The policy should serve as the foundation for your EMS and provide a unifying vision of environmental concern by the entire organization. Your policy should be more than just flowery prose. Since it serves as the framework for setting environmental objectives and targest, the policy should be brought to life in your plans and deeds. Everyone in the organization should understand the environmental policy and what is expected of them in order to achieve the organization's objectives and targets.
Your policy should contain three key commitments see box, below , including a commitment to continual improvement. This doesn't mean that you must improve in all areas at once, but that the policy should drive your overall efforts to continually improve your organization's environmental management. Sample environmental policies which contain the three key policy commitments are provides in the Tool Kit see page Your organization probably has an environmental policy now, even if it's not written.
For example, your organization is probably committed to complying with the law and avoiding major environmental problems, at a minimum. Document your existing commitments as a starting point. Your policy should be related to your products and services, as well as supporting activities. Consider the results of your preliminary review before finalizing the policy.
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Also, make sure the policy reflects the environmental aspects of your products, services and activities as described in the next section. Keep your policy simple and understandable. Ask yourself: What are we trying to achieve? How can I best communicate this to the rest of the organization? Will we do what we said we would? Keep in mind that your policy should be explicit enough to be auditable. Consider who should be involved in developing the policy and the best process for writing it. Input from a range of people in your organization should increase commitment and ownership.
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Make sure that your empleyees undestand the policy. Options for communicating your policy internally include posting it around the site e. Test awareness from time to time by asking employees what the policy means to them. The policy should also be communicated externally. Options for external communcation include business cards, newspaper advertisements and annual reports, among other options. You can choose to communicate the policy proactively or in response to external requests. To plan for and control its significant environmental impacts, an organization must first know what these impacts are.
But knowing what the impacts are is only part of the challenge - you also should know where these impacts como from. If your organization has undertaken pollution prevention projects, your are probably familiar with this concept your must know how a waste is generated in order to minimize or eliminate it.
As with pollution prevention, the identification and management of environmental aspects can 1 have positive impacts on the bottom line and 2 provide significant environmental improvements. Your EMS should include a procedure to identify the environmental aspects that your organization:.
The relationship between aspects and impacts is one of cauce and effect. The term "aspects" is neutral, so keep in mind that your environmental aspects could be either positive such as making a product out of recycled materials or negative such as discharge of toxic materials to a stream. Your organization is not expected to manage issues outside its sphere of influence. For example, while your organization probably has control over how much electricity it uses, it likely does not control the way in which the electriciy is generated.
Once you have identified the environmental aspects of your products, activities, and services, you should determine which aspects could have significant impacts on the environment.
These environmental aspects should be considered when you set your environmental objectives and define your operational controls as discussed later. A multi-step process see figure al left can be used to make this evaluation. Keep the resulting information up-to-date, so that potential aspects of new products, services, and activities are factored into your objectives and controls. In identifying aspects and impacts, you should also look at activities not controlled by applicable laws and regulations.
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Permits, audit reports, and other such documents can serve as useful inputs. Beyond regulations, look at issues such as land, energy, and other natural resource use. Once you have identified environmental aspects and related significant impacts, use this information in setting your objectives and targets. This does not mean that your need to address all of your impacts at once.
There may be good reasons such as cost, availability of technology, and scientific uncertainty for addressing some impacts now and deferring action on others. Keep in mind that managing environmental aspects could have positive business impacts. Remember to look al services as well as products. While the need to examine your on-site operations might be obvious, you should also consider the potential impacts of what you do off-site such as servicing equipment al customer sites.
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Similarly, the environmental aspects of the products, vendors, and contractors your use may be less obvious, but should still be considered. Identifying significant environmental aspects is one of the most critical elements of the EMS - and can be one of the most challenging. Decisions you make in this task can affect many other system elements such as, setting objectives and targets, establishing operational controls, and defining monitoring needs.
Careful planning and conduct of this activity will pay dividens in latr steps. To understand your environmental aspects, it helps to understand the processes by which you generate products and services.
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A flow chart of your major processes might help you undesrstad the inuts and outputs of your processes and how materials are used. A sample flow chart is provided in the Tool Kit see page You may also want to consider the views of interested parties - some organizations have found external parties to be a good resource to help you identify your organization's environmental aspects. There are many readily-available sources of information to help you perform your assessment. For starters, look at your permits, various regulations that apply to your operations, audit reports, EPCRA reports, and monitoring records.
Trade associations, regulatory agencies, your customers and suppliers also might provide useful information to support your assessment. Various techniques exist for evaluating environmental impacts.
Find one that can be readily adapted for your use in identifying environmental aspects and significant impacts. More information on these techniques can be found in the Tool Kit see page Once you've found a process that works for your organization, describe the process in a written procedure. A sample procedure for performing the assessment is provided in the Tool Kit see page You can start out with a simple process for identifying aspects and then refine the process over time as needed.
You also can address the more obvious impacts or "low hanging fruit" first, then tackle the more complex issues later. To be in compliance with the laws and regulations that apply to your organization, you must first know what the rules are and how they affect what you do. As discussed earlier, compliance with legal requirements is one of the "three pillars" upon which your environmental policy should be based.
Costs of non-compliance in terms of dollars, public image and possible damage to the environment can be very high. An effective EMS will include a process for:.
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Identifying applicable legal and other requirements, and;. Changing legal requirements might require that you modify your environmental objectives or other elements of your EMS. By anticipating new requirements and making changes to your operations, you can avoid some future compliance obligations and their associated costs. Your EMS should include a procedure for identifying and having access to the legal and other requirements that apply to your organization. These "other requirements" might include industry codes, the CERES Principles, or similar requirements to which your organization may subscribe.
The process of identifying applicable regulations, interpreting them, and determining their impacts on your operations can be a time-consuming task.
Fortunately, there are many ways in which your organization can obtain information about applicable laws or regulations. These include:. Small business assistance programs exist in every state. Under the Clean Air Amendments of , each state environmental regulatory agency must establish a technical and compliance assistance program to help companies comply with air quality rules. These programs are being expanded into other environmental "media" e.
Communicating the "other requirements" that apply to your organization as well as their impacts is an important - and often overlooked- step. A list of some resources you can use to identify and track environmental lawas and regulations is provided in the Tool Kit see page Annex C also contains additional sources of information about environmental laws and regulations.
The Tool Kit contains a sample procedure for tracking environmental laws and regulations see page Objectives and targets help you translate purpose into action - they should be factored into your strategic plan and can facilitate the integration of environmental management with other business management processes. You determine what objectives and targets are appropriate for your organization. These goals can be organization-wide or applied to individual units or activities.
In setting objectives, keep in mind your environmental policy, including its three "pillars".
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You should also consider your significant environmental aspects, applicable legal and other requirements, the views of interested parties, your technological options, and financial, operational, and other business requirements. There are no "standard" environmental objectives that fit all organizations. Your objectives and targets should reflect what your organization does and what it wants to achieve.
Objectives and targets should be set by the people in the functional area involved - they will be best positioned to establish, plan for, and achieve these goals. Objectives should be consistent with your overall business mission and plan ant the key commitments established in your policy pollution, prevention, continual improvement, and compliance. Be flexible in your objectives.
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