Implementing the EMP

Step 3: Implement the program.

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, well take a look at the various elements in the implementation phase:

• Structure and Responsibility
• Training, Awareness, Competence
• Communication
• EMS Documentation
• Document Control
• Operational Control
• Emergency Preparedness and Response

Structure and Responsibility

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

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 teach 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 your 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.

For more information on training, be sure to check out OSHAcademy Courses 703, 721, or 723.

Communication

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:

• notes in pay checks that inform employees about EMS efforts
• training courses
• posted signs with reminders of key EMS goals and actions
• weekly EMS meetings at the facility to review progress with key management personnel
• posting of results of progress toward objectives and targets on facility bulletin boards (for example, waste generation and chemical use rates)
• meetings with senior management to report on the EMS
• employee suggestion box and communications about awards for successful projects

External Communication

You should also identify external stakeholders and communicate regularly with them regarding your EMS. This group includes customers, vendors, suppliers, neighbors, and regulators.

To help make sure communications are effective, 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 your external stakeholders:

• Meet with vendors and suppliers to explore options for green chemicals.
• Tell customers about your EMS efforts.
• Participate in community meetings to discuss your plant and its EMS efforts.
• Host an open house or tour of the facility.
• Host meetings to share information and obtain input about EMS efforts.
• Communicate your EMS efforts to Federal, state, and local regulators.

EMS Documentation

Your EMS must be clearly understood by employees and external stakeholders. You should provide EMS information to employees and external parties, such as customers, regulators, financial institutions, and the public, who need to understand how your EMS is designed and deployed. To do that, you must make sure your EMS is well documented. There are two basic categories of EMS documentation:

The EMS Manual

• a description of the EMS core elements (and how they relate to each other), and
• directions on how to locate other related documentation.

Other Documentation

EMS System Procedures

You should have a specific Document Control procedure to manage EMS documents.

EMS System Procedures document the processes used to meet the EMS criteria. However, you may also need to include area-or activity-specific documents like work instructions or job hazard analyses (JHAs).

EMS Document Control Procedures describe

• how to control or manage EMS documentation,
• how documents are periodically reviewed and revised,
• and how obsolete documents are promptly removed from all points of issue and use.

The following are documents that should be for control management:

• environmental policy
• lists of objectives and targets
• description of roles, responsibilities, authorities, and lines of communication
• EMS Manual (system description)
• system-level procedures
• work instructions to support the EMS
• related plans (for example, emergency preparedness

Means and Controls

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 should address how EMS documents will be:

• prepared
• issued and distributed
• revised
• reviewed
• disposed of (for outdated documents)

Operational Controls

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:

• Physical controls, (for example, berms, walls, and roofs),
• Engineering controls (for example, alarms, level indicators, and gauges), or
• Administrative controls (for example, procedures and inspections).

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:

1. You may have operational controls for production lines regarding chemical use, production methods, and temperature control to support both high quality production and EMS objectives and targets.
2. You may have an Operational Control Procedure that describes how a wastewater treatment plant will be operated to ensure compliance with Clean Water Act permit requirements regarding discharges to surface water from your facility.

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:

• chemical purchasing
• material handling
• maintenance
• plating line operations
• wastewater treatment system operation
• waste accumulation and disposal
• storage of parts before off-site shipment

Emergency Preparation and Response

This activity is critical whether you have an EMS or not. Your company should have a strong programs in this area to:

• comply with applicable environmental laws and corporate policy and
• to protect personnel and those who live around the facility.

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:

• type and location of hazardous substances used and stored on site
• key organizational responsibilities
• arrangements with local emergency responders, including points-of contact for response agencies
• emergency response procedures
• emergency communication (lines of communication and internal and external contact information)
• locations and functions of emergency equipment and provisions for maintenance of such items
• prevention requirements (for example, testing alarms, training)
• evacuation routes

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:

• identifying the potential for problems,
• testing the EPR plan annually, and
• updating the EPR plan, as necessary.

Instructions

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.

Read each question carefully. Select the best answer, even if more than one answer seems possible. When done, click on the "Get Quiz Answers" button. If you do not answer all the questions, you will receive an error message.

Good luck!