Environmental Management System

Transcription

1 Environmental Management System Area Noise Sampling Area Sampled By Job Classification Date Area Testing No. Sample Location/Task dba Comments/Notes 70

2 Environmental Management System Respirator Fit Test Employee Name Date Job Title/Description Type of Respirator: No. Make Model/Size Full or Half-Face Testing Protocol: Isoamyl Acetate Saccharin Aerosol Irritant fume Cartridge Type: Test Exercises (P=Pass, F=Fail): Normal Breathing Respirator No Deep Breathing Nodding Head Read Passage Jogging in Place Normal Breathing Overall Employee Signature Trainer Signature 71

3 Environmental Management System Process Tank Ventilation Date Measured By Class Exhaust Velocity Tank Hazardous 8 CCR 5154 (feet per minute) No. Tank Description Substances (Table V-7/8/9) Required Measured 72

4 Environmental Management System Laboratory Hood Ventilation Description of Hood Inspector Date Time _ Temperature Barometric Pressure Velocity Correction Diagram of Face of Hood Showing Sampling Areas Air Velocity Measurements of Sampling Areas No. Velocity No. Velocity No. Velocity Calculation of Volume Flow Rate Average Velocity Hood Face Area Volume Flow Rate 73

5 Environmental Management System Workplace Hazard Assessment Area Job Classification Assessed By Date Hazard Description Hazard Category Impact Penetration Compression (Roll-Over) Chemical Heat Harmful Dust Light (Optical) Radiation Estimate of Potential Injury Personal Protective Equipment Eye and Face: Head: Foot and Leg: Hand and Arm: Torso and Other: Comments/Notes: 74

6 Environmental Management System Employee Training Record Employee Name Job Title/Description Training Date Hours of Training Instructor Name [Check boxes for training received] ALL EMPLOYEES RIGHT-TO-KNOW / HAZARD COMMUNICATION Hazard Communication, Container Labeling, Material Safety Data Sheets GENERAL HEALTH & SAFETY Emergency Procedures and Evacuation, Injury and Illness Prevention Plan, Hearing Conservation, Confined Spaces, Lockout/Tagout, General Safety Rules, Codes of Safe Practice, Fire Prevention, Chemical Hygiene JOB SPECIFIC TRAINING Duties, Hazardous Materials, Workplace Hazards, Codes of Safe Practice, and Personal Protective Equipment Related to Employee s Specific Job Assignment PROCESS EMPLOYEES HAZARDOUS MATERIAL HANDLING Hazardous Chemicals, Personal Protective Equipment, Hazardous Materials Handling, Incompatible Materials, Spill Cleanup HAZARDOUS MATERIAL TRANSPORTATION Hazardous Material Classification, Shipping Containers, Labeling and Marking Containers, Shipping Documents, Hazardous Material Handling, Emergency Response HAZARDOUS WASTE HANDLING Identifying Hazardous Waste, Handling Hazardous Waste, Labeling Hazardous Waste, Shipping Hazardous Waste, Hazardous Waste Minimization HAZARDOUS WASTE TREATMENT Operation of Treatment Facilities, Shutdown of Waste Treatment Facilities, Emergency and Monitoring Equipment, Recordkeeping EMERGENCY COORDINATOR TRAINING Emergency Coordinator Authority and Duties RESPIRATOR TRAINING Respirator Selection, Use and Limitations of Respirator, Cleaning and Disinfection, Storage, Inspection and Maintenance Employee Signature certifying receipt of training described above Date Instructor Signature Date 75

7 Environmental Management System Facility Inspection Date of Inspection Time of Inspection Inspector Circle type of inspection: DAILY WEEKLY MONTHLY ANNUAL _Loading and unloading areas X Frequency Freeboard level in uncovered tanks Overfill/spill control equipment Tank monitoring data Hazardous materials/waste containers X X X X 76

8 Aisle space Incompatible material storage areas Safety suggestion box Hazardous material storage/transfer areas Hazardous material tank systems Hazardous waste treatment areas Storm water management structures Employer notices Posting of evacuation map / phone numbers Material safety data sheets Hazardous material/waste containers/labels Emergency alarms Fire extinguishers Emergency equipment and supplies Process area ventilation Housekeeping Employer posters and accident forms Emergency Response Plan review Hazardous material storage tanks X X X X X X X X X X X X X X X X X X X FREQUENCY: D-Daily, W-Weekly, M-Monthly, A-Annual 77

9 ELEMENT 2.3 OBJECTIVES AND TARGETS After you identify the facility s environmental aspects and impacts and regulatory compliance ISO/PT-1 requirements, objectives and targets should be established for the EMS. An objective is a facility goal that is consistent with the company s environmental policy, priority environmental aspects and impacts, and applicable environmental regulations. A target is a more detailed performance requirement ISO-1 related to and supporting a specific objective. In other words, specific targets must be met for an objective to be achieved. Examples Objective Reduce hazardous wastewater treatment sludge (F006) generation Improve chrome emission compliance Eliminate cyanide from all plating operations Improve employee awareness of environmental issues and costs Reduce energy consumption Target Reduce dragout from nickel plating baths by 25% within 18 months Continuously train 100% of chrome platers about chrome emission control procedures and recordkeeping Pilot test three non-cyanide chemistries within 12 months Hold bimonthly training courses Train 100% of employees within 12 months Reduce electricity use 15% within 12 months Reduce natural gas use 10% within 12 months Improve compliance with wastewater discharge permit limits Use process water more efficiently Zero permit violations by December 1999 Reduce water consumption by 20% within 12 months Continuously train all platers in good rinsing techniques ISO/PT-1 Add: and other voluntary ISO-1 Add: quantifiable where practicable 78 Element 2.3

10 The objectives and targets represent the transition from planning to action. The objectives and targets will drive many other EMS elements, particularly measurement and monitoring activities. For this reason, they should be carefully expressed and effectively communicated to all facility workers. In addition, input from facility workers is critical in developing objectives and targets Targets should be: Quantitative Realistic Linked to a source (of the waste or environmental aspect) Measurable that are meaningful and practical. Reviewing the objectives and targets at regular intervals provides a good opportunity to gauge progress, cost savings, and improved environmental performance. ISO-1 PT-1 There is one EMS procedure and several EMS tools associated with the objectives and targets element. The procedure, 2.3 Objectives and Targets, describes the process your facility should follow to develop and update its environmental objectives and targets. The EMS tools that support this procedure include a matrix that facilitates and documents the process of developing objectives, targets associated with those objectives, and parameters that will be measured to track progress made to meet the objective. Objectives and targets originate from: Environmental Policy Aspects and Impacts Review Compliance Checklist Corrective and Preventive Action ISO-1 Add: Those responsible for setting objectives and targets should consider significant aspects, legal and other requirements, technical options, financial, operational, and business requirements, and the views of interested parties. PT-1 Add: Additionally, the facility should consider preventing non-compliance, preventing pollution at its sources, minimizing cross-media pollutant transfers, and improving environmental performance. 79 Element 2.3

11 EMS Procedure 2.3 Effective Date Company Name Subject Objectives and Targets Purpose Step 1 This procedure is used to develop and update the objectives and targets that are addressed by the EMS. The environmental manager and other facility personnel selected by the environmental manager are responsible for developing the objectives and targets for the EMS. Objectives are ISO-1 facility goals that are consistent with the company s environmental policy, priority environmental aspects, and applicable environmental regulations. Targets are detailed performance requirements related to and supporting a specific objective. Targets should be quantitative, realistic, linked to the source, and measurable. Step 2 Step 3 Step 4 Step 5 Step 6 Objectives and targets will be developed and documented using the Objectives and Targets tools: Summary of EMS Objectives and Targets and Actions Planned and Taken to Achieve Objectives and Targets. Objectives and targets will be supported and tracked according to procedures described in Element 4.1, Measurement and Monitoring. The impact of corrective and preventive actions on objectives and targets will be evaluated and documented according to the schedule specified in the EMS. The environmental manager and other facility personnel will review and update the environmental objectives and targets according to the schedule specified in the EMS. Objective and target documentation will be retained at the facility in accordance with the company or EMS specific record retention policy. ISO/PT-1 ISO-1 Add: quantifiable ISO/PT-1 Add: Step 7 EError! Main Document Only.stablish and maintain Environmental Management Programs (EMPs) for achieving objectives and targets. The EMPs should designate responsibility and establish means and time frame. New projects should be reviewed to ensure that environmental management applies to such projects. 80 Element 2.3

12 Responsible Person: Signature and Date: 81 Element 2.3

13 Summary of EMS Objectives and Targets 1. Objective Target and Deadline Element 2.3

14 Objective and Target # Action Plan OBJECTIVE: TARGET: BASELINE: DEADLINE: Tracking Parameter Measurement Frequency ACTIONS PLANNED AND TAKEN Consider what type of actions you are evaluating to achieve targets for objectives. Are there pollution prevention alternatives such as source reduction, material substitution, in-process recycling, or waste minimization that could achieve your objectives and targets? Try to find an action that addresses the pollution source most directly. What type of action? Source Reduction Material Substitution In-Process Recycling Reuse Improved Treatment Waste Treatment Compliance Action 1: Deadline: Action Taken: Action 2: Deadline: Action Taken: Action 3: Deadline: Action Taken: Action 4: Deadline: Action Taken: Responsible Person: Responsible Person: Responsible Person: Responsible Person: 83 Element 2.3

15 ELEMENT 3.1 ROLES AND RESPONSIBILITIES An EMS should establish roles and responsibilities for environmental management. These roles and responsibilities must be clearly and effectively communicated to all employees. In addition, top management should designate an employee who (1) ensures that the EMS is established and implemented; (2) reports on the EMS s performance over time; and (3) works with others to modify the EMS when necessary. The structure of a business will have a direct effect on the organization of personnel responsibilities for the EMS. PT-1 Smaller businesses, such as many metal finishing facilities, have some advantages over larger businesses in creating an EMS team. For example, smaller businesses usually have less hierarchy, more direct lines of communication, and faster decisionmaking processes. Because many metal finishing employees often perform multiple functions, integrating environmental responsibilities with other functions can simplify the EMS structure and minimize use of resources. ISO-1 Procedure 3.1, Roles and Responsibilities, describes how to assign responsibilities and determine organizational roles for the EMS. The procedure can be implemented, in part, through the Responsibilities Matrix and Organizational Chart. The matrix and chart should be used to assign EMS responsibilities and can also be used to communicate these responsibilities to other people in the company. After EMS responsibilities have been assigned, it will be helpful to develop an organizational chart showing responsible employees, lines of communication and reporting, and any hierarchy that may be in place. PT-1 Add: The facility should have a defined procedure for providing appropriate incentives for personnel to meet the EMS requirements. ISO-1 Add: Management shall provide resources essential to the implementation and control of the environmental management system. Resources include human resources and specialized skills, technology, and financial resources. 84 Element 3.1

16 EMS Procedure 3.1 Effective Date Company Name Subject Roles and Responsibilities Purpose Step 1 Step 2 Step 3 Step 4 Step 5 This procedure is used to determine the organizational roles and personnel responsibilities for the company s EMS. The company will first designate an environmental manager whose role is to oversee company environmental activities. The environmental manager and other facility personnel selected by the environmental manager are responsible for implementing the EMS. ISO-1 The environmental manager will develop and assign EMS roles and responsibilities and document them using the Responsibility Matrix. The environmental manager will communicate EMS roles and responsibilities to all employees. The environmental manager and other facility personnel will review and update the EMS roles and responsibilities every 12 months ISO-2 Things to consider in developing and reviewing EMS roles and responsibilities: Capabilities of business Personnel involved Training and resources required Results of previous audits Improvement of current structure Integration with other business functions and existing management systems Roles and responsibilities documentation will be retained in accordance with the company or EMS-specific record retention policy. ISO-1 Change to: The company will designate an environmental manager whose roles are to oversee and implement the environmental management system and to report on the performance of the EMS to top management. ISO-2 Add: and report the performance to top management. 85 Element 3.1

17 Responsible Person: Signature and Date: 86 Element 3.1

18 RESPONSIBILITY Develop and distribute environmental policy Develop budget for environmental management Identify and prioritize environmental aspects Obtain and renew permits and develop compliance plans Comply with applicable regulatory requirements Track/analyze new regulations PERSONNEL RESPONSIBLITY MATRIX Fill in names and L (lead) or S (supporting) responsibilities to EMS team members using the possible positions listed Shop Environmental Plating Production Laboratory All Owner Manager Manager Supervisor Staff Maintenance Accounting Employees Other Establish environmental objectives and targets Develop EMS structure and identify personnel responsible Implement internal communication Coordinate external communication Train employees Integrate environmental metrics into performance appraisal process Coordinate emergency response efforts Track corrective and preventive action efforts Coordinate auditing efforts Conduct management review Responsible Person Effective Date 87 Element 3.1

19 (COMPANY NAME) EMS ORGANIZATION Example Organizations Responsible Person Effective Date 88 Element 3.1

20 ELEMENT 3.2 COMMUNICATIONS Communication is an important feature of a successful EMS. Active communication can increase the effectiveness of the EMS by (1) explaining environmental policy and how it relates to the overall business strategy; (2) motivating employees; (3) making sure roles and expectations are understood by all employees; (4) demonstrating management commitment; and (5) identifying potential system improvements. Both internal and external communications should be performed to ensure that environmental goals are met. Internal communication should explain the environmental policy and address the EMS roles and responsibilities delegated to employees as well as progress toward specific objectives and targets. This communication should possess mechanisms for top-down and bottom-up information flow. External communication is also an important element of the EMS. Communication with community groups and stakeholders in the business, such as regulators, local residents, stockholders, insurers, emergency responders, and customers interested in the environmental impacts of the business should be addressed and documented. By maintaining meaningful dialogue and a proactive approach with external parties, a company can more easily meet EMS and other business goals. Procedure 3.2a, Internal Communication, describes how and when to initiate and document internal communication. The procedure can be implemented, in part, through the Internal Communications form. Procedure 3.2b, External Communication, describes how and when to initiate and document external communication. The procedure is implemented, in part, through the External Communications form. Both Internal and External Emergency Communications can be implemented through the Emergency Responses Communications form. 89 Element 3.2

21 EMS Procedure 3.2a Effective Date Company Name Subject Internal Communication Purpose Step 1 Step 2 Step 3 Step 4 Step 5 Step 6 This procedure is used to ensure adequate internal communication about the EMS. PT-1 Identification of internal audiences should be performed. Internal audiences will include employees and other stakeholders of the business who play a role in everyday business operations. This may include contractors. The environmental manager will determine the type of information that needs to be communicated. This may be general EMS policy information, individual EMS responsibilities, or specific waste reduction targets and measurements. Methods of Internal Communication: Staff/employee meetings Newsletters Bulletin boards/posters Brown bag lunches Training Websites, s Based on the audience involved and type of information to communicate, the environmental manager will determine methods of internal communication. Initial forms of internal communication may include training, followed by meetings and postings in newsletters or bulletin boards. The environmental manager will determine the frequency of internal communication. Since the types of information being communicated will vary, the frequency with which the information will be communicated will also vary. The environmental manager and other facility personnel designated by the environmental manager will ensure that adequate internal communication occurs. Documentation of internal communications will be achieved using the Internal Communications and the Emergency Response Communications forms. All internal communication documentation will be retained at the facility in accordance with the company or EMS-specific record retention policy. PT-1 Change to: This procedure is used to communicate relevant information regarding the EMS, including the facility s environmental performance throughout the facility. 90 Element 3.2

22 Responsible Person: Signature and Date: 91 Element 3.2

23 EMS Procedure 3.2b Effective Date Company Name Subject External Communication Purpose Step 1 Step 2 Step 3 Step 4 Step 5 Step 6 This procedure is used to ensure adequate external communication PT-1 The environmental manager will identify external audiences. External audiences may include community members, customers, suppliers, and stakeholders in the company, such Methods of External as neighbors, community groups, local officials, Communication: insurers, stockholders, regulatory agencies, and emergency responders. The environmental manager will determine the type of EMS performance information that needs to be communicated. This may be company waste reduction successes, permit applications for new processes, or future plans to change business practices. Open houses Focus groups Press releases Annual reports Advertising Community meetings Permits/applications Website Based on the audience and the type of information to be communicated, the environmental manager will determine methods of external communication. The environmental manager will determine the frequency of external communication. The types of information and the frequency with which the information will be communicated will vary. The environmental manager and other facility personnel designated by the environmental manager will ensure that adequate external communication is occurring. External communications will be documented using the External Communications and the Emergency Response Communications forms. All external communication documentation will be retained in accordance with the company or EMS specific record retention policy. PT-1 Change from: to ensure adequate internal communication about the EMS to for sharing information with the community on EMS performance. 92 Element 3.2

24 Responsible Person: Signature and Date: 93 Element 3.2

25 INTERNAL COMMUNICATIONS Form of Communication Type of Information Frequency of Communication Audience Training Staff Meeting Individual Meeting Bulletin Board Newsletter Other Company Environmental Policy Identification of Environmental Aspects Prioritization of Environmental Aspects Compliance Awareness Targets and Objectives Individual EMS Responsibilities Process Change Emergency Response and Preparedness Measurement and Monitoring Corrective and Preventive Action Results of Audits and Management Review Other Responsible Person 94 Element 3.2 Effective Date

26 EXTERNAL COMMUNICATIONS Form of Communication Type of Information Frequency of Communication Audience Community Meeting Individua l Meeting Newsletter Advertising Annual Report Trade Group Other Company Environmental Policy Targets and Objectives for Waste Reduction Waste Reduction Successes Health and Safety Successes Preventive Actions Results of Audits and Management Review Future Company Changes Permit Applications Other Responsible Person Effective Date 95 Element 3.2

27 EMERGENCY RESPONSE COMMUNICATIONS Type of Emergency Chemical Release/Spill Worker Injury 911 Audience Emergency Responders Employees Community Fire Department National Response Center Fire Department Ambulance Hospital Notify by Sounding Alarm Telling to Vacate the Building Notify Neighbors Regulatory Agencies Coast Guard POTW EPA DTSC OSHA Other Natural Disaster 911 Fire Department Ambulance Hospital Other Responsible Person Effective Date 96 Element 3.2

28 ELEMENT 3.3 TRAINING Training is an important aspect of the EMS because it can be used to communicate to all employees (1) the environmental impacts of their Training Hints: Use opportunities like safety meetings, staff meetings, and production meetings to provide training and reinforce EMS goals. Consider videotaping training sessions for use later as refreshers or with new employees. Factor training needs and abilities into hiring practices. activities, (2) the company s environmental policy, (3) EMS roles and responsibilities, and procedures, and (4) methods and actions for reducing waste generation and meeting EMS objectives and targets. ISO-1 Because every employee plays an integral role in the function of a business, it is important that the training needs of all employees be evaluated and met at a level that enables them to support the goals of the EMS in their daily activities. Training should be based on the ISO-2 previous education, training, and work experience of an employee. ISO-3 ISO-1 Add: Training should also indicate the consequences of departure from specified operating procedures ISO-2 Add: employee s responsibilities as well as ISO-3 Add: Personnel performing tasks that can cause significant environmental impacts must be competent on the basis of education, training and/or experience. 97 Element 3.3

29 EMS Procedure 3.3 Effective Date Company Name Subject Training Purpose This procedure is used to develop and implement a training program that (1) complies with environmental regulations requiring training and (2) addresses high-priority environmental aspects and objectives and targets. PT-1 Step 1 Step 2 A training program will be developed. This program will identify training topics, who should receive the training, when training should be given, and the training method. The program will also distinguish between training conducted to comply with environmental regulations and other training. Training Resources: A critical first step in developing a training program is to assess employee training needs. The environmental manager and others will review past training and the nature of the employee s work. Based on this review, specific training requirements for each employee or type of employee will be documented. Internal trainers Consultants Educational institutions Suppliers/vendors Technical/trade associations Self study Computer-based training PT-1 Change: (2) to: provides general environmental awareness for all employees, and and add: (3) provides specific training for those whose jobs and responsibilities involve activities directly related to achieving objectives and targets and to compliance with legal requirements. 98 Element 3.3

30 Step 3 Step 4 Step 5 The training program will be implemented and training dates, subjects, and attendees will be documented. ISO-1 Training documentation will be retained at the facility in accordance with the company or EMS-specific record retention policy. When Training is Needed: New hire New job/change in employees role or responsibility Procedure change New process, material, or equipment New regulation Increase employee performance Training effectiveness will be evaluated to ensure that the EMS is being implemented effectively. Improvements to trainings will be made accordingly. Responsible Person: Signature and Date: ISO-1 Add: Elements to be covered in the training include: 1) the importance of conformance with the environmental policy and procedures and with the requirements of the environmental management system; 2) the significant environmental impacts, actual or potential, of their work activities and the environmental benefits of improved personal performance; 3) the roles and responsibilities to achieve conformance with the environmental policy and procedures and with the requirements of the environmental management system, including emergency preparedness and response requirements; 4) the potential consequences of departure from specified operating procedures. 99 Element 3.3

31 TRAINING NEEDS Employee Name: Job Function(s): Date: Training Completed: Training Required: 100 Element 3.3

32 TRAINING PROGRAM YEAR JOB FUNCTIONS Topic Title Platers Maintenance Waste Treatment Lab Shift/Line Supervisors Management EMS Awareness Supervisor EHS Training Hazardous Waste Management Wastewater Treatment Spill Prevention & Response Chemical Handling Emergency Response Dragout Reduction Hazard Communication Personal Protective Equipment Fire Safety Electrical Safety Hearing Conservation Job-Specific Training (List) Enter dates or frequency of each training. Responsible Person Effective Date 101 Element 3.3

33 ELEMENT 3.4 EMS DOCUMENT CONTROL The purpose of EMS document control is to ensure that the facility creates and maintains documents in a manner and to the extent necessary to implement the EMS. The primary focus of the organization should be effective EMS implementation, not a large documentation control system. There are several types of documents that are integral to the EMS, including the environmental policy and various written procedures, records, and forms used to implement the EMS. Document control ensures that EMS documents can be easily located, periodically reviewed and updated as needed, and removed when obsolete. Controlled documents should be centrally located at your facility, usually with the environmental manager. ISO-1 In addition, controlled documents should feature the following characteristics: Effective date Approval signature and date Copy number (if more than one controlled copy is required) Document control should usually be the responsibility of one person, usually the environmental manager. Procedure 3.4 describes document control. ISO-1 Change to: Current versions of relevant documentations should be available at all locations where operations essential to the effective functioning of the EMS are performed. The EMS should specifically control all documents to ensure that: They can be located; They are periodically reviewed; Current versions are available; Obsolete documents are promptly removed and assured against unintended use; and Any obsolete documents retained for legal preservation, etc are clearly identified as such. 102 Element 3.4

34 Company Name EMS Procedure 3.4 Effective Date Subject EMS Document Control Purpose Step 1 This procedure governs EMS document control. The environmental manager is responsible for EMS document control. EMS documents that are addressed by this document control procedure may include the following: The environmental policy All EMS procedures (including this one) The following completed EMS Template forms used to implement EMS procedures: Environmental aspects tables Compliance self-assessment checklist Compliance calendar Objectives and targets matrix Organizational chart Training needs Emergency, internal, and external communication Step 2 Step 3 Step 4 Step 5 The controlled EMS documents listed in Step 1 will be designated by headers and/or footers with the following: Effective date Approval signature and date The controlled EMS documents listed in Step 1 will be maintained in a binder or file under the safekeeping and control of the facility environmental manager. The collection of controlled EMS documents will contain an index of all documents and a distribution list that identifies other facility personnel who should receive copies of EMS documents. The index of controlled EMS documents will be updated whenever one of the documents is revised. 103 Element 3.4

35 Responsible Person: Signature and Date: 104 Element 3.4

36 ELEMENT 3. [NEW] EMS DOCUMENTATION ISO/PT-1 EMS Documentation describes what comprises your systems, which is supported by the EMS records. The documentation is important to the success of your EMS for several reasons: Consistency. Word-of-mouth information is rarely communicated consistently, whereas written information is more likely to be constant from person to person and over time. Documentation is vital to maintaining consistency in an EMS over time and from department to department. Since change occurs so frequently, accurate documentation makes it easier to maintain an effective and flexible EMS. Assessment of Progress. Creating documentation helps you assess the progress of your EMS. Some inconsistencies show up only as you commit your ideas to paper and having a record allows you to check on progress and evaluate results. EMS Documentation includes: Demonstration. Documentation demonstrates that your EMS is complete and functioning. Environmental Policy Key EMS elements Organizational chart Tables of key responsibilities System-level procedures Activity or process-specific operational control procedures/work instructions Compliance Checklist Corrective and Preventive Action Other EMS-related document Audit Findings ISO/PT-1 Please note: The template needs an additional element (as suggested here in 3.NEW), entitled EMS Documentation that directs users and provides guidance about establishing and maintaining information, in paper or electronic form, which describes the core elements of the management systems and provides direction to related documentation. 105 Element 3.NEW

37 EMS Procedure 3.NEW Effective Date Company Name Subject EMS Documentation Purpose Step 1 Step 2 This procedure governs EMS documentation. The environmental manager is responsible for EMS documentation. Before beginning documentation steps, the environmental manager will research the existing documentation. The goal of this search is to locate materials you can use to begin your EMS implementation and documentation. The environmental manager will determine the detail needed in the documentation. The manager may use the following questions as guidelines for creating new documentation: How can we use or revise existing documents rather than creating new ones? Does our business operate in a single location or many? This will affect who creates some of the documents and where they are located. It may also affect how many versions of a document might be necessary to cover different circumstances. What is our current computer capability? Many companies use an electronic system to maintain documents. What security precautions do we need? While computer systems are handy, they often can be accessed by a number of people. Electronic documentation can be edited or destroyed. Security, or at least restrictions on who can change data, can be a critical issue for many companies that use electronic documentation systems. Step 3 The environmental manager will decide the format (document and page appearance) for the EMS documents. This may be the existing company standard, if it exists, or a new standard. The manager will consider whether pages are single- or double-sided and why; choose margins, header, footer, typefaces, text, headings, etc. Include plans for bulleted and numbered lists, tables, and even paragraph spacing. Step 4 The manager will also consider what is needed for the document and design each document template by creating an outline. The manager will also consult those who actually use the documents. Involving them in the process should help make sure the documents are usable and applied to support the EMS. Responsible Person: Signature and Date: 106 Element 3.NEW

38 Documentation Worksheet A Is there existing EMS documentation? How is this EMS documentation maintained? (Electronically? Paper?) Who is responsible for maintaining EMS documentation? Does the EMS manual or other summary documents describe the key elements of the EMS? If so, does this document describe the linkages among system elements? What does the EMS documentation consist of? (List components such as environmental policy, EMS manual, activity-level procedures or work instructions, emergency plans, etc.) Is the EMS documentation integrated with other organizational documentation (such as human resource plans or quality procedures)? If so, how is proper coordination between environmental and these other functions ensured? How do we ensure that the EMS documentation is up-to-date? 107 DOCUMENTATION WORKSHEETA

39 Documentation Worksheet B Documents Determine Format: Who/ Date Completed Develop Prototype/ Draft: Who/ Date Completed Assign Writing: Who/ Date Review Writing/ Compare to Prototype/Draft: Who/ Date Added to Document List/ Date Who Has Access Where Located Existing Documents / / / / / / / / / / / / / / / / / / / / Documents to be Created / / / / / / / / / / / / / / / / / / / / Contact Person: Date Completed: 108 DOCUMENTATION WORKSHEET B

40 ELEMENT 3. [NEW2] OPERATIONAL CONTROL ISO-1 To ensure that you satisfy the commitments in your environmental policy, certain operations and activities must be controlled. Where operations or activities are complex and/or the potential environmental impacts are significant, operational controls should include operational control procedures. Procedures can help your organization to manage its significant environmental aspects (SEAs), ensure regulatory compliance, and achieve environmental objectives. Procedures can also play an important role in employee training. The company should plan operations and activities, including maintenance, in order to ensure that they are carried out under specified conditions by: 1. Establishing and maintaining documented procedures to cover situations where their absence could lead to deviations from the environmental policy and the objectives and targets; 2. Stipulating operating criteria in the procedures; and 3. Establishing and maintaining procedures related to the significant environmental aspects of goods and services used by the company and communicating relevant procedures and requirements to suppliers and contractors. Operational control may improve the management of the following types of activities: Management/disposal of wastes Approval of new chemical use Production processes or operations Storage & handling of raw materials and chemicals Wastewater treatment ISO-1 The template needs an additional element, entitled Operation Control (as show in 3.NEW2, that directs user s to identify those operations and activities that are associated with the identified significant environmental aspects. 109 Element 3.NEW2

41 Building and vehicle maintenance Transportation Operation and maintenance of equipment Marketing and advertising Acquisition or construction of property and facilities 110 Element 3.NEW2

42 EMS Procedure 3.NEW2 Effective Date Company Name Subject Operational Control Purpose Step 1 Step 2 This procedure governs Operational Control of the organization. The environmental manager will determine the possible causes of a potential impact for all significant environmental aspects. The environmental manager will also set targets and measurement indicators for each objective. The targets will reflect correction of the cause identified in Step 1. Using measurement indicators, you can determine if your operational controls are helping you meet your objectives. Step 3 Each aspect that could potentially deviate from environmental policy and objectives and targets requires a documented procedure. Some of the documented operation control procedure may already exist. The environmental manager will identify those procedures that exist and those that need to be developed. In some cases the procedures that you have in place to comply with environmental and health and safety regulations may be useful to meet your EMS objectives. The manager will consult with those implementing the procedures when developing them. To do this, the manager will: Meet with staff and have them describe current procedures. Discuss the environmental objective desired and obtain their input on operational controls procedures to ensure that the objectives will be met. Have a staff member interview the workers to establish current documented or undocumented procedures. Once you have drafted or revised operational controls, have the staff and a manager review it and incorporate their input. Step 4 Step 5 Step 6 The manager will then designate responsibility for maintaining and reviewing operational controls to ensure that procedures are followed and deviations are corrected. A training program will be developed to ensure that everyone understands the controls and their role in ensuring that they are followed. Training can include on-the-job training. Finally, when objectives are not met, corrective action is taken to correct failures in operational controls as quickly as possible to meet environmental objectives. 111 Element 3.NEW2

43 Responsible Person: Signature and Date: 112 Element 3.NEW2

44 Operational Control Worksheet Have we identified operations and activities associated with significant environmental aspects, legal and other requirements, and environmental objectives? If not, how will this be accomplished? Who should be involved? What operations and activities are associated with significant environmental aspects? What operations and activities are associated with legal and other requirements? What operations and activities are associated with environmental objectives and targets? How are the above operations and activities controlled? Are the controls are adequate? How do we train employees and contractors on relevant operating controls? If new controls are needed (or existing ones need to be revised), what is our process and who is involved? 113 OPERATIONAL CONTROL WORKSHEET

45 ELEMENT 3.5 EMERGENCY RESPONSE AND PREPAREDNESS Most metal finishing facilities have experienced an event that required some kind of emergency response. Unfortunate events such as an employee injury, a spill of hazardous chemicals, or a fire do occasionally occur. With the large number of hazardous chemicals and the potential for accidents inherent in a manufacturing setting, metal finishing facilities should be particularly vigilant in planning and preparing for ISO-1 emergencies. Emergency planning can limit injuries; protect employees, neighbors and the environment, reduce asset losses, and minimize downtime. An effective emergency response and preparedness program should include provisions for: Assessing the potential for accidents and emergencies; Preventing incidents and their associated environmental impacts; Responding to incidents ISO-2 Mitigating impacts associated with these incidents ISO-3 Procedure 3.5, Emergency Response and Preparedness, describes the personnel responsible for completing emergency preparations and incident reviews, and how and when the tasks will be completed. There are many overlapping requirements in local, state and federal regulations concerning emergency response and preparedness. Helpful Documents: Often, the most difficult part of developing emergency Process flow diagrams preparedness and response plans is identifying the potential for accidents and emergencies. The Plant maps environmental manager should form a team composed Drainage plans of company personnel (and outside consultants or regulators if necessary or beneficial) to examine all Design codes and standards facility activities. Extend your evaluation beyond those facility materials and operations that are obviously or inherently dangerous; ask what if questions under both normal and abnormal conditions. ISO-1 Add: as well as responding to ISO-2 Add: Reviewing and revising where necessary emergency preparedness and response procedures, in particular, after the occurrence of accidents or emergency situations ISO-3 Add: Testing procedures periodically, where practicable. 115 Element 3.5

46 No tool is provided for this element because the tools and forms associated with emergency response and preparedness are already included as part of the documents required by federal, state, and local regulations. 116 Element 3.5

47 EMS Procedure 3.5 Effective Date Company Name Subject Emergency Response and Preparedness Purpose Step 1 Step 2 Step 3 Step 4 Step 4 Step 5 This procedure is used to anticipate, document, prepare, and review emergency events and preparedness plans ISO-1 The environmental manager and other facility personnel selected by the environmental manager are responsible for identifying dangers, taking proactive steps to prevent emergency incidents, and completing tasks in preparation for emergencies. The environmental manager will prepare and update an Emergency Response Plan that contains all emergency procedures required by local, state and federal regulatory agencies. The environmental manager will familiarize and train employees and emergency coordinators on the procedures described in the Emergency Response Plan. Following each emergency incident, the environmental manager, emergency coordinators and the involved employees will determine the cause of the emergency, evaluate the response to the incident, and identify actions to be taken to minimize its recurrence. ISO-2 At least twice per year, the environmental manager and other facility personnel will review the Emergency Response Plan and any emergency incidents that ISO-3 ISO-4 occurred since the last review. Documentation concerning emergency response and preparedness and emergency incidents will be retained at the facility for at least 5 years. ISO-1 Add: and to periodically test response procedures. ISO-2 Add: Additionally, they will review the response and mitigation procedures, and revise as necessary. ISO-3 Change from: and any emergency incidents that occurred since the last review to and update or revise the Plan for new equipment and processes, etc. ISO-4 Add: Step 5 As practicable, the facility will run a simulate emergency to test procedures. Following the simulation, the environmental manager and other staff involved will evaluate the procedures and revise, as necessary. 117 Element 3.5

48 Responsible Person: Signature and Date: 118 Element 3.5

49 ELEMENT 4.1 MEASUREMENT AND MONITORING Basing decisions and operational improvements on quantified environmental performance data is an important part of the EMS approach and a central feature of both quality management programs and EMSs. If the primary goal of an EMS is to improve environmental performance through consistent compliance and waste reduction, there must be measurable parameters, or metrics, that reflect environmental performance trends. After objectives and targets are created, specific parameters must be identified and measured to track progress toward the objective and target. For example, if CN-bearing wastewater is a highpriority environmental aspect and CN-bearing wastewater reduction is an objective, with a target of 10 percent reduction in the next 12 months, then parameters must be identified and periodically measured to determine if the target is reached. In this example, typical parameters that could be included in a measurement and monitoring program are volume and concentration of CN-containing rinse water and dragout volume from CN-containing process baths. There are also several important facility-wide metrics that should be used to monitor environmental performance. An Excel spreadsheet is included as a tool to record and chart facility metrics. Suggestions for target-specific metrics and a procedure for measuring dragout are also discussed. ISO-1 Target-Specific Metrics Target-specific metrics are unique to your facility s objectives and targets. Examples of metrics that relate to common objectives and targets are listed below. Copper concentration (measured using conductivity) in final rinse after acid copper plating Percentage of rejected parts requiring stripping Duration of storage before disposal of waste sludge Weekly volume of chrome dragout recovered and returned to plating bath Concentration of cyanide in wastewater as a percentage of allowable limit ISO-1 Add: Additionally, it is important to ensure that monitoring equipment is functioning and measuring properly by calibrating at least as frequently as manufacturing specifications recommend. 119 Element 4.1

50 Percentage of measurements of chrome tank surface tension below allowable limit Dragout is the primary source of waste in metal finishing, and dragout from particular tanks is often linked to specific objectives and targets. Because of its importance for understanding process efficiency and its impact on operating costs, metal finishers should measure dragout. Facility Metrics Eight facility metrics that provide at-a-glance information about environmental performance are identified in the table below. Metric Rejects/rework rate Water use Wastewater discharge quality Treatment residuals Chemical use rate Bath dumps Energy use Production Description Process rejects and associated rework generate up to three times the waste of an acceptable part because waste is generated (1) the first time the parts are processed (through dragout losses), (2) when the parts are stripped, and (3) the second time the parts are processed. Rejects also affect quality and customer satisfaction. Water is an important natural resource used by metal finishing operations, and its use is directly related to wastewater generation. Water use objectives are common to many EMSs. The Strategic Goals Program established a water reduction goal of 50 percent from a baseline year (typically 1992). Wastewater is usually the largest environmental release from a metal finishing facility. Treated wastewater quality (measured by contaminant concentrations) is regulated by discharge permits; therefore, measurement and monitoring of contaminant concentration is important for both compliance and pollution prevention. Wastewater treatment residuals include sludge from conventional chemical precipitation treatment systems and saturated resin canisters from ion exchange treatment systems. These waste streams contain most process chemicals lost through dragout and are therefore important metrics to track the impact of dragout reduction techniques. Treatment residuals are also expensive to manage and dispose of and present potential long-term liability concerns. Process chemicals used in metal finishing baths are lost or wasted through dragout to rinse water that must be treated and discharged. If dragout is reduced, fewer chemical additions are required. This metric tracks process efficiency and waste generation from the perspective of raw material use; the monthly or weekly quantity and cost of the top five to ten process chemicals added to process baths are recorded and charted. In addition to dragout, periodic bath dumps are the other main source of metal finishing wastes. Spent baths usually require batch treatment or are bled into the on-site wastewater treatment system both treatment methods generate a sludge requiring offsite disposal. In addition, extending bath life will reduce chemical purchases. Energy (electricity, natural gas, or other power source) is a primary resource used by metal finishers. Energy use is important to track the effects of efficiency initiatives. A measure of production is needed to determine whether trends in other metrics are a result of changes in production. For example, it is important to know that reductions in water or chemical use or sludge generation are caused by process changes, not production declines. Examples of production metrics are number of parts plated, revenue, number of racks processed, amp-hours. 120 Element 4.1

51 EMS Procedure 4.1 Effective Date Company Name Subject Measurement and Monitoring Purpose This procedure is used to implement a measurement and monitoring program designed to support the EMS and specific EMS objectives and targets. ISO-1 Step 1 The environmental manager and key facility production staff will track the following facility metrics by collecting and charting data relevant to the metric at the frequency indicated below. Facility Metric Rejects/Rework Rate Water Use Wastewater Discharge Quality Treatment Residuals Chemical Use Rate Bath Dumps Energy Use Production Data Collection Frequency Step 2 Step 3 Step 4 The environmental manager and key production staff will identify and measure unique parameters for each EMS objective and target. The environmental manager or designee will measure, monitor, and record targetspecific parameters at a predetermined frequency. The environmental manager will ensure that monitoring equipment is calibrated at least as frequently as recommended by the manufacturer. These records shall be retained in accordance with the company or EMS-specific record retention policy. The environmental manager and key facility staff will review facility and targetspecific measurement and monitoring data every 3 months to identify trends, evaluate progress toward meeting EMS objectives and targets, and discuss overall ISO-1 Change from: This procedure. to: This procedure is used to monitor and measure on a regular basis the key characteristics of the facility s operations and activities that can have a significant impact on the environment. 121 Element 4.1