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Managing an EMS With Curtailed Resources

Managing an EMS With Curtailed Resources. Practical Advice for Managing EMSs in Today’s Economy. Many of us were not not originally environmental scientists Many of us inherited our jobs Many of us perform several other jobs Environmental is sometimes out-prioritized by other domains

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Managing an EMS With Curtailed Resources

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  1. Managing an EMS With Curtailed Resources

  2. Practical Advice for Managing EMSs in Today’s Economy • Many of us were not not originally environmental scientists • Many of us inherited our jobs • Many of us perform several other jobs • Environmental is sometimes out-prioritized by other domains • Many employees don’t understand “environmental” • Things got much worse when the recession hit

  3. THE GOOD NEWS: • We all want to protect our environment • Methods exist for doing a good job environmentally despite these challenging circumstances

  4. Cleaning up Issues as HSE Specialists Leave • Understand the scope – get macro data • Understand consequences • Immediate health hazards • Clear violations of regulations • Potentially serious pollution • Big fines • 14001 non-conformances • Risk to certificate renewal • Loss of sales • Work Instruction violations: CARs • Bad housekeeping: more aggressive audits or inspections

  5. Cleaning up Issues as HSE Specialists Leave • Triage your issues – find out what your most risky environmental aspects are: • Hazardous waste? • Storm water? • Used oil? • Reporting? • Walk through with someone who knows some environmental – inside AND everywhere outside • Maintenance • Savvy operators • Facilities engineering • Quality • Manage your time to address risky items first

  6. Document for a Smooth Transition - Crucial as Downsizing Occurs • Give experts time to document and train others before they go • If Work Instructions are incomplete, request a series of cheat sheets: • Hazardous waste procedures • Outfall sampling procedures • Used oil recycling • Universal waste procedures • Environmental reporting files • Filing system indexes

  7. Establish and Maintain an Environmental Filing System • Why? • Reduce risk in audits and inspections • Save time finding data daily • Spend less of consultants’ time looking for your data • Simplify delegating tasks • Stand-alone documentation survives turnover of employees

  8. Establish and Maintain an Environmental Filing System • Get a fireproof, locking file cabinet for paper, permits, certifications, training log signatures • Establish a detailed outline (don’t hesitate to copy someone else’s): • Compliance top level: water, air, RCRA, CERCLA, EPCRA, etc. • Conformance top level: elements of 14001 standard • Mirror the filing system digitally: • Server directories • Intranet applications – BEWARE THE I.T. GUYS • Email folder structures • Back up hard drives, servers, email

  9. Reduce Paperwork in 14001 Compliance • Interpretations of ISO 14001 conformance have been modernized • ANAB (governing body) re-reinterpretations of standard promote more effective EMSs • Focus is on results, less time wasted on paperwork • Increase your EMS’s effectiveness with LESS time investment • Remember: entire ISO 14001 is 9 pages long • Intended to be robust • Compliance methods subject to interpretation • You are your registrar’s customer

  10. Revise Paper-intensive Conformance Procedures • Replace numerical schemes for assessing significance of environmental aspects with criteria • Significant if training, monitoring or measurementand controls are needed • Significant if had recent issues with aspect • Labor-intensive “competency” evaluation • Take credit for all forms of competency assessment: • Routine supervisory interaction • Other existing performance measures

  11. Utilize your Existing Procedures to Conform to 14001 • Don’t internally over-audit • Delegate internal auditing • Audit significant aspects, elements in manageable chunks • Avoid onerous management review meetings • Implement a system of meetings – not one huge meeting • Include all relevant management exposure to EMS

  12. Train for Effectiveness • Remember who your audience is • In many cases they are legally required to have awareness only • You are obligated to make them environmentally effective • Reduce time spent on esoteric topics • Focus on training that will help them comply with regulations • Delegate some training to supervisors, line chiefs

  13. Make Sure Trainees Internalize the Message • Increase the frequency of exposure to topics • Use supervisor safety briefings • Spread training across the year • Infer training priorities from your auditors, inspectors • Assess real competency, not just test-taking ability

  14. Managing Environmental and Safety • Many small facilities combine functions – it’s unavoidable • Many areas of safety / environmental overlap • Hazard Communications • Management systems – VPP, SHARP • Safety documentation and file organization is as important as environmental – for same reasons • Use OSHA website resources • Good inspection checklist : “small business” • Good list of training topics: • BLR 7-minute safety table of contents • KellerOnline toolbox talks

  15. Safety and Environmental Culture: Employees Need to Know Why They Need Both • Quality of their environment at home • Non-compliance means money out of THEIR pockets and less job security • Fines • Insurance costs • Lost new sales • Less job security • Poor product quality • Reduced quality of life due to injury

  16. Your Best Hope: Use THE TEAM • Plant management • Start here • Do not proceed without management backing • Managing consultants • Write specific statements of work • Support them with good data and files to minimize your expenditures • Corporate resources • Sometimes invaluable • Sometimes irrelevant • Always: Understand and plan for their role

  17. Use THE TEAM • Quality Assurance • Good for help learning 14001 • Similar methodology to 9000, TS • “Show Me the Shall” blog • Maintenance managers - you’re lost without them • Key technology person in plant • Learn to communicate • Pick your battles • Learn to compromise • Earn their respect • GTRI • In GA, invaluable free expert resource • Look for counterparts in your state • Confidential is good

  18. Use THE TEAM • HR • Closer to environmental than you may think • Environmental incidents require same HR support as safety: • Investigation • Accountability • Vendors • Reporting quantities • Tier II usages, maximums • Ozone depleting substances (refrigerants) • Waste haul records • Most important: the employees

  19. EMS – Environmental MANAGEMENT System • This job is managing • Management skills required • People skills • Time management • Persuasion • Prioritization • Investment of time up front • Personal organization • Organizational dynamics • Contract management • 80% management, 20% technical • THANK YOU FOR YOUR TIME!

  20. CON UNDERWOOD Con Underwood Consulting, LLC 706-338-9096 conunderwood1@gmail.com conunderwood.com

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