Organizing Existing EH&S Programs into an Environmental Management System Approach

1. Organizing Existing EH&S Programs into an Environmental Management System Approach Presented by Amy L. Borman, PRIZIM Inc., at the Environmental Compliance Assistance Workshop for Colleges and Universities September 13-14, 2005, at University of North Carolina at Chapel Hill

2. Is this what you think of when you hear EMS?

3. What is the state of EH&S at your campus?

4. Overview • What is EMS (in a nutshell)? • Drivers for university EMSs • EMS as applied to typical EH&S program components • Strategic planning • Hazardous waste • Fuel management • Chemical Hygiene Plans

5. What is EMS?

6. What is EMS? Environmental Management System – • An organizational approach to environmental management that incorporates quality improvement principles and strategic planning techniques to reduce environmental impacts Act Check Plan Do

7. The EMS Model– Five Basic Steps Continual Improvement Management Review (Lessons learned. Put changes into effect.) Environmental Policy Statement (Your vision. What you stand for.) Checking and Corrective Action (What has been achieved? What needs more work?) Planning (Your roadmap. How you are going to get there?) Implementation & Control (Make It Happen. Get on with it.)

8. Aspects and Impacts • Look objectively at operations and activities • Identify how they interact with the environment to cause impacts • Determine which impacts are most significant • Commit to taking action on select significant impacts for the immediate time being

9. Objectives and Targets • Policy – tells you what direction you want to go in • Objective – gives you a roadmap • Target – tells you how you will know when you arrive

10. Objectives and Targets • Objectives and targets focus on reducing selected significant impacts • Makes sure you are focused on the right priorities: • Real environmental impacts • Compliance • Integrates well with existing EH&S strategic planning processes

11. Why EMS? A well planned and executed EMS: • Reduces real environmental impacts

12. Why EMS? A well planned and executed EMS: • Integrates with daily operations to improve environmental performance • Verifies environmental performance claims • Saves money and time • Improves management perceptions • Improves public image An EMS must add value over time to be sustainable

13. EMS Drivers for Universities • Pressure from EPA • SEP agreements or outcome of audit disclosure process • Letter to C&U Presidents from EPA/ACE • Pressure and incentives from states • Peer pressure • Provides focus for existing greening and sustainability initiatives • To get agreement on priorities and achieve measurable performance improvements

14. Why Hazardous Waste? • Most significant environmental issue at most colleges and universities • Potential for significant harm • Often the main focus of regulatory scrutiny • Potential for long term liability • A major budget item

15. Why Hazardous Waste? • Often the most developed campus environmental program, so many EMS elements are probably already in place • EMS puts heightened emphasis on managing “real risks” – gets your head up out of the regulations • EMS provides a framework for pollution prevention efforts

16. Where are the Real Impacts of Hazardous Waste? • Leaky or poor containers, potential spills • Unidentified wastes • Improper disposal – drain disposal, normal trash • Problems in transit What are you already doing to address these impacts? How could these efforts be improved?

17. Campus Hazardous Waste Program Elements That Address Impacts • Hazardous waste SOPs • Waste determination • Controls on how wastes are transferred on campus and off • Training (generator and DOT) • Audits and Performance Verification • Controls on off-campus shipments

18. Why Fuel Storage? • Can be significant environmental issue • Potential for significant harm – probably most significant spill risk • Potential for clean-up costs and long term liability associated with contamination • A major budget item

19. Where are the Real Impacts of Tanks? • Leaky or deteriorating tanks • Leaky or deteriorating pipes • Problems with fuel dispensers • Potential spills • Problems in transit What are you already doing to address these impacts? How could these efforts be improved?

20. Campus Fuel Tank Program Elements That Address Impacts • Ensuring all tanks, piping, and fuel dispensers are up to code • EPA requirements (USTs) • NFPA and engineering requirements (ASTs) • Security and controls on access • Ensuring each tank has a method of release detection • Ensuring Spill Prevention Control Countermeasures Plan or equivalent is in place • Monitoring all fuel deliveries • Assessing fuel needs – can tanks be eliminated?

21. Why Chemical Hygiene Plans? • Chemical Hygiene Plan provides existing platform of written procedures • SOPs for particularly hazardous substances • Already a recognition of need to use CHPs as a vehicle for environmental management • HHMI study • Opportunity to explore integrated safety and environmental management system

22. Where are the Real Impacts of Labs? • Drain disposal of chemical wastes • Air emissions via fume hoods • Potential spills • Inadvertent release of biohazards • Excess chemical disposal What are you already doing to address these impacts? How could these efforts be improved?

23. CHP Elements That Address Impacts • Hazardous waste SOPs • Waste determination • Waste containers and labeling • Waste disposal • SOP to minimize air emissions via fume hoods • Spill response protocols, integrated with campus chemical incident response framework • Expand CHP concept to include biohazards • SOP for chemical inventory management (including purchasing, tracking, and storage) Used solvents - acetone (40%), xylene (60%)

24. Advantages of EMS • Allows you to focus your precious resources on what’s most important – real impacts • Be assured all campus waste streams are “in the system” • Verify conformance and compliance with required practices and regulations • Help staff to work smarter • Emphasizes understanding of root causes and systematic change versus quick fix

25. Steps to Get Started EMS is a management tool that can improve and streamline campus environmental management programs • Identify campuswide aspects and impacts – even if “back-of-the-envelope” • Keep it simple – identify components you already have in place and build on those

26. Steps to Get Started • Set objectives and targets to measure performance – use only SMART targets and not too many • Integrate with your strategic plan (if you have one) • Consider integrating with your safety program

27. Advice from Those Who Are Doing It “Just do it and rely on continuous improvement.” Plan Act Do Check

28. Amy Borman PRIZIM Inc. aborman@prizim-inc.com 301-840-9316, ext. 105