Now that we've reviewed the planning phase, let's talk about the implementation phase. During this step, you do the things that you’ve planned. In this module, we’ll take a look at the various elements in the implementation phase:
The first activity includes defining a management structure and associated roles and responsibilities for the EMS. The groundwork for this activity was laid during the planning phase, when environmental management programs are designed to achieve objectives and targets.
That's right, the steps build on, and support, each other. For the EMS, roles and responsibilities should be defined, documented, and communicated at all levels to facilitate effective implementation.
To ensure EMS roles are established and associated activities take place, job-specific EMS responsibilities should become a part of each individual's job description. Incentives also can be used - for example, some facilities provide incentives for employees to meet EMS requirements, through reward and recognition programs.
EMS education and training are key activities for implementation.
EMS education is usually online or classroom instruction. The goal of EMS education is to help employees become aware of key EMS concepts and why it is important to the success of the organization.
EMS training may be online, in the classroom, or hands-on instruction. The primary goals of EMS training is to each employees how to do something. Be sure employees demonstrate the necessary skills to safely perform tasks by using on-the-job (OJT) training. The OJT method is very important for any procedure that might cause an injury, illness or property damage. You can learn more about this training method in OSHAcademy Course 723.
Because EMS concepts are new to many employees and impact their daily activities, you can't expect success unless you teach them about our EMS and what they can and must do to support it.
Job-specific training is tailored to job types to ensure that workers understand the significant environmental aspects of their job functions and the potential impacts of not following EMS instructions. The training also reviews the benefits of improved environmental performance. For example, such training may include instruction on how to manage hazardous waste properly. Where EMS objectives and targets require changes to equipment or operations, workers also need to be trained regarding the changes required in how they perform their jobs.
Another important element of the implementation phase is communication. This includes both internal and external communication to support continual improvement with respect to environmental protection.
Internal communication: It’s important to focus on communication within the organization. Communication channels must be created to ensure the personnel who need information at any level and function will receive the necessary information in a reasonable time frame. Personnel must also be able to forward suggestions and concerns about the EMS to those management personnel that can appropriately address such issues.
It is quite helpful to allow all personnel the authority to identify system nonconformance or regulatory noncompliance and report issues to the person responsible for managing the corrective and preventive action process. This helps to foster continual improvement. Of course, this only works well if employee suggestions and comments are appreciated and rewarded.
Examples of Internal Communication include:
You should also identify external stakeholders and have implement regular communication with them regarding your EMS. This group includes customers, vendors, suppliers, neighbors, and regulators. More importantly, you should have a procedure to receive and document external concerns and ensure an appropriate response in a timely manner. Here are some of the ways you can communicate with our external stakeholders:
Another activity in in the implementation phase is two types of documentation:
The first item includes your EMS manual, which describes the core elements of your EMS and provides direction to related documentation like management procedures, work instructions, and forms.
Part of document management includes identifying each EMS document and its document retention period.
Because documentation is so important, you should have a specific EMS Document Control procedure to manage EMS documents, including:
Also, develop and describe the means and controls you will use to make sure EMS documentation is up to date and readily available to all employees. The EMS Document Control Procedure describes how to manage EMS documentation. It describes how documents are periodically reviewed and revised and how obsolete documents are promptly removed from all points of issue and use.
The EMS Document Control Procedure should address how EMS documents will be:
Operational controls ensure that operations and activities do not exceed specified conditions or performance standards, or violate applicable regulations such as discharge limitations. The need for operational controls is based on the significant aspects and legal requirements identified earlier.
Operational controls are used to support the EMS and can be:
For aspects that need to be controlled, review whether existing physical controls, engineering controls, and administrative controls are sufficient. If they are not, develop an operational control. Here are a couple of examples:
These operational controls help ensure that specified conditions and performance standards are met.
One of the goals should be to keep operational control procedures simple, focusing on the "who, what, where, when, how, and why" of getting the job done to meet both facility production and EMS requirements.
Examples of activities that may require operational controls include:
This activity is critical whether you have an EMS or not. Your company should have a strong programs in this area to:
It’s important to build on existing procedures and plans to develop the Emergency Preparedness and Response Plan for the EMS. A critically important area to develop is the process for identifying the potential for emergencies and accidents. Typically, it’s best to develop a proactive process for identifying potential hazards that may not be strictly regulated.
Items that should be addressed in the Emergency Preparedness and Response (EPR) program include:
Finally, make sure your EPR plans address relevant environmental regulations and the requirements of the EMS. This will help consolidate EPR efforts so you have fewer documents and clear direction regarding what you need to do in the event of an emergency. This is sometimes referred to as integrated contingency planning.
Important EPR items include:
Before beginning this quiz, we highly recommend you review the module material. This quiz is designed to allow you to self-check your comprehension of the module content, but only focuses on key concepts and ideas.
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