlorine, cyanide, heavy metals,
alcohol, mercury, ...

Activities: Findings


Still others (6) listed specific resource uses
and waste streams


Use of electricity, water, raw materials


Waste generation, air emissions, wastewater
discharges, land contamination


A few: minute detail


Trash, cardboard, soiled rags


Drinking fountains, toilets, janitorial sinks,
shoveling snow

Activities: Findings


Few included
products

or
services


Nearly all focused on site
-
specific
production and support activities


Few mentioned life
-
cycle analysis, product
stewardship, sustainability

Aspects


ISO 14001 guidance:


Identify all environmental aspects of activities,
products and services


Aspect = element of activity, product or service
which can have a beneficial or adverse effect on
the environment


Include all those that the organization “can
control and over which it can be expected to
have an influence”

Findings


Aspects


Varied in characterization, specificity


More than half included more detailed
actions associated with each activity


25% simply duplicated activity lists


Three identified more detailed business
functions without environmental content

Example 1: AAIS Identification


-

Note discrimination of significance for some impacts

Activity
Aspects
Impacts
Significance
Synthesis
Chemical usage
Raw materials
no
Synthesis
Glassware disposal
Solid waste
no
Synthesis
Glassware cleaning
Cleaning agent disposal
no
Synthesis
Residue from reaction
Solid waste disposal
no
Synthesis
Residue from reaction
Hazardous waste disposal
yes
Synthesis
Cleaning from synthesis
Liquid hazardous waste disposal
yes
Synthesis
Column hardware
Solid waste disposal
no
Synthesis
Heat, oven
Energy use
no
Synthesis
Air emissions
Volatile solvents
no
Example 2: AAIS Identification


-

Note
every

identified impact ranked as significant


Activity
Aspects
Impacts
Significance
Facility operations
Air
Environmental impact
Yes
Facility operations
Air
Compliance
Yes
Facility operations
Hazardous waste
Compliance
Yes
Facility operations
Hazardous waste
Environmental impact
Yes
Facility operations
Hazardous waste
Money
Yes
Facility operations
Water
Compliance
Yes
Facility operations
Water
Environmental impact
Yes
Facility operations
Water
Money
Yes
Impacts


ISO 14001 guidance:


Organization should identify as many as
possible of the
actual

or

potential

environmental impacts associated with each
aspect of its activities


Impact = change which takes place in the
environment as a result of the aspect,
either
positive

or

negative

Impacts
--

Findings


Impacts usually described generically


Most (32) identified impacts only by 15
-
20
generic types, without details or quantification


Degradation of air, water, groundwater, soil


Use of energy, water, natural resources;


Generation of wastes, impacts on landfill capacity;
noise; wildlife habitat, endangered species

Impacts
--

Findings


A few mentioned others: cultural resources,
pathogens and vectors


Six included occupational health and safety


Only seven included
positive

environmental
effects


Can be important: e.g. natural resource
management, cleaner
-
production technologies

Significance Determination
--

Findings


Variation in procedures for determining


Also in actual judgments of significance


What is significant in the judgment of one
facility may not seem so to another


Major hazardous waste streams or air pollutant
emissions, versus snow
-
blower fuel and oil
-
contaminated Q
-
tips

Significance Ranking Judgments
and Procedures

Facility
Activity
Aspect
Impact
Significant
?
Basis
A
Mill
operations
Effluent
discharge
Nutrient
loading
Yes
Total rank score = 25
Mill
operations
Scrap board
Decreased raw
material use
Yes
Total rank score = 7.7
Mill
operations
Scrap board
Decreased
waste
generation
No
Total rank score = 7.0
B
Compressors
(product)
Compressors
(product)
Land
Yes
Impact rating = 334
Nitric acid
stripping
baths
Nitric acid
stripping
baths
Water
No
Impact rating = 174
pH
adjustment
pH
adjustment
Water
Yes
Impact rating = 39;
permitted activity
C
Oil-soaked
rags
Hazardous
waste
Release—soil
and water
Yes
Hazardous waste is
categorically significant
Municipal
trash
Solid waste
Depletion of
natural
resources
Yes
Solid waste has
immediate impact on
environment
Toilets
Wastewater
discharge,
water
consumption
Depletion of
natural
resources,
POTW
contamination
Yes
Semi-controlled potential
impact
Significance Ranking Judgments
and Procedures

Facility
Activity
Aspect
Impact
Significant
?
Basis
D
Lubrication
Waste
Q-tips with oil
or silicone
Yes
Worksheet: env. and
business considerations,
frequency, severity, cost
E
Air emissions
Regulated
sources
Potential
releases to
environment
Yes
Stringently regulated
Air emissions
Unregulated
sources
Potential
releases to
environment
No
Low level of regulation
Water use
Municipal
Natural
resource
depletion
No
Low cost, not regulated
from environmental
perspective
Objectives and Targets
--

Findings


Four distinct types of objectives and targets
identified:


Performance
-
oriented


Project
-
oriented,


Management activity
-
oriented


Compliance
-
oriented



A few others
--

no common category

Performance
-
based O & T

Example
Objective
Target
Target Date
A
Reduce hazardous air
pollutants by 10%
0.00048 lbs. of
HAPs per pound of
rubber processed (monthly
monitoring)
December 31, 2000
B
Reduce hazardous waste
by 10%
3,734 lbs. total (Average = 415 lbs.
per month; monthly monitoring)
December 31, 2000
C
Recycle industrial
waste (any item that
could be disposed of in a
sanitary landfill)
Recycle 58% of industrial waste
(monthly monitoring)
December 31, 2000
D
Minimize HAZMAT
incidents
Reduce
trichloroethylene spills to
zero
December 2000
E
Increase
eco-productivity
index for general energy
usage
Increase by at least 1.5 points in 2000
and 2001
July 1, 2000
F
Water conservation
Reduce water usage by 5% per
million gallons/pounds of product
from 1997 level
Not specified
Project
-
based O & T

Example
Objective
Target
Target Date
A
Reduce disposal costs
and future potential
liability for cleanup of
waste disposal sites
Substitute coolant containing
chlorinated paraffin
December 1999
B
Recycle antifreeze
Install antifreeze recycling system
Completed in 1998
C
Reduce mop water sent
as waste
Install evaporator with belt skimmer
for oil removal
December 1999
D
Eliminate
perchloroethylene parts
cleaning
100% elimination
June 1, 2000
E
Eliminate use of enamel-
based paint and solvents
Eliminate use of enamel-based paint
and solvents
Summer 1999
F
Stop
landfilling light
bulbs
Properly recycle/dispose of all light
bulbs
July 30, 1998
Management, Training, and
Awareness
-
Raising as O & T

Example
Objective
Target
Target Date
A
Reduce solid waste
disposal
Increase employee awareness
December 2000
B
Conduct quarterly safety
committee meetings
Conduct 2 meetings
January 1, 2000
C
Assess hazardous
materials and
environmental awareness
survey scores of
laboratory workers
See that scores demonstrate
improvement over life of the project
Not specified
D
Conduct training for
employees regarding
recycling
100% of all employees
March 2000
E
Manage vendor activities
concerning chemical
usage (assure vendors
invited to come to the
facility through the
Procurement Department
are aware of their
responsibilities)
Vendor notification sent to all
vendors who conduct
environmentally impacting operations
inside the plant
April 2000
Compliance Assurance O & T

Example
Objective
Target
Target Date
A
Decrease CN in
wastewater to eliminate
violations
CN concentration in effluent from CN
oxidation tanks 50% lower than
permitted, or 0/60 mg/L
January 1, 2000
B
Comply with FIFRA
Maintain contractor (grounds
maintenance) requirements
Not specified
C
Comply with permit for
… [34 separate
regulatory requirements
identified]
PM = 10.82 tons/year, VOC = 1.45
tons/year, pH = 6.0-9.0, … [etc.]
Not specified
D
Continue to implement
existing preventive
measures and spill
response procedures
Maintain preventive and response
measures
Not specified
E
Improve wastewater
pretreatment quality
Maintain BOD levels in our
wastewater discharge less than or
equal to 300 mg/l
Ongoing from 11/98
Other Considerations


Few included identifiable objectives related
to life
-
cycle analysis, product stewardship


Only three facilities specifically mentioned
risk reduction O & T


All for maintaining regulatory compliance


Very few involved external interested
parties


Target Dates


Target dates: three categories


Already accomplished (a few cases)


Coming year (2000
-
01)


“Continuous," “ongoing"


None mentioned any O & T for more than
two years in the future


Immediate, incremental, facility
-
level


No longer
-
term strategic objectives

Conclusions …


Facilities have great discretion in EMS design


In practice, EMSs vary significantly


Content

more important than certificate per se


Certification = organization
has

good
information easily available


Key issues: Internal versus external uses,
openness about performance

http://www.eli.org/isopilots.htm


ndems@unc.edu

National Database

on Environmental Management Systems