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SECTION 14

ENVIRONMENTAL MANAGEMENT SYSTEMS

U.S. TEAM Guide, March 2009[Added July 2007]

A. Applicability

The checklist for EMS primarily consists of management practices (MP). These MPs are drawn from ISO 14001, ISO 14004, EO 13423, and guidance documents provided by the EPA. This checklist is also targeted at facility-level (i.e., installation, project, refuge, laboratory, center, park) EMS, not at Departmental, Bureau, Agency, or Regional EMS.

Assessors are required to review state and local regulations and, if applicable, the appropriate Agency Supplement, to perform a comprehensive assessment.

B. Federal Regulations

• Executive Order (EO) 13423, Strengthing Federal Environmental, Energy, and Transportation Management. This EO, dated 24 January 2007, requires Federal agencies to lead by example in advancing the nation’s energy security and environmental performance by achieving goals outlined in the EO. This EO revokes the following EOs:

1. Executive Order 13101, Greening the Government Through Waste Prevention, Recycling, and Federal Acquisition of September 14, 1998;

2. Executive Order 13123, Greening the Government Through Efficient Energy Management of June 3, 1999;

3. Executive Order 13134, Developing and Promoting Biobased Products and Bioenergy of August 12, 1999, as amended;

4. Executive Order 13148, Greening the Government through Leadership in Environmental Management of April 21, 2000; and

5. Executive Order 13149, Greening the Government Through Federal Fleet and Transportation Efficiency of April 21, 2000.

The EO sets forth the following Agency goals:1. improve energy efficiency and reduce greenhouse gas emissions of the agency, through reduction of

energy intensity by 3 percent annually through the end of fiscal year 2015, or 30 percent by the end of fiscal year 2015, relative to the baseline of the agency's energy use in fiscal year 2003;

2. ensure that at least half of the statutorily required renewable energy consumed by the agency in a fiscal year comes from new renewable sources, and to the extent feasible, the agency implements renewable energy generation projects on agency property for agency use;

3. beginning in FY 2008, reduce water consumption intensity, relative to the baseline of the agency's water consumption in fiscal year 2007, through life-cycle cost-effective measures by 2 percent annually through the end of fiscal year 2015 or 16 percent by the end of fiscal year 2015;

4. require in agency acquisitions of goods and services the use of sustainable environmental practices, including acquisition of biobased, environmentally preferable, energy-efficient, water-efficient, and recycled-content products, and use of paper of at least 30 percent post-consumer fiber content;

5. ensure that the agencya. reduces the quantity of toxic and hazardous chemicals and materials acquired, used, or disposed of

by the agency, b. increases diversion of solid waste as appropriate, and c. maintains cost-effective waste prevention and recycling programs in its facilities;

6. ensure that:a. new construction and major renovation of agency buildings comply with the Guiding Principles for

Federal Leadership in High Performance and Sustainable Buildings set forth in the Federal

14-1Environmental Management Systems

Leadership in High Performance and Sustainable Buildings Memorandum of Understanding (2006), and

b. 15 percent of the existing Federal capital asset building inventory of the agency as of the end of fiscal year 2015 incorporates the sustainable practices in the Guiding Principles;

7. ensure that, if the agency operates a fleet of at least 20 motor vehicles, the agency, relative to agency baselines for fiscal year 2005:

a. reduces the fleet's total consumption of petroleum products by 2 percent annually through the end of fiscal year 2015,

b. increases the total fuel consumption that is non-petroleum-based by 10 percent annually, and c. uses plug-in hybrid (PIH) vehicles when PIH vehicles are commercially available at a cost

reasonably comparable, on the basis of life-cycle cost, to non-PIH vehicles; and 8. ensure that the agency:

a. when acquiring an electronic product to meet its requirements, meets at least 95 percent of those requirements with an Electronic Product Environmental Assessment Tool (EPEAT)-registered electronic product, unless there is no EPEAT standard for such product,

b. enables the Energy Star feature on agency computers and monitors, c. establishes and implements policies to extend the useful life of agency electronic equipment, and d. uses environmentally sound practices with respect to disposition of agency electronic equipment

that has reached the end of its useful life.

• Instructions for Implementing EO 13423 – These instructions, dated 30 March 2007, are developed by the Council on Environmental Quality (CEQ) after consultation with the Office of Management and Budget (OMB) and the agencies. Section 4(b) of EO 13423 authorizes the issuance of instructions to implement the E.O. CEQ issued the first set of implementing instructions on March 30, 2007. According to the Federal Register notice announcing the instructions, “These instructions should be considered mandatory, and agencies are expected to implement them as part of complying with the EO” (Federal Register: June 18, 2007 [Notices], Page 33504).

• International Organization for Standardization (ISO) 14001, Environmental Management Systems – Specification with Guidance for Use. This standard, revised 15 November 2004, addresses the basic structures and systems needed for an effective environmental management systems. ISO 14001 is not a regulation, it provides guidance to any organization wishing to:

1. establish, implement, maintain and improve an environmental management system,2. assure itself of conformity with its stated environmental policy,3. demonstrate conformity with this International Standard by

a. making a self-determination and self-declaration of conformance, orb. seeking confirmation of its conformance by parties having an interest in the organization, such as

customers, orc. seeking confirmation of its self-declaration by a party external to the organization, ord. seeking certification/registration of its environmental management system by an external

organization.

• International Organization for Standardization (ISO) 14004, Environmental Management Systems — General Guidelines on Principles, Systems and Support Techniques. This standard, revised 15 November 2004, provides assistance to organizations that wish to implement or improve an environmental management system and thereby improve their environmental performance. This International Standard is consistent with the concept of sustainable development and compatible with diverse cultural, social and organizational frameworks and systems of management.

• Office of Management and Budget (OMB) Circular A-11, Part 2: Preparation and Submission of Budget Estimates. In paragraph 31-2 of the circular, dated June 2002, OMB reminds Federal agencies to include resources for EMS in their funding requests. The guidance states “Federal agencies should develop and implement environmental management systems in order to integrate environmental accountability into agency day-to-day decision-making and long-term planning processes, across all agency missions, activities, and functions. These efforts must be funded within guidance totals. They should include, but not be limited to, the following components: initial self-assessments, development of performance measures, policy, and establishment of management systems.”


• Joint Memorandum from OMB and the Council on Environmental Quality (CEQ), Next Steps in Successfully Meeting Executive Order Requirements for Effective Environmental Management . This memo, dated 11 April 2006, reaffirms the commitment to a strong environmental stewardship policy including EMS. Additionally, the memo refers to the OMB scorecard initiatives.

• Environmental Management System Metrics - For each reporting year, appropriate facility information collected should reflect facility level EMS implementation progress, performance and successes. Each agency will be requested to provide a summary of the following information for its appropriate facilities:

1. EMS Scorecard Metrics2. EMS Effectiveness Questions3. EMS Experiences Feedback.

The metrics in Appendix 14-1 will be used for reporting years 2006 to 2008.

C. State/Local Regulations

For information on regulations in specific states, see the State Supplements to TEAM Guide.

D. Key Compliance Requirements

• EMS Implementation - Federal agencies will implement environmental management systems (EMS) at all appropriate organizational levels to ensure the use of EMS as the primary management approach for addressing the environmental aspects of internal agency operations and activities, including the environmental aspects of energy and transportation function; establishment of agency objectives and targets to ensure implementation of the EO; and collection, analysis, and reporting of information to measure performance in the implementation of EO 13423 (Instructions for Implementing EO 13423, para. ID(1)).

• Compliance - Compliance with environmental and energy legal and regulatory requirements is a fundamental responsibility of Federal agencies at all levels (Instructions for Implementing EO 13423, para. ID(1)).

• Performance Evaluations - Agency’s will include successful implementation of EO 13423 in performance standards and performance evaluations of senior agency officials designated as responsible under EO 13423, and relevant staff, such as facility managers, environmental and program managers, vehicle fleet managers, contracting officials, and others as appropriate (Instructions for Implementing EO 13423, para. ID(4)).

• Agency Goals – Federal agencies must develop plans and policy to be implemented at athe facility level in order to meet the following Agency goals outlined in EO 13423:

1. Improve energy efficiency and reduce greenhouse gas emissions through the reduction of energy intensity (EO 13423, para. 2(a))

a. 3% annually OR 30% by the end of FY 2015b. The baseline year is FY 2003c. Guidance from the Instructions for Implementing EO 13423 state:

i. Each agency shall begin reporting performance toward the reduction goal for FY 2007, which for that year requires a 6 percent reduction, relative to the FY 2003 baseline, in order to be considered on track to meet 30 percent reduction goal in 2015.

ii. Where life-cycle cost is effective, implement distributed generation systems in new construction or retrofit projects, including renewable systems such as solar electric, solar lighting, geo (or ground coupled) thermal, small wind turbines, as well as other generation systems such as fuel cell, cogeneration, or highly efficient alternatives.

iii. Use distributed generation systems when a substantial contribution is made toward enhancing energy reliability or security.

iv. To the maximum extent practicable, install metering devices that measure consumption of potable water, electricity, and thermal energy in Federal buildings and other facilities and


grounds. Data collected shall be incorporated into Federal tracking systems and be made available to Federal facility managers.

v. Consider inclusion of metering requirements in all ESPCs and UESCs, as appropriate.vi. Agencies should conduct energy and water audits of at least 10 percent of facility square

footage annually and conduct new audits at least every 10 years, thereafter. This can be met by audits done in conjunction with ESPC or UESC projects.

vii. For applicable facilities, agencies should meet Energy Star® Building criteria, and score the energy performance of buildings using the Energy Star® Portfolio Manager rating tool as part of comprehensive facility audits. Agencies may use the Energy Star Portfolio Manager rating tool to track energy and water use in all facilities.

viii. Agencies should explore efficiency opportunities in applicable facilities and programs such as the Labs21 partnership to encourage the development of sustainable, high performance, and low-energy laboratories nationwide.

ix. Purchase electricity and thermal energy from sources that use high efficiency and low-carbon generating technologies in order to reduce greenhouse gas intensity to the extent possible.

2. Increase the use of new renewable resources (EO 13423, para. 2(b)(i)):a. At a minimum 50% of the statutorily required renewable energy consumed in a single FY comes

from new renewable sourcesb. No baseline year

3. To the extent feasible, implement renewable energy generation projects on agency property for agency use (EO 13423, para. 2(b)(ii)).

NOTE: DOE, in consultation with the Interagency Energy Management Task Force, shall issue or update guidance on:

Long term planning and strategies for achieving energy goals. The renewable energy goal and use of renewable energy credits. Use of alternatively financed projects such as ESPCs and UESCs. Use of and investment in renewable energy generation. Calculating and validating funds available for retention in accordance with Section

102(f) of EPAct 2005.

4. Beginning in FY 2008, reduce water consumption intensity through life-cycle1 cost-effective measures (EO 13423, para 2(c)):

a. 2% annually OR 16% by the end of FY 2015b. The baseline year is FY 2007c. Guidance from the Instructions for Implementing EO 13423 state:

i. Where applicable, purchase WaterSense (SM) labeled products and choose irrigation contractors who are certified. www.epa.gov/watersense

ii. By 30 September 2007, DOE, in coordination with EPA, shall issue guidance with respect to a 2007 baseline for potable, landscape, and other water consumption intensity and meeting the water conservation goal of Section 2(c) of the EO.

5. Sustainable environmental practices will be used in acquisition of goods and services, including acquisition of biobased, environmentally preferable, energy-efficient, water-efficient, and recycled –content products (EO 13423, para (d)(i))

a. Guidance from the Instructions for Implementing EO 13423 state:i. Purchase environmentally preferable products and services, using EPA’s Guidance on the

Acquisition of Environmentally Preferable Products and Services http://www.epa.gov/epp/pubs/guidance/guidancepage.htm

ii. When purchasing commercially available, off-the-shelf energy-consuming products such as Standby Power Devices, purchase products that use no more than one watt of standby power as defined and measured by International Electrotechnical Commission (IEC) code 62301, or otherwise meet FEMP specifications for low standby power consumption. This applies when life-cycle cost-effective and practicable, and where the relevant product’s utility and performance are not compromised as a result.


http://www.epa.gov/epp/pubs/guidance/guidancepage.htm

http://www.epa.gov/watersense

iii. If FEMP has not specified a standby power level for a product category, purchase products with the lowest standby power consumption available. This applies when life-cycle cost-effective and practicable, and where the relevant product’s utility and performance are not compromised as a result.

iv. Agencies which procure electronic devices for resale, such as military exchanges, shall establish a policy which limits procurement and sale of items which do not meet FEMP specifications for low standby power.

v. Preference is to be given in procurement and acquisition programs to the purchase of: Recycled content products designated in EPA’s Comprehensive Procurement

Guidelines. Energy Star® products identified by DOE and EPA, as well as FEMP-designated

energy-efficient products. Water-efficient products, including those meeting EPA’s WaterSense standards. Energy from renewable sources. Biobased products designated by the U.S. Department of Agriculture in the

BioPreferred program. Environmentally preferable products and services, including EPEAT-registered

electronic products. Alternative fuel vehicles and alternative fuels required by EPAct. Products with low or no toxic or hazardous constituents, consistent with section VIII.A

of these instructions. Non-ozone depleting substances, as identified in EPA’s Significant New Alternatives

Program.vi. In contracts providing for contractor performance at Federal facilities, a requirement must be

included that the contractor provides the information needed by the Federal facility to comply with EPCRA, PPA, and E.O 13423.

6. Use paper of at least 30% post-consumer fiber content (EO 13423, para (d)(ii)):a. Guidance from the Instructions for Implementing EO 13423 state:

i. Continue to use the following minimum content standards when purchasing printing and writing papers, including office paper products, or support services that include the supply of written documents: 30 percent postconsumer fiber. 20 percent postconsumer fiber, IF papers containing 30 percent postconsumer fiber are

not reasonably available, do not meet reasonable performance requirements, or are only available at an unreasonable price.

7. Reduce the quantity of toxic and hazardous chemicals acquired, used, or disposed of. (EO 13423, para 2(e)(i))

a. Guidance from the Instructions for Implementing EO 13423 state:i. By 24 January 2008, each agency, at all appropriate organizational levels including

appropriate facilities, organizations, and acquisition activities, shall develop written goals and support actions to identify and reduce the release and use of toxic and hazardous chemicals and materials, including toxic chemicals, hazardous substances, ozone-depleting substances (ODSs), and other pollutants that may result in significant harm to human health or the environment.

ii. Agencies will ensure that they maximize the use of safe alternatives to ODSs, as approved by the EPA’s Significant New Alternatives Policy (SNAP) program.

iii. Agency plans to replace ODSs should target cost effective reduction of environmental risk by eliminating the use of ODSs in new equipment and facilities and by phasing out ODS applications as the existing equipment using those substances reaches its expected service life. In developing ODS-related actions, agencies shall consider (1) maintaining equipment to prevent or fix leaks and (2) replacing leaking equipment when repair is no longer cost-effective or where it is life-cycle cost-effective to replace the equipment.

iv. Agencies shall amend personal property management policies and procedures to preclude the disposal of ODSs removed or reclaimed from its facilities or equipment, including disposal


as part of a contract, trade, or donation, without prior coordination with the Department of Defense (DoD).

v. Where the recovered ODS is a critical requirement for DoD missions, agencies shall transfer the materials to DoD. DoD will bear the costs of such transfer.

vi. Compliance with the provisions set forth in sections 301 through 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA), section 6607 of the Pollution Prevention Act (PPA), all implementing regulations, and future amendments to these authorities, will be done in light of applicable EPA guidance and without regard to the Standard Industrial Classification (SIC) or North American Industrial Classification System (NAICS) delineations.

vii. In contracts providing for contractor performance at Federal facilities, a requirement must be included that the contractor provides the information needed by the Federal facility to comply with EPCRA, PPA, and the E.O.

8. Increase diversion of solid waste as appropriate. (EO 13423, para 2(e)(ii))a. The baseline year is FY 2000 if the Agency has not previously had solid waste diversion goals.

9. Maintain cost-effective waste prevention and recycling programs in its facilities. (EO 13423, para 2(e)(iii))

a. The goal is 35% recycledb. Guidance from the Instructions for Implementing EO 13423 state:

i. Facilities will operate waste prevention and recycling programs in the most cost-effective manner possible, and where appropriate, leased facilities and facilities managed by the General Services Administration (GSA).

ii. In GSA-managed facilities, GSA manages the recycling program, but agencies shall work with GSA to ensure that there is a recycling program that meets the agencies’ needs.

iii. Agencies that have a 35 percent or higher recycling rate shall strive for annual continuous improvement.

iv. Each agency shall recycle materials to the maximum extent practicable, considering cost, cost avoidance, return on investment, and availability of markets.

v. Facilities or installations with a recycling program will have a recycling coordinator.

10. New construction and major renovation of agency buildings will comply with the Guiding Principles for Federal Leadership in High Performance and Sustainable Buildings set forth in the Federal Leadership in High Performance and Sustainable Buildings Memorandum of Understanding (2006) (EO 13423, para 2(f)(i)).

a. The baseline year is the FY 2007 funding cycle.b. Guidance from the Instructions for Implementing EO 13423 state:

i. Beginning with the FY 2007 funding cycle, when planning the funding and design for construction of buildings that meet the agency defined capital asset threshold, each agency shall meet or exceed statutory goals and address each of the five Guiding Principles for Federal Leadership in High Performance and Sustainable Buildings (Guiding Principles)5.

ii. If an agency proposes not to comply, written justification must be provided to OFEE and OMB.

iii. In order to apply the Guiding Principles to building projects, all business cases for new building construction or major renovations, developed per OMB A-11, Part 7, Section 300, shall incorporate the Guiding Principles to the greatest extent practicable.

iv. These requirements apply to construction of new Federal buildings; new, renegotiation, or extension of leases for Federal occupancy, or major renovation projects (NOTE: The agency determines the threshold for major renovation projects.)

11. Existing Federal capital asset building inventory of the agency incorporates the sustainable practices in the Guiding Principles. (EO 13423, para 2(f)(ii))

a. 15% of existing Federal capital asset building inventory by the end of FY 2015b. There is no baseline year.c. Guidance from the Instructions for Implementing EO 13423 state:


i. The 15 percent goal for existing buildings applies to an agency’s full building inventory as it exists in FY 2015, including any new buildings brought on line and excluding any unneeded buildings disposed of or sold prior to 2015. Therefore, agencies should strongly consider incorporating sustainable practices into projects underway and selling or disposing of unneeded assets.

ii. Each agency shall report its success stories and lessons learned for at least one major building project per year into the High Performance Federal Buildings Database, www.eere.energy.gov/femp/highperformance/index.cfm, unless the agency does not have an applicable project to report. The Energy Star® rating of each facility’s energy performance shall be included in each success story.

iii. When entering into leases for Federal occupancy, including the renegotiation or extension of existing leases, agencies shall include criteria encouraging lease provisions that support the Guiding Principles.

iv. Build-to-suit lease solicitations shall incorporate criteria for sustainable design and development, energy efficiency, and verification of building performance in accordance with the Guiding Principles.

v. Technical Guidance for implementing the Guiding Principles and other best practices developed by the Interagency Sustainability Working Group (ISWG) can be found in the Whole Building Design Guide, www.wbdg.org. Contents of the WBDG include clarification of requirements; related mandates; additional recommendations and considerations; and resources for implementation, including model contract and specification language per the Federal Green Construction Guide for Specifiers.

12. If the agency operates a fleet of at least 20 motor vehicles, the agency reduces the fleet’s total consumption of petroleum products (EO 13423, para 2(g)(i)).

a. 2 percent annually by the end of FY 2015b. Baseline year is FY 2005c. Guidance from the Instructions for Implementing EO 13423 state:

i. When calculating the replacement or reduction levels, include fuel use from all vehicles, including light-duty, medium-duty, and heavy-duty vehicles unless such vehicles meet the following exemptions or the agency applies for exemptions in accordance with Section 8 of the E.O. (DOE will determine if vehicles have been properly exempted by auditing the data agencies provide in the Federal Automotive Statistical Tool (FAST)):

Motor vehicles used for motor vehicle manufacturer product evaluations or tests. Law enforcement and emergency vehicles, including those vehicles that are used in

an emergency capacity, by the agency, greater than 75 percent of the year. Agencies with vehicles meeting this definition (as approved by DOE) will have a baseline (and related record-keeping) adjustment to reflect this change.

• Military tactical vehicles, defined as motor vehicles (excluding general-purpose motor vehicles) designed to military specification or a commercially designed motor vehicle modified to military specification to meet direct transportation support of combat or tactical operations and protection of nuclear weapons. These vehicles are inherently mission-critical and are used for no other purpose.

Vehicles owned and operated by the Central Intelligence Agency. Vehicles that are not licensed for use on all roads and highways. Federally owned vehicles operated solely by Indian nations or state-run Fish and

Wildlife services, as applicable. Vehicles operated outside of the U.S.

ii. In planning for petroleum use reductions, agencies shall assess their petroleum needs across their sub-organizations, taking into account mission needs, and make adjustments where necessary to attain the 2 percent goal on average for the entire agency.

iii. If an agency fails to meet the 2 percent petroleum reduction goal in any year, in the following year it shall reduce both the percentage it missed and the 2 percent reduction due for that following year.

To achieve the petroleum reduction goal, each agency shall strive to:


Reduce vehicle miles traveled through such methods as trip consolidation practices, increased use of videoconferencing and web conferencing, and the use of mass transportation/agency shuttles.

Increase overall fleet fuel economy through acquisition of higher fuel economy vehicles (e.g., smaller sized vehicles, hybrid-electric vehicles, and other advanced technology vehicles).

“Right-size” its fleet, employing the most fuel-efficient vehicle for the required task and having the appropriate number of vehicles relative to need.

Employ efficiency strategies such as low rolling resistant tire, synthetic oil, and other technologies.

13. If the agency operates a fleet of at least 20 motor vehicles, the agency increases the total fuel consumption that is non-petroleum based. (EO 13423, para 2(g)(ii))

a. 10 percent annually b. Baseline year is FY 2005c. Guidance from the Instructions for Implementing EO 13423 state:

i. The requirement to annually increase the use of alternative fuels by 10 percent is measured relative to the prior year’s alternative fuel usage levels.

ii. If an agency fails to attain the 10 percent increase in any year, in the following year it shall attain both the percentage missed and the 10 percent increase due for that following year.

14. If the agency operates a fleet of at least 20 motor vehicles, the agency uses plug-in hybrid (PIH) vehicles when PIH vehicles are commercially available at a cost reasonably comparable, on the basis of life-cycle1 cost, to non-PIH vehicles (EO 13423, para 2(g)(iii)).

a. Guidance from the Instructions for Implementing EO 13423 state:i. GSA shall issue a fleet order for PHEVs in all vehicle categories when PHEVs become

commercially available at a cost reasonably comparable, on the basis of life-cycle cost, to non-PHEVs.

ii. To be considered eligible for dual-fuel vehicle status, PHEVS must meet the alternative fuel definitions of EPAct 1992, as amended by EPAct 2005; to do so,

iii. PHEVs will have to meet the minimum driving range as specified by the U.S. Department of Transportation and use electricity generated from a non-petroleum source or from the grid.

15. When acquiring electronic products to meet the agency’s requirements, they meet at least 95% of those requirements with an Electronic Product Environmental Assessment Tool (EPEAT)-registered electronic product unless there is no EPEAT standard for such product (EO 13423, para 2(h)(i)).

a. Guidance from the Instructions for Implementing EO 13423 state:i. Ensure that applicable IT contracts incorporate appropriate language for the procurement of

EPEAT-registered equipment, and address any future FAR clauses related to EPEAT.ii. Strive to purchase to EPEAT Silver rated electronic products or higher if available.

16. Agencies will enable the Energy Star feature on agency computers and monitors (EO 13423, para 2(h)(ii)).

17. Agencies will establish and implement policies to extend the useful life of agency electronic equipment. (EO 13423, para 2(h)(iii)).

a. Guidance from the Instructions for Implementing EO 13423 state:i. Strive to extend the useful lifetime of electronic equipment to four (4) or more years.ii. Use EPA’s guidance to improve the operation and maintenance of electronics products

provided at www.federalelectronicschallenge.net/resources/docs/oandm.pdf.iii. Implement procedures to ensure the timely reuse and donation of equipment.

18. Agencies will use environmentally sound practices with respect to disposition of agency electronic equipment that has reached the end of its useful life (EO 13423, para 2(h)(iv)).

a. Guidance from the Instructions for Implementing EO 13423 state:


i. Comply with GSA procedures for the transfer, donation, sale and recycling of electronic equipment, provided at www.federalelectronicschallenge.net/resources/docs/gsa_eolfact.pdf, as well as any applicable Federal, State an local laws and regulations.

ii. Use national standards, best management practices, or a national certification program for recyclers. In the absence of national standards, best management practices, or a national certification program for recyclers, agencies shall use EPA’s Guidelines for Materials Management for Plug-In To eCycling partners found at www.epa.gov/epaoswer/osw/conserve/plugin/guide.htm.

iii. Comply with GSA’s Computers for Learning Program (CFL) under E.O. 12999 when transferring their computers and other eligible equipment and shall use GSA’s CFL website, www.computers.fed.gov, to affect the transfer.

iv. Ensure that applicable IT contracts for leased equipment incorporate adequate language to require that, at the end of the lease period, the equipment is reused, donated, sold, or recycled using environmentally sound management practices.

E. Key Compliance Definitions

• Agency - an executive agency as defined in section 105 of title 5, United States Code, excluding the Government Accountability Office. For the purpose of EO 13423, military departments, as defined in 5 USC 102, are covered under the auspices of DoD (EO 13423, paragraph 9(a) and Instructions for Implementing EO 13423, Section XIII, Definitions).

• Appropriate Facility or Organization - any Federal facility or organization that is subject to compliance with environmental regulation or conducts activities that can have a significant impact on the environment, either directly or indirectly, individually or cumulatively, due to the operations of that facility's or organization’s mission, processes, or functions (Instructions for Implementing EO 13423, Section XIII Definitions).

• Auditor - person with the competence to conduct an audit (ISO 14001:2004, para 3.1).

• Chairman of the Council - the Chairman of the Council on Environmental Quality, including in the Chairman’s capacity as Director of the Office of Environmental Quality (EO 13423, paragraph 9(b)).

• Continual Improvement - recurring process of enhancing the environmental management system (3.8) in order to achieve improvements in overall environmental performance (3.10) consistent with the organization's environmental policy. NOTE: The process need not take place in all areas of activity simultaneously. (ISO 14001:2004, para 3.2).

• Council - the Council on Environmental Quality (EO 13423, paragraph 9(c)).

• Correction - action taken to eliminate a detected nonconformity (ISO 14004:2004, para 3.3).

• Corrective Action - action to eliminate the cause of a detected nonconformity (ISO 14001:2004, para 3.3).

• Document - information and its supporting medium. NOTE 1: The medium can be paper, magnetic, electronic or optical computer disc, photograph or master sample, or a combination thereof. NOTE 2 Adapted from ISO 9000:2000, 3.7.2 (ISO 14001:2004, para 3.4).

• Energy Intensity - energy consumption per square foot of building space, including industrial or laboratory facilities (EO 13423, Section 9, paragraph i).

• Environment - surroundings in which an organization (3.16) operates, including air, water, land, natural resources, flora, fauna, humans, and their interrelation. NOTE Surroundings in this context extend from within an organization (3.16) to the global system (ISO 14001:2004, para 3.5).


http://www.federalelectronicschallenge.net/resources/docs/gsa_eolfact.pdf

• Environmental - environmental aspects of internal agency operations and activities, including those environmental aspects related to energy and transportation functions (EO 13423, 9(d)).

• Environmental Aspect - element of an organization's activities or products or services that can interact with the environment. NOTE A significant environmental aspect has or can have a significant environmental impact (ISO 14001:2004, para 3.6).

• Environmental Impact - any change to the environment (3.5), whether adverse or beneficial, wholly or partially resulting from an organization's environmental aspects (ISO 14001:2004, para 3.7).

• Environmental Management System (EMS) - part of an organization's management system used to develop and implement its environmental policy and manage its environmental aspects. NOTE 1: A management system is a set of interrelated elements used to establish policy and objectives and to achieve those objectives. NOTE 2 A management system includes organizational structure, planning activities, responsibilities, practices, procedures, processes and resources (ISO 14001:2004, para 3.8).

• Environmental Management System - a set of processes and practices that enable an organization to increase its operating efficiency, continually improve overall environmental performance and better manage and reduce its environmental impacts, including those environmental aspects related to energy and transportation functions. EMS implementation reflects accepted quality management principles based on the “Plan, Do, Check, Act,” model found in the ISO 14001:2004(E) International Standard and using a standard process to identify and prioritize current activities, establish goals, implement plans to meet the goals, evaluate progress, and make improvements to ensure continual improvement (Instructions for Implementing EO 13423, Section XIII Definitions).

• Environmental Objective - overall environmental goal, consistent with the environmental policy, that an organization sets itself to achieve (ISO 14001:2004, para 3.9).

• Environmental Performance - measurable results of an organization's management of its environmental aspects. NOTE: In the context of environmental management systems, results can be measured against the organization's environmental policy, environmental objectives, environmental targets and other environmental performance requirements (ISO 14001:2004, para 3.10).

• Environmental Performance Indicator (EPI) - specific expression that provides information about an organization's environmental performance (ISO 14004:2004, para 3.3).

• Environmental Policy - overall intentions and direction of an organization related to its environmental performance as formally expressed by top management. NOTE: The environmental policy provides a framework for action and for the setting of environmental objectives and environmental targets (ISO 14001:2004, para 3.11).

• Environmental Target - detailed performance requirement, applicable to the organization or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives (ISO 14001:2004, para 3.12).

• Facility - any building, installation, structure, land, and other property owned or operated by, or constructed or manufactured and leased to, the Federal Government, as well as any fixture. This term includes a group of facilities at a single or multiple location(s) managed as an integrated operation, as well as government-owned contractor operated facilities. For purposes of energy reporting, “facility” excludes land and sites where the utilities are not paid by the reporting agency (i.e., in cases where no separate periodic invoice for utilities is required to be paid) (Instructions for Implementing EO 13423, Section XIII Definitions).

• Greenhouse Gases - carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride (EO 13423, paragraph 9(e)).


• Interested Party - person or group concerned with or affected by the environmental performance of an organization (ISO 14001:2004, para 3.13).

• Internal Audit - systematic, independent and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which the environmental management system audit criteria set by the organization are fulfilled. NOTE In many cases, particularly in smaller organizations, independence can be demonstrated by the freedom from responsibility for the activity being audited (ISO 14001:2004, para 3.14).

• Life-cycle Cost-Effective - the life-cycle costs of a product, project, or measure are estimated to be equal to or less than the base case (i.e., current or standard practice or product) (EO 13423, paragraph 9(f)).

• Management Performance Indicator (MPI) - environmental performance indicator that provides information about the management efforts to influence an organization's environmental performance (ISO 14004:2004, para 3.3).

• Management Practice (MP) - practices that, although not mandated by law, are encouraged to promote safe operating procedures.

• New Renewable Sources - sources of renewable energy placed into service after January 1, 1999 (EO 13423, paragraph 9(g)).

• Nonconformity - non-fulfillment of a requirement (ISO 14001:2004, para 3.15).

• Operational Performance Indicator (OPI) - environmental performance indicator that provides information about the environmental performance of an organization's operations (ISO 14004:2004, para 3.3) .

• Organization - company, corporation, firm, enterprise, authority or institution, or part or combination thereof, whether incorporated or not, public or private, that has its own functions and administration . NOTE For organizations with more than one operating unit, a single operating unit may be defined as an organization (ISO 14001:2004, para 3.16).

• Preventive Action - action to eliminate the cause of a potential nonconformity (ISO 14001:2004, para 3.17).

• Prevention of Pollution - use of processes, practices, techniques, materials, products, services or energy to avoid, reduce or control (separately or in combination) the creation, emission or discharge of any type of pollutant or waste, in order to reduce adverse environmental impacts. NOTE Prevention of pollution can include source reduction or elimination, process, product or service changes, efficient use of resources, material and energy substitution, reuse, recovery, recycling, reclamation and treatment (ISO 14001:2004, para 3.18).

• Procedure - specified way to carry out an activity or a process. NOTE 1 Procedures can be documented or not (ISO 14001:2004, para 3.19).

• Record - document stating results achieved or providing evidence of activities performed (ISO 14001:2004, para 3.20).

• Renewable Energy - energy produced by solar, wind, biomass, landfill gas, ocean (including tidal, wave, current and thermal), geothermal, municipal solid waste, or new hydroelectric generation capacity achieved from increased efficiency or additions of new capacity at an existing hydroelectric project (EO 13423, paragraph 9(h)).

• Steering Committee - the Steering Committee on Strengthening Federal Environmental, Energy, and Transportation Management established under subsection 4(b) of this EO (EO 13423, paragraph 9(j)).


• Sustainable - to create and maintain conditions, under which humans and nature can exist in productive harmony, that permit fulfilling the social, economic, and other requirements of present and future generations of Americans (EO 13423, paragraph (9)k).

• United States - when used in a geographical sense, means the fifty states, the District of Columbia, the Commonwealth of Puerto Rico, Guam, American Samoa, the United States Virgin Islands, and the Northern Mariana Islands, and associated territorial waters and airspace (EO 13423, paragraph 9(l)).

F. Records To Review

EMS manual and the procedures applicable to the area being audited Regulatory documents and specifications that typically apply in the area being audited The findings of the last audit of the area and any available audit checklists relating to that area Any records of corrective action analysis relating to that area

G. Physical Features To Inspect

• None


H. Guidance for EMS Checklist Users

REFER TOCHECKLISTITEMS:

All Facilities EM.1.1.US. through EM.1.3.US

Missing, Risk Management, and Positive Checklist Items

EM.2.1.US. through EM.2.3.US

Policy EM.10.1.US. and EM.10.2.US

Planning EM.20.1.US. through EM.20.7.US.

Implementation EM.30.1.US through EM.30.6.US

Monitoring and Measuring EM.40.1.US through EM.40.6.US

Management Review EM.50.1.US. through EM.50.2.US.

Appendix 14-1, EMS Metrics

Appendix 14-2, Identification of Aspects and Impacts

Appendix 14-3, Examples of Activities, Products and Services and Their Associated Environmental Aspects, Objectives, Targets, Programs, Indicators, Operational Control, and Monitoring and Measurement.

Appendix 14-4, Examples of Environmental Training That Can Be Provided by a Facility


COMPLIANCE CATEGORY:ENVIRONMENTAL MANAGEMENT SYSTEMS

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REGULATORY REQUIREMENTS:

REVIEWER CHECKS:March 2009

EMS

EM.1All Facilities

EM.1.1.US. The current status of any ongoing or unresolved consent orders, compliance agreements, notices of violation (NOVs), interagency agreements, or equivalent state enforcement actions is required to be examined (a finding under this checklist item will have the enforcement action/ identifying information as the citation).

Determine if noncompliance issues have been resolved by reviewing a copy of the previous report, consent orders, compliance agreements, NOVs, interagency agreements, programmatic agreements executed with the SHPO, NEPA documents with specific mitigation requirements, management plans, litigation settlement agreements, court imposed injunctions, or equivalent state enforcement actions.

EM.1.2.US. Appropriate organizational levels are required to develop, implement, and maintain an EMS to be used to identify and address agency environmental, transportation, and energy issues (EO 13423, Section 3(b); Instructions for Implementing EO 13423, Section II, paragraphs A and B).

(NOTE: The phrase “appropriate organizational level” is not specifically defined but does include agency, sub-agency, bureau, service, command, and/or facility.)

(NOTE: According to the June 18, 2007 Federal Register notice [page 33504] the Instructions for Implementing EO 13423, “should be considered mandatory, and agencies are expected to implement them as part of complying with the EO.”)

Verify that where an agency’s environmental issues, including the goals identified in section 2 of EO 13423., are best addressed in management of the operational elements of its facilities or organizations, and/or where pursuit of sustainable practices is best carried out at the facility or organizational level, the agency ensures that all appropriate facilities or organizations develop, implement, and maintain an EMS.

(NOTE: Facilities previously identified under EO 13148 as “appropriate facilities” and already underway with implementation as of the date of the E.O. shall ensure their EMS is fully implemented by December 2008, and maintained as specified in the instructions. Agencies may revise schedules relative to this deadline after consultation with OFEE, specifically in regard to the definition of “fully implemented” requiring an external audit.)

Verify that, where an agency’s environmental issues, including the goals identified in EO 13423 are primarily represented in the administrative, decision-making, and/or business infrastructure actions of that agency or its component organizations, and/or where pursuit of sustainable practices is best carried out at



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the agency or component level, the agency develops, implements, and maintains an EMS at that level to respond to those issues and opportunities.

(NOTE: Where appropriate, agencies may develop, implement, and maintain an EMS at both the organizational or facility level and at the agency or component level.)

(NOTE: Agencies developing additional EMSs as a result of EO 13423 and these implementing instructions shall establish an EMS implementation schedule, in consultation with OFEE.)

Verify that the EMS reflects the EMS elements and framework found in the ISO 14001:2004(E) International Standard or equivalent.

Verify that the EMS objectives include the goals from Section 2 of EO 13423.

Verify that the EMS is used to support compliance with environmental and energy regulations, to enable the prevention of pollution and efficient energy management, and to support other objectives identified by the facility.

(NOTE: Where tenant, contractor, and concessionaire activities affect an agency’s environmental, transportation, or energy issues, those activities shall be addressed in the development, implementation, and maintenance of the EMS. Requirements shall be included in all appropriate contracts to ensure that the contractors’ roles and responsibilities under the EMS are properly addressed. Where an agency owns or manages public lands on which non-governmental entities are present and whose activities are permitted, licensed, or otherwise authorized or regulated, that agency shall, at a minimum, consider the environmental impacts of such activities in its EMS.)

EM.1.3.US. Where an EMS exists at the appropriate organization level, the elements of the Compliance Management Plan must be part of the EMS (Instructions for Implementing EO 13423, Section III, paragraph A and B).


Verify that, where an EMS exists at the appropriate organization level, the elements of the Compliance Management Plan are part of the EMS.

(NOTE: A separate compliance management plan is not required.)

(NOTE: The development, implementation, and maintenance of compliance management plans developed under E.O. 13423 and the implementing instructions shall not affect, pre-empt, nor supersede EPA’s environmental regulatory and enforcement requirements.)

Verify that each compliance management plan formally includes the following elements at the appropriate level:



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a clear, sustained, and up-to-date commitment is integrated into strategic plans and policies for senior leadership to achieve and maintain environmental compliance.

clearly articulated roles and responsibilities related to environmental performance at all levels to ensure accountability for less than desired environmental performance.

implementation of an environmental compliance review and audit program that identifies compliance needs and possible root cause of non-compliance.

integration of compliance management system information and resource allocation procedures to ensure that audit findings and possible non-compliance root causes are tracked and addressed, including allocation of funding.



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EMS

EM.2Missing, Risk Management, and Positive Checklist Items

EM.2.1.US. Facilities are required to comply with all applicable Federal regulatory requirements not contained in this checklist (a finding under this checklist item will have the citation of the applied regulation as a basis of finding).

Determine if any new regulations concerning EMS have been issued since the finalization of the manual.

Determine if the facility has activities or facilities that are regulated but not addressed in this checklist.

Verify that the facility is in compliance with all applicable and newly issued regulations.

EM.2.2.US. Risk management techniques should be promoted in environmental efforts (MP).

Determine if risk management techniques are promoted in environmental efforts.

EM.2.3.US. Facilities should go above and beyond statutory and regulatory compliance (MP).

Determine if the facility has gone above and beyond simply complying with environmental requirements.



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EMS

EM.10Policy

EM.10.1.US. Federal facility EMS should have a policy statement endorsed by top management (MP).

(NOTE: This checklist item is drawn from ISO 14001:2004, para 4.2a through 4.2e, Appendix A, para. A2; and ISO 14004:2004, para 4.1.3 and 4.2.)

Verify that the policy statement:

is appropriate to the nature, scale and environmental impacts of the federal facility’s activities, products and services

includes a commitment to continual improvement and prevention of pollution

includes a commitment to comply with applicable legal requirements and with other requirements to which the facility subscribes which relate to its environmental aspects

includes a commitment to set an example in the field of environmental management

provides the framework for setting and reviewing environmental objectives and targets

is documented, implemented and maintained is available to the public.

Verify that, where possible, the policy statement is tied to the facility’s Agency/Departmental/Bureau mission and priorities.

Verify that, in the process of developing its environmental policy, a facility considers the following:

its mission, vision, core values and beliefs coordination with other facility policies (e.g. quality, occupational health

and safety) the requirements of, and communication with, interested parties guiding principles specific local or regional conditions its commitments to prevention of pollution and continual improvement its commitment to comply with legal requirements and other requirements

to which the facility subscribes.

Verify that top management has endorsed the policy statement.

Verify that the environmental policy recognizes that all activities, products and services within the defined scope of a facility’s EMS can cause impacts on the environment.

(NOTE: Endorsement may take a variety of forms depending on the



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facility/organizations culture and structure.

(NOTE: Interview personnel who are familiar with the policy development process. The following questions will assist in verifying conformance to this requirement.

What is top management’s definition of the organization’s environmental policy?

How does top management ensure that its policy is appropriate to the nature, scale, and environmental impacts of its activities, products, or services?

How does the policy guide the organization towards appropriate technologies and management practices?

Is the policy consistent with other organizational policies? If so, how? How does the policy guide the setting of environmental objectives and

targets? How does the policy guide the organization in reviewing and adjusting its

environmental objectives and targets?)

(NOTE: The environmental policy is the driver for implementing and improving an organization's EMS so that it can maintain and potentially improve its environmental performance. Therefore, this policy should reflect the commitment of top management to comply with applicable legal requirements and other requirements, to prevent pollution and to continually improve. The environmental policy forms the basis upon which the organization sets its objectives and targets. The environmental policy should be sufficiently clear to be able to be understood by internal and external interested parties, and should be periodically reviewed and revised to reflect changing conditions and information.)

(NOTE: The area of application (i.e. scope) of the policy should be clearly identifiable and should reflect the unique nature, scale and environmental impacts of the activities, products and services within the defined scope of the EMS. The “scope” also includes the boundaries of the organization to which the EMS applies. Once the scope of the environmental management system has been defined, all activities, products and services of the organization that are within the defined scope should be included in the EMS.)

(NOTE: Top management usually consists of a person or group of people who direct and control an organization at the highest level.)

(NOTE: Both auditors who are reviewing an EMS in the context of a regulatory compliance audit and auditors who are conducting EMS conformance audits must show restraint in how they comment and present valid findings. If a facility has a procedure for doing something, the organizations is doing what it says it will do, and that procedure appears to be working, then the facility is in conformance, whether or not the auditor happens to think that there is a better procedure. If asked, the auditor can provide additional information as an addition to the statement of fact that the site is in conformance with their chosen



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EMS model and site-specific EMS implementation requirements.)

EM.10.2.US. EMS policy should be communicated to all persons working for or on behalf of the facility as well as to the public (MP).

(NOTE: This checklist item is drawn from ISO 14001:2004, para 4.2f, 4.2g, and Appendix A, para A2.)

Verify that the EMS policy is communicated to all persons working for or on behalf of the facility.

Verify that the EMS policy is communicated to the public.

Verify that, if appropriate, the EMS policy is communicated to external entities and individuals.

(NOTE: The following questions will assist in verifying conformance to this requirement.

What are the procedures to check if the environmental policy is understood and practiced?)

(NOTE: Interview personnel in various management levels at the facility. The following questions will assist in verifying conformance to this requirement.

Are you familiar with the policy? Are you familiar with the EMS program?)

(NOTE: The environmental policy should be communicated to all persons who work for, or on behalf of, the organization, including contractors working at an organization's facility. Communication to contractors can be in alternative forms to the policy statement itself, such as rules, directives and procedures, and may therefore only include pertinent sections of the policy. The facility’s environmental policy should be defined and documented by its top management within the context of the environmental policy of any broader corporate body of which it is a part, and with the endorsement of that body. Top management usually consists of a person or group of people who direct and control an organization at the highest level.)

(NOTE: Both auditors who are reviewing an EMS in the context of a regulatory compliance audit and auditors who are conducting EMS conformance audits must show restraint in how they comment and present valid findings. If a facility has a procedure for doing something, the organizations is doing what it says it will do, and that procedure appears to be working, then the facility is in conformance, whether or not the auditor happens to think that there is a better procedure. If asked, the auditor can provide additional information as an addition to the statement of fact that the site is in conformance with their chosen EMS model and site-specific EMS implementation requirements.)



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EMS

EM.20Planning

EM.20.1.US. Federal facilities should develop and implement a procedure to identify environmental aspects and their impacts (MP).

(NOTE: This checklist item is drawn from ISO 14001:2004, para 4.3.1 and ISP 14004:2004, para 4.3.1.)

Verify that the facility has established, implemented and maintains a procedure(s):

to identify the environmental aspects of its activities, products, and services within the defined scope of the EMS that it can control, and those that it can influence taking into account planned or new developments, or new or modified activities, products and services

to determine those aspects that have or can have significant impact(s) on the environment (i.e. significant environmental aspects).

(NOTE: For example, if a facility washes vehicles/heavy equipment onsite, there is a potential to impact groundwater or surface water with oily residues from the vehicle or heavy equipment.)

Verify that the facility documents the environmental aspects and those which are significant environmental aspects.

(NOTE: See Appendix 14-2 for additional guidance on the identification of aspects and impacts.)

Verify that the significant environmental aspects are taken into account in establishing, implementing and maintaining the EMS.

(NOTE: An facility’s policy, objectives and targets, training, communications, operational controls and monitoring programs should be primarily based on knowledge of its significant environmental aspects, although issues such as applicable legal requirements and other requirements to which the organization subscribes and the views of interested parties will also need to be taken into account.)

(NOTE: The identification of significant environmental aspects is an ongoing process that enhances an organization's understanding of its relationship to the environment and contributes to continual improvement of its environmental performance through enhancement of its EMS.)

(NOTE: There is no single approach for identifying environmental aspects and environmental impacts and determining significance that will suit all facilities/organizations.)



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Verify that new or recently changed products, activities, or services are adequately addressed in the most recent list of aspects and impacts.


What is the procedure to identify significant environmental aspects? How is it maintained? What are the environmental aspects of the organization’s activities,

products, and services? Is there an assignment of responsibility for periodic review and application

of the procedure? If so, who is assigned this responsibility? How does the procedure enable the organization to determine which

environmental aspects have or could have significant impacts on the environment?

How do you identify all aspects of your activities, products, and services? How does the organization consider its environmental aspects when setting

its objectives? How does the organization consider normal operating conditions, shut

down and start up conditions, and the realistic significant impacts associated with potential or emergency situations?

How are input materials considered? How are proper use and disposal issues considered? What procedures are used to keep this information up-to-date? How will any intended changes or additions to activities, products, or

services affect the environmental aspects and their associated impacts?)

(NOTE: Interview personnel in various management levels at the facility. The following questions will assist in verifying conformance to this requirement.

What are the significant aspects and impacts associated with your function? How do you know what to do? (Ask for procedures and operating criteria). What specific training have you received? Are there any objectives and targets associated with your function? Are you responsible for any monitoring and measurement activities? What records do you keep?)


EM.20.2.US. The development of EMS environmental objectives and

(NOTE: This checklist item is drawn from ISO 14001:2004, para 4.3.2, Appendix A, para. A.3.2 and ISO 14004:2004, para 4.3.2)



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targets should include the consideration of regulatory requirements applicable to the federal facility (MP).

(NOTE: This may be done through an Agency/Bureau/Departmental auditing program and interaction with state and federal compliance assistance organizations.)

Verify that the facility has established, implemented, and maintains a procedure(s) to:

identify and have access to the applicable legal requirements and other requirements applicable to the facility and related to its environmental aspects

determine how the applicable requirements apply to its environmental aspects.

Verify that the facility ensures that the applicable legal requirements and other requirements to which the organization subscribes are taken into account in establishing, implementing and maintaining its EMS.

(NOTE: See Appendix 14-3 for examples of activities, products and services and their associated environmental aspects, objectives, targets, programs, indicators, operational control, and monitoring and measurement.)

(NOTE: Examples of other requirements to which the organization may subscribe include, if applicable,

agreements with public authorities, agreements with customers, non-regulatory guidelines, voluntary principles or codes of practice, voluntary environmental labeling or product stewardship commitments, requirements of trade associations, agreements with community groups or non-governmental organizations, public commitments of the organization or its parent organization, corporate/company requirements.

The determination of how legal and other requirements apply to an organization's environmental aspects is usually accomplished in the process of identifying these requirements. It may not be necessary, therefore, to have a separate or additional procedure in order to make this determination.)

(NOTE: Information on internal performance criteria, together with applicable legal requirements and other requirements to which the organization subscribes, can assist an organization in developing its objectives and targets. Where legal and other requirements do not exist or are insufficient to meet the organization's needs, an organization may develop and implement internal performance criteria to meet its needs. Examples of internal performance criteria might include limitations on types and quantities of fuels or hazardous substances that can be used or managed at a facility or limitations on air emissions that go beyond legal compliance requirements.)

(NOTE: Both auditors who are reviewing an EMS in the context of a regulatory



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compliance audit and auditors who are conducting EMS conformance audits must show restraint in how they comment and present valid findings. If a facility has a procedure for doing something, the organizations is doing what it says it will do, and that procedure appears to be working, then the facility is in conformance, whether or not the auditor happens to think that there is a better procedure. If asked, the auditor can provide additional information as an addition to the statement of fact that the site is in conformance with their chosen EMS model and site-specific EMS implementation requirements.)

EM.20.3.US. EMS Planning should include the development of environmental objectives and targets (MP).

(NOTE: This checklist item is drawn from ISO 14001:2004, para 4.3.3, Appendix A, para A3.3, and ISO 14004:2004, para 4.3.3)

Verify that environmental planning includes the identification of environmental objectives and targets.

Verify that the facility has established, implemented, and maintains documented environmental objectives and targets, at relevant functions and levels within the facility.

Verify that, when setting objectives and targets, the facility/organization considered several inputs, including:

principles and commitments in its environmental policy its significant environmental aspects (and information developed in

determining them) applicable legal requirements and other requirements to which the

organization subscribes effects of achieving objectives on other activities and processes views of interested parties technological options and feasibility financial, operational, and organizational considerations, including

information from suppliers and contractors possible effects on the public image of the organization findings from environmental reviews other organizational goals.

Verify that the objectives and targets are specific and measurable.

Verify that objectives and targets cover and short- and long-term issues.

Verify that objectives were set at the top level of the facility and at other levels and functions where activities important to meeting the environmental policy commitments and overall organizational goals are carried out.

(NOTE: An objective can be expressed directly as a specific performance level, or may be expressed in a general manner and further defined by one or more targets. When targets are set, they should be measurable by performance levels that need to be met to ensure the achievement of the related objectives. Targets



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may need to include a specified time frame to be delivered by the program.)

Verify that objectives describe the organization's goals for environmental performance.

(NOTE: Depending on the complexity of the facility, separate targets and objectives may be appropriate at varying management and operational levels of the facility.)

(NOTE: When establishing and reviewing its objectives and targets, a facility shall take into account the legal requirements and other requirements to which the organization subscribes, and its significant environmental aspects. It shall also consider its technological options, its financial, operational and business requirements, and the views of interested parties.)

Verify that, where practicable, the objectives and targets are consistent with:

environmental policy commitments to pollution prevention compliance with applicable legal requirements compliance with other applicable requirements.

Verify that the objectives and targets incorporate continual improvement.

Verify that part of the planning process includes the elaboration of a program addressing the following items for achieving the facility’s environmental objectives and targets:

roles responsibilities processes resources timeframes priorities the actions necessary for achieving the environmental objectives and

targets.

Verify that a facility establishes objective, verifiable, measurable, and reproducible environmental performance indicators.

(NOTE: See ISO 14031 and ISO/TR 14032 for further guidance on the selection and use of environmental performance indicators.)

(NOTE: Progress towards an objective can generally be measured using environmental performance indicators such as:

quantity of raw material or energy used quantity of emissions such as CO2 waste produced per quantity of finished product



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efficiency of material and energy used number of environmental incidents (e.g. excursions above limits) number of environmental accidents (e.g. unplanned releases) percentage waste recycled percentage recycled material used in packaging number of service vehicle kilometers per unit of production quantities of specific pollutants emitted, e.g. NOx, SO2, CO, VOCs, Pb,

CFCs investment in environmental protection number of prosecutions land area set aside for wildlife habitat.)

Verify that the metrics used to measure target attainment are valid.

(NOTE: When considering its technological options, a facility should consider the use of best-available techniques where economically viable, cost-effective and judged appropriate. The creation and use of one or more programs is important to the successful implementation of an EMS. Each program should describe how the organization's objectives and targets will be achieved, including timescales, necessary resources and personnel responsible for implementing the program. These) programs may be subdivided to address specific elements of the organization's operations. The program should include, where appropriate and practical, consideration of planning, design, production, marketing and disposal stages. This may be undertaken for either current and new activities, products or services. For products, this can address design, materials, production processes, use and ultimate disposal. For installations or significant modifications of processes, this can address planning, design, construction, commissioning, operation and, at the appropriate time determined by the organization, decommissioning.)


How are the aspects of contractor and supplier activities considered when setting objectives?

What are the significant impacts and how are they used in establishing environmental goals?

What is the process for balancing and resolving conflicts between environmental and other business objectives and priorities?

How do you consider your technological options when establishing and reviewing the objectives and targets?

How do you prepare cost-benefit analyses? Where are these documented? How do the employees responsible for achieving the objectives and targets

provide input into their development?)

(NOTE: Both auditors who are reviewing an EMS in the context of a regulatory compliance audit and auditors who are conducting EMS conformance audits must show restraint in how they comment and present valid findings. If a facility has a procedure for doing something, the organizations is doing what it



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says it will do, and that procedure appears to be working, then the facility is in conformance, whether or not the auditor happens to think that there is a better procedure. If asked, the auditor can provide additional information as an addition to the statement of fact that the site is in conformance with their chosen EMS model and site-specific EMS implementation requirements.)

EM.20.4.US. EMS Planning should include the identification of environmental responsibilities organization/facility-wide (MP).

(NOTE: This checklist item is drawn from ISO 14001:2004, para 4.3.3 and ISO 14004:2004, para 4.3.3.1.)

Verify that, as a part of objectives and targets development, the facility establishes, implements and maintains a program(s) for achieving its objectives and targets, including:

designation of responsibility for achieving objectives and targets at relevant functions and levels of the organization, and

the means and time-frame by which they are to be achieved.

Verify that environmental responsibilities are documented in job descriptions.

Verify that environmental roles and responsibilities are not confined to the environmental management function,

Verify that a facility identifies the contributions of different levels and functions of the facility in achieving the objectives, and makes the individual members of the facility aware of their responsibilities.


What is the facilities procedure for defining and documenting roles, responsibilities, and authorities throughout the organization?

How are the roles, responsibilities, and authorities communicated to facilitate effective environmental management?

How are participants made aware of their roles and responsibilities within the EMS?)


EM.20.5.US. Successful implementation of the EO 13423 must be included in

Verify that the successful implementation of the E.O. is included in performance standards and performance evaluations for facility managers, environmental and energy program managers, vehicle fleet managers, contracting officials, and



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performance standards and performance evaluations (or equivalent) facility managers, environmental and energy program managers, vehicle fleet managers, contracting officials, and others as appropriate (Instructions for Implementing EO 13423, Section I, paragraph D4).

others as appropriate.


EM.20.6.US. EMS planning should include a comparison of existing programs to an accepted EMS framework (MP).

(NOTE: This checklist item is drawn from ISO 14001:2004, Appendix A and ISO 14004:2004, para 4.1.4.)

Verify that EMS planning includes a comparison to an accepted EMS framework (i.e., a gap analysis).

(NOTE: Appendix A of ISO 14001:2004 indicates that an organization with no existing EMS should, initially, establish its current position with regard to the environment by means of a review. The aim of this review is to consider all environmental aspects of the organization as a basis for establishing the EMS.)

Verify that the comparison/review covers the following four key areas:

identification of environmental aspects, including those associated with normal operating conditions, abnormal conditions including start-up and shut-down, and emergency situations and accidents

identification of applicable legal requirements and other requirements to which the organization subscribes

examination of existing environmental management practices and procedures, including those associated with procurement and contracting activities

evaluation of previous emergency situations and accidents.)

(NOTE: The review can also include additional considerations, such as: an evaluation of performance compared with applicable internal criteria,

external standards, regulations, codes of practice and sets of principles and guidelines

opportunities for competitive advantage, including cost reduction opportunities

the views of interested parties other organizational systems that can enable or impede environmental

performance.)

(NOTE: Methods that can be used to examine existing environmental management practices and procedures include:

interviews with persons previously or currently working for or on behalf of the organization to determine the scope of the organization's past and



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current activities, products and services evaluation of internal and external communications that have taken place

with the organization's interested parties, including complaints, matters related to applicable legal requirements or other requirements to which the organizations subscribes, past environmental or related incidents and accidents

gathering information related to current management practices, such as: process controls on purchasing hazardous chemicals the storage and handling of chemicals [e.g. secondary containment;

housekeeping, storage of incompatible chemicals] controls on fugitive emissions waste disposal methods emergency preparedness and response equipment use of resources [e.g. use of office lights after working hours] vegetation and habitat protection during construction temporal changes in processes [e.g. changes to crop rotation patterns

affecting fertilizer discharges to water] environmental training programs review and approval process for operational control procedures, and completeness of monitoring records and/or ease in retrieving

historical records.The review can be conducted using checklists, process flowcharts, interviews, direct inspection and past and current measurements, results of previous audits or other reviews depending on the nature of the facility/organization's activities, products and services. The results of the review should be documented so that it can be used to contribute to setting the scope and establishing or enhancing the facility/organization's EMS, including its environmental policy.) (NOTE: Individual Agencies may mandate the use of a particular model. One widely accepted EMS model is the ISO 14001 Standard. Another less widely accepted model is CEMP. The European Union’s Eco-Management and Audit Scheme [EMAS] is not typically used in the U.S.)


EM.20.7.US. The facility/organization budget should address the costs of EMS (MP).

(NOTE: This checklist item is drawn from ISO 14004:2004, para 4.4.1.)

Verify that EMS-related activities such as initial self-assessments, development of performance measures, policy, and establishment of management systems are addressed in the budget requests.



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Verify that, when identifying the resources needed to establish, implement and maintain the EMS, a facility considers:

infrastructure information systems training technology financial, human and other resources specific to its operations.

Verify that resource allocations consider both the current and future needs of an organization.

(NOTE: In allocating resources, an organization can develop procedures to track the benefits as well as the costs of its environmental or related activities. Issues such as the cost of pollution control, wastes and disposal can be included.)

Verify that resources and their allocation are reviewed periodically, and in conjunction with the management review to ensure their adequacy.

(NOTE: In evaluating adequacy of resources, consideration should be given to planned changes and/or new projects or operations.)

(NOTE: On 27 June 2002, OMB issued guidance in its Circular No. A-11 to Federal agencies regarding preparation and submission of their FY 2004 budgets. OMB Circular No. A-11 is considered an indicator of planning priorities in the Administration’s annual budget. The guidance included a new statement in section 31, Compliance With Administration Policies and Other General Requirements, supporting the use of EMS by all Federal agencies. The guidance reads: “Federal agencies should develop and implement environmental management systems in order to integrate environmental accountability into agency day-to-day decision-making and long-term planning processes across all agency missions, activities and functions. These efforts must be funded within guidance totals. They should include, but not be limited to, the following components: initial self-assessments, development of performance measures, policy, and establishment of management systems.”)


What are the procedures for defining and providing resources to achieve the environmental program’s objectives and targets?)

(NOTE: Both auditors who are reviewing an EMS in the context of a regulatory compliance audit and auditors who are conducting EMS conformance audits must show restraint in how they comment and present valid findings. If a facility has a procedure for doing something, the organizations is doing what it says it will do, and that procedure appears to be working, then the facility is in conformance, whether or not the auditor happens to think that there is a better



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procedure. If asked, the auditor can provide additional information as an addition to the statement of fact that the site is in conformance with their chosen EMS model and site-specific EMS implementation requirements.)



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EMS

EM.30Implementation

EM.30.1.US. All personnel whose actions are affected by E.O. 13423 must receive initial awareness training as well as necessary refresher training on the goals of the E.O and any related instructions (Instructions for Implementing EO 13423, Section V, paragraph A).


Verify that all personnel whose actions are affected by E.O. 13423 receive initial awareness training as well as necessary refresher training on the goals of the E.O and any related instructions, including the environmental impacts of the employees’ actions.

(NOTE: The interagency workgroups shall discuss training needs and develop guidance on training, as appropriate.)

(NOTE: The following portion of this checklist item is drawn from ISO 14001:2004, para 4.4.2 and ISO 14004:2004, para 4.4.2.)

Verify that the facility establishes, implements and maintains a procedure(s) to make persons working for it or on its behalf aware of:

the importance of conformity with the environmental policy and procedures and with the requirements of the EMS

the significant environmental aspects and related actual or potential impacts associated with their work, and the environmental benefits of improved personal performance

their roles and responsibilities in achieving conformity with the requirements of the EMS

the potential consequences of departure from specified procedures.

(NOTE: All persons working for or on behalf of an organization include employees, contractors and, as applicable, other involved parties.)

(NOTE: Environmental responsibilities may include: who to call in case of a spill or other environmental exposure what to do if unsure how to dispose of an item taking advantage of recycling or pollution prevention opportunities.)

(NOTE: The process of communicating environmental responsibilities may differ depending on the level of responsibilities. For example, it might be done as a part of an existing regularly scheduled meeting, through email alerts, through internal memos, through heightened awareness training.)

Verify that the methodology used to communicate environmental responsibilities



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works by asking individuals what their environmental responsibilities/activities are. (NOTE: Asking employees the following questions will assist in verifying conformance to this requirement.

What are your roles and responsibilities with respect to environmental management?

Where are these roles and responsibilities documented? What is your authority to fulfill these roles and responsibilities? Where is this authority documented? How were you made aware of your roles, responsibilities, and authorities? Do you understand your responsibilities within the EMS?)


EM.30.2.US. When implementing EMS, employees must receive environmental management training (Instructions for Implementing EO 13423, Section V, paragraph B).


Verify that environmental management training is provided to employees.

(NOTE: Each agency shall identify the specific training needs of individual employees, which shall be a function of operations and responsibilities related to the E.O. goals and other legal requirements.)

Verify that the training addresses the role of individual employees in ensuring the pursuit of the policy, goals, and objectives set forth in the E.O. and emphasizes the benefit of improved environmental, energy, and transportation management to the mission of the organization.

Verify that training is provided to employees and others, such as contractors, as appropriate, at all levels, and repeated as necessary to ensure improved awareness.

(NOTE: Training can be, but is not limited to, agency-developed training, training provided by a third party such as a contractor or non-profit organization, training provided by another agency, Defense Acquisition University or Federal Acquisition Institute courses, or educational sessions provided during relevant conferences such as the annual Federal environmental symposium, annual GSA



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Expo, DoD’s annual Joint Services Environmental Management conference, FedFleet, or the annual Energy conference.)

(NOTE: The following portion of this checklist item is drawn from ISO 14001:2004, para 4.4.2, Appendix A, para A.4.2, and ISO 14004:2004, para 4.4.2)

Verify that, for those activities that are most important in the management of its environmental aspects, the facility identifies the knowledge, understanding, skills, or abilities that make an individual competent to perform them.

Verify that, once required competence is identified, the facility ensures that persons performing these activities have the required competence.

Verify that the facility ensures that any person performing tasks for it or on its behalf that have the potential to cause a significant environmental impact(s) identified by the organization is competent on the basis of appropriate education, training, or experience.

Verify that personnel at all organizational levels are informed of, and trained to execute, their environmental responsibilities by asking them how and on what they are trained.

Verify that the facility retains records supporting that personnel are competent.

Verify that the facility identifies training needs associated with its environmental aspects and its EMS.

(NOTE: See Appendix 14-4 for examples of types of environmental training that can be provided by a facility.)

(NOTE: Awareness, knowledge, understanding, and competence may be obtained or improved through training, education, or work experience. Competence is based on appropriate education, training, skills and/or experience. Competence requirements should be considered in recruiting, training and developing future skills and abilities of persons working for or on behalf of the organization. Competence should also be considered in selecting contractors and others working for or on behalf of the organization.)

Verify that the facility has identified and assessed any differences between the competence needed to perform an activity and that possessed by the individual required to perform the activity.

Verify that any difference between the competence needed to perform an activity and that possessed by the individual required to perform the activity is rectified through additional education, training, skills development, etc.

(NOTE: The facility will provide training or take other action to meet these



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needs, and retain associated records.)

(NOTE: The facility should require that contractors working on its behalf are able to demonstrate that their employees have the requisite competence and/or appropriate training.)

(NOTE: Interview management responsible for identifying training needs. The following questions are examples to assist in verifying conformance to this requirement and may or may not be appropriate at an individual facility.

How does the organization identify its environmental training needs? How are the environmental training needs of specific job functions

analyzed? How are the organization’s environmental training programs developed,

reviewed, and modified? How does the organization ensure that employee knowledge of regulatory

requirements, internal standards, and organization environmental policies and objectives is current?

What is the appropriate training for each area?)


EM.30.3.US. EMSs will support appropriate inclusion of local participation, consistent with the objectives of EO 13352 of August, 2004, Facilitation of Cooperative Conservation (Instructions for Implementing EO 13423, Section II, paragraph A(3)).


Verify that EMSs support appropriate inclusion of local participation, consistent with the objectives of EO 13352 of August, 2004, Facilitation of Cooperative Conservation.

(NOTE: The following portion of this checklist item is drawn from ISO 14001:2004, para 4.4.3, Appendix A, para A.4.3 and ISO 14004:2004, para 4.4.3.)

Verify that, in relation to environmental aspects and EMS, the facility establishes, implements, and maintains a procedure(s) for:

internal communication among the various levels and functions of the organization,

receiving, documenting and responding to relevant communication from



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external interested parties.

(NOTE: Methods of internal communication may include regular work group meetings, newsletters, bulletin boards, suggestion boxes, email, and intranet sites.)

Verify that employees know how to implement the procedure.

Verify that the facility has decided whether to communicate externally about its significant environmental aspects and has documented its decision.

Verify that, if the facility has decided to communicate externally about its significant environmental aspects, the facility has established and implemented a method for this external communication.

(NOTE: The purposes and benefits of communication include: demonstrating the organization's commitment and efforts to improve

environmental performance, as well as the results of such efforts raising awareness and encouraging dialogue about the organization's

environmental policy, environmental performance and other relevant achievements

receiving, considering and responding to questions, concerns or other inputs

promoting continual improvement of environmental performance.)

Verify that personnel are identified as responsible for contacting external organizations/agencies about environmental management issues, including emergency planning.

(NOTE: Examples of information to be communicated include: general information about the organization management statement if applicable environmental policy, objectives and targets environmental management processes (including employee and interested

party involvement) the organization's commitments to continual improvement and prevention

of pollution information related to environmental aspects of products and services,

conveyed through for example environmental labels and declarations information on the organization's environmental performance including

trends (e.g. waste reduction, product stewardship, past performance) the organization's compliance with legal and other requirements to which

the organization subscribes, and corrective actions taken in response to identified instances of noncompliance

supplementary information in reports, such as glossaries financial information such as cost savings or investments in environmental

projects potential strategies to improve an organization's environmental



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performance information related to environmental incidents sources for further information, such as contact person(s) or websites.)

(NOTE: For example: Who tracks environmental permits and contacts the appropriate agencies

when renewal is necessary? Who notifies the appropriate state and local entities of a spill/release? How are personnel informed of a change in environmental managers or

permit requirements?) What do you do if you receive environmental-related communication from

external parties?)


EM.30.4.US. EMS is the management framework which identifies, manages, and improves EO 13423 sustainable practices while also identifying and collecting performance measurement information (Instructions for Implementing EO 13423, Section II, paragraph A(1)).


Verify that the EMS identifies, manages, and improves EO 13423 sustainable practices.

(NOTE: The following portion of this checklist item is drawn from ISO 14001:2004, para 4.4.6, Appendix A, para A.4.6; ISO 14004: 2004, para 4.4.6)

Verify that operations, activities, and processes at a facility/organization are planned and managed to align with EMS policy, objectives and targets.

(NOTE: A facility might use operational controls to: manage identified significant environmental aspects ensure compliance with legal requirements and other requirements to which

the organization subscribes achieve objectives and targets and ensure consistency with its

environmental policy, including the commitment to prevention of pollution and continual improvement,

avoid or minimize environmental risks.)

(NOTE: A facility should evaluate those of its operations that are associated with its identified significant environmental aspects and ensure that they are



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conducted in a way that will control or reduce the adverse impacts associated with them, in order to fulfill the requirements of its environmental policy and meet its objectives and targets. This should include all parts of its operations, including maintenance activities.)

Verify that the facility has identified, and plans, those operations that are associated with the identified significant environmental aspects consistent with its environmental policy, objectives and targets, in order to ensure that operations are carried out under specified conditions, by:

establishing, implementing and maintaining a documented procedure to control situations where their absence could lead to deviation from the environmental policy, objectives and targets

stipulating the operating criteria in the procedure establishing, implementing and maintaining procedures related to the

identified significant environmental aspects of goods and services used by the organization and communicating applicable procedures and requirements to suppliers, including contractors.

(NOTE: For example, if there is a target of 50% solid waste reduction, recycling options have to be readily available throughout the facility/operation.)

(NOTE: Examples of operations include: acquisition, construction or modification of property and facilities contracting customer service handling and storage of raw materials marketing and advertising production and maintenance processes purchasing research, design, and development engineering storage of products transportation utility processes [e.g. energy and water supply, recycling, waste and

wastewater management].)

(NOTE: A common approach to establishing operational controls includes: choosing a method of control selecting acceptable operating criteria establishing procedures, as needed, that define how identified operations

are to be planned, carried out and controlled documenting these procedures, as needed, in the form of instructions, signs,

forms, videos, photos, etc.)


Who has been identified and given authority to oversee and implement the policy?



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How do the management units within the organization implement the policy?

How is the environmental policy implemented throughout the organization?)

Are individuals aware of the environmental policy? How were they made aware?

What does the environmental policy mean to individuals? What is your procedure for specifying operating criteria in the documented

procedures for the activities that must be carried out under controlled conditions?

How do personnel ensure that these operations are carried out in accordance with specified operating criteria?)


EM.30.5.US. The facility/organization should have procedures and agreements in place to prepare for and respond to emergencies (MP).

(NOTE: This checklist item is drawn from ISO 14001:2004, para 4.4.7, Appendix A, para A.4.7; ISO 14004, para 4.4.7.)

Verify that the facility/operation has identified potential emergencies and developed procedures for preventing them and responding to them.

Verify that the facility does respond to actual emergency situations and accidents and prevent or mitigate associated adverse environmental impacts.

Verify that the facility periodically reviews and, where necessary, revises its emergency preparedness and response procedures, in particular, after the occurrence of accidents or emergency situations.

Verify that the procedure(s) take into account potential consequences of abnormal operating conditions, potential emergency situations and potential accidents.

Verify that the facility also periodically tests such procedures where practicable.

Verify that, if needed, formal agreements have been made with local fire departments and/or HAZMAT response teams for services.

(NOTE: In developing emergency procedure(s), the facility should include consideration of:

the nature of on-site hazards, e.g. flammable liquids, storage tanks and



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compressed gases, and measures to be taken in the event of spillages or accidental releases

the most likely type and scale of an emergency situation or accident the potential for an emergency situation or accident at a nearby facility

[e.g., plant, road, railway line] the most appropriate method(s) for responding to an accident or emergency

situation internal and external communication plans the action(s) required to minimize environmental damage mitigation and response action(s) to be taken for different types of accident

or emergency situation the need for a process(es) for post-accident evaluation to establish and

implement corrective and preventive actions periodic testing of emergency response procedure(s) training of emergency response personnel a list of key personnel and aid agencies, including contact details (e.g. fire

department, spillage clean-up services) evacuation routes and assembly points the potential for an emergency situation(s) or accident(s) at a nearby

facility (e.g. plant, road, railway line), the possibility of mutual assistance from neighboring organizations.)


What procedures have been established to identify potential accidents and emergency situations?

What procedures have been established to identify the responses to accidents and emergency situations?

How are these procedures maintained? How are these procedures periodically reviewed for adequacy? What are the training plans for these procedures? What are the organizational procedures for preventing the environmental

impacts associated with identified potential accidents and emergency situations?

What are the organizational procedures for mitigating the environmental impacts associated with identified potential accidents and emergency situations?

How do you ensure that these procedures cover all environmental impacts? How do you ensure that there is a clear link between potential accidents,

emergency situations, and their environmental impacts? What is your process for reviewing the prevention and mitigation

procedures, especially after process or operational changes? How are the emergency preparedness and response procedures reviewed

and revised for adequacy after an occurrence of an accident or emergency situation?

How are key staff made aware of specific emergency preparedness and response procedures? How are the changes made to these procedures?

How often does the organization test emergency preparedness and response



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procedures? How do you ensure that these procedures are tested wherever practicable? What records are available for emergency response testing?

(NOTE: Asking employees the following questions will assist in verifying conformance to this requirement.

What do you do in case of a procedural nonconformance? What do you do in case of an emergency?)


EM.30.6.US. The facility/organization should integrate continual improvement as a part of its EMS (MP).

(NOTE: This checklist item is drawn from ISO 14001:2004, para 4.6.2, and ISO 14004, para 4.6.2.)

(NOTE: Continual improvement is accomplished through the achievement of environmental objectives and targets and the overall enhancement of the environmental management system or any of its components.)

Verify that, as a part of the continual evaluation of environmental performance and the performance of the EMS, opportunities for improvement are identified.

(NOTE: Opportunities for improvement can be identified by analyzing the root causes(s) of EMS deficiencies.)

(NOTE: Some useful sources of information for continual improvement include: experience gained from corrective and preventive actions external benchmarking against best practices intended or proposed changes applicable to legal requirements and other

requirements to which the organization subscribes results of environmental management system and compliance audits results of monitoring of key characteristics of operations results of progress towards achieving objectives and targets views of interested parties, including employees, customers and suppliers.)

Verify that, when opportunities for improvement are identified, they are evaluated to determine what actions should be taken.

Verify that the actions for improvement are planned, and changes to the EMS are implemented in accordance with those plans.



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(NOTE: Improvements need not take place in all areas simultaneously.)

(NOTE: Examples of improvements include: establishing a process for evaluating new materials to promote the use of

less harmful materials improving an organization's process for identifying applicable legal

requirements so that new compliance requirements are identified in a more timely fashion

improving employee training on materials and handling to reduce an organization's generation of waste

introducing waste water treatment processes to allow water reuse implementing changes in default settings on reproduction equipment to

print two-sided copies at a printing office redesigning delivery routes to reduce fossil fuel consumption by

transportation company(ies) setting objectives and targets to implement fuel substitution in boiler

operations and reduce particulate emissions.)



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EMS

EM.40Monitoring and Measuring

EM.40.1.US. Conformance with EO 13423 EMS requirements is determined by a formal audit, recognition of audit findings, and declaration of conformance (Instructions for Implementing EO 13423, Section II, paragraph C).

Verify that, in order for an EMS to be fully implemented in conformance with EO 13423, the following have occurred:

the EMS has been the subject of a formal audit by a qualified party outside the control or scope of the EMS

audit findings have been recognized by the appropriate level of the agency implementing the EMS

the appropraite senior management accountable for implementation of the EMS has declared conformance to EMS requirements.


EM.40.2.US. Once implemented, an EMS must be reviewed and updated annually or more frequently, as appropriate, by senior leadership accountable for implementation of that EMS (Instructions for Implementing EO 13423, Section II, paragraph A2).

(NOTE: This annual management review does not require a conformance determination.)

Verify that an implemented EMS is reviewed and updated annually or more frequently, as appropriate, by senior leadership accountable for implementation of that EMS.

(NOTE: The following portion of this checklist item is drawn from ISO 14001:2004, para 4.4.4, 4.4.5, 4.5.4, Appendix A, para A.4.4., A.5.4; IS 14004:2004, para 4.4.4, 4.4.5, and 4.5.4)


Verify that the facility establishes and maintains records as necessary to demonstrate conformity to the requirements of its EMS and the results achieved.

(NOTE: Documentation should be collected and maintained in a way that reflects the culture and needs of an organization, building onto and improving its existing information system.)

Verify that EMS documentation includes:

the environmental policy, objectives and targets description of the scope of the environmental management system,



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description of the main elements of the environmental management system and their interaction, and reference to related documents

documents, including records, required by this International Standard documents, including records, determined by the organization to be

necessary to ensure the effective planning, operation and control of processes that relate to its significant

environmental aspects.

(NOTE: The level of detail of the documentation should be sufficient to describe the environmental management system and how its parts work together, and to provide direction on where to obtain more detailed information on the operation of specific parts of the EMS.)

Verify that documents can be located.

Verify that records are and remain legible, identifiable, and traceable.

Verify that documents required by the EMS are controlled.

Verify that documents that are used which were originally created for purposes other than the EMS are referenced in the system.

(NOTE: Examples of documents include: statements of policy, objectives and targets description of the scope of the EMS descriptions of programs and responsibilities information on significant environmental aspects procedures process information organizational charts internal and external standards site emergency plans records.)

Verify that the facility has established, implemented and maintains a procedure(s) for the identification, storage, protection, retrieval, retention and disposal of records.

Verify that the facility has established, implemented, and maintains a procedure to:

approve documents for adequacy prior to issue review and update as necessary and re-approve documents ensure that changes and the current revision status of documents are

identified ensure that relevant versions of applicable documents are available at

points of use ensure that documents remain legible and readily identifiable



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ensure that documents of external origin determined by the organization to be necessary for the planning and operation of the environmental management system are identified and their distribution controlled

prevent the unintended use of obsolete documents and apply suitable identification to them if they are retained for any purpose.

(NOTE: Any decision to document procedures should be based on issues such as:

the consequences, including those to the environment, of not doing so the need to demonstrate compliance with legal and with other requirements

to which the organization subscribes the need to ensure that the activity is undertaken consistently the advantages of doing so, which can include easier implementation

through communication and training, easier maintenance and revision, less risk of ambiguity and deviations, and demonstrability and visibility

the requirements of ISO 14001:2004.)

(NOTE: Some obsolete documents may need to be retained for legal and/or knowledge preservation purposes.)

(NOTE: Environmental records can include, among others: complaint records training records process monitoring records inspection, maintenance and calibration records pertinent contractor and supplier records incident reports records of tests for emergency preparedness audit results management review results external communications decision records of applicable legal requirements records of significant environmental aspects records of environmental meetings environmental performance information legal compliance records details of nonconformities and corrective and preventive actions permits, licenses, or other forms of legal authorization results of operational controls communications with interested parties.)

(NOTE: The primary focus of organizations should be on effective implementation of the EMS and on environmental performance, not on a complex document control system.)

(NOTE: The following questions are examples to assist in verifying conformance to this requirement and may or may not be appropriate at an individual facility.



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How does the organization’s record/information management system make environmental information available to the employees when they need it?

What is your procedure for controlling all documents required by the EMS to ensure they can be located?

How do employees access EMS documentation needed to conduct their job activities?

How are environmental management procedures identified, documented, communicated, and revised?)

What records exist to demonstrate that authorized personnel have approved EMS documents for adequacy?

How has the EMS documentation been integrated into the overall business management documentation?

What procedures exist to ensure that up-to-date documents are available where they are needed?

Who is responsible for implementing these procedures? How are changes to this procedure made when operations or activities

change? What records does your EMS generate? How are these records identified within your EMS procedures?)


EM.40.3.US. The facility/organization should have a procedure to check on the key characteristics of its operations that can have a significant environmental impact (MP).

(NOTE: This checklist item is drawn from ISO 14001:2004, para 4.5.1, Appendix A, para A.5.1; ISO 14004, para 4.5.1.) (NOTE: This involves more than an environmental compliance audit, although environmental compliance auditing is a component of EMS implementation.)

Verify that the facility has established, implemented and maintains a procedure to monitor and measure, on a regular basis, the key characteristics of its operations that can have a significant environmental impact.

(NOTE: Key characteristics are those that the facility needs to consider to determine how it is managing its significant environmental aspects, achieving objectives and targets, and improving environmental performance.)

(NOTE: Monitoring involves collecting information, such as measurements or observations, over time. Measurements can be either quantitative or qualitative.)

Verify that the procedure includes the documenting of information to monitor



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performance, applicable operational controls and conformity with the organization's environmental objectives and targets.

Verify that the facility ensures that calibrated or verified monitoring and measurement equipment is used and maintained and associated records are maintained.

(NOTE: Monitoring and measurements can serve many purposes in an EMS, such as:

tracking progress on meeting policy commitments, achieving objectives and targets, and continual improvement

developing information to identify significant environmental aspects monitoring emissions and discharges to meet applicable legal requirements

or other requirements to which the organization subscribes monitoring consumption of water, energy or raw materials to meet

objectives and targets providing data to support or evaluate operational controls providing data to evaluate the organization's environmental performance providing data to evaluate the performance of the environmental

management system.)


How do you determine the key characteristics of the organization’s operations and activities that can have a significant impact on the environment?

What procedures are used to regularly monitor and measure these key characteristics?

What process do you use to develop these procedures? How do you revise old procedures or add new procedures when changes to

products, processes, or activities occur? How is environmental performance regularly monitored? How are operational controls regularly monitored? How is conformance with the organization’s environmental objectives and

targets regularly monitored?)


EM.40.4.US. The Verify that the facility/organization monitors key activities and tracks their



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facility/organization should monitor key activities and track their performance in relation to the EMS (MP).

performance in relation to the EMS.

(NOTE: For example, if the reduction of liquid solvent use is a target of the EMS, the facility/organization should be able to review statistics on liquid solvent procurement and waste disposal.)


How do you measure progress toward achieving the program’s objectives and targets?

How are the specific actions to attain targets prioritized in order of their importance to the organization?

How is EMS performance reported to top management for review and as a basis for continual improvement?)


EM.40.5.US. The facility/organization should periodically assess compliance with legal requirements as well as other requirements such as policy letter and memorandum (MP).

(NOTE: This checklist item is drawn from ISO 14001:2004, para 4.5.2 and ISO 14004:2004, para 4.5.2.)

Verify that, consistent with its commitment to compliance, the facility establishes implements and maintains a procedure(s) for periodically evaluating compliance with applicable legal requirements.

Verify that the facility keep records of the results of the periodic compliance evaluations.

Verify that the facility has established a frequency and methodology for evaluation of compliance that suits its size, type and complexity.

(NOTE: Frequency can be affected by factors such as past compliance performance or specific legal requirements.)

Verify that the facility evaluates compliance with other requirements (i.e., Army Regulations, Bureau/Agency memorandum, policy letter) to which the facility is required to comply. (NOTE: The facility may wish to combine this evaluation with the above mentioned evaluation of legal compliance or to establish a separate



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procedure(s).)

Verify that the facility keeps records of the results of the periodic evaluations.


What is the organization’s process for ensuring compliance with relevant environmental legislation and regulations?

What procedure does the organization use to identify its legal requirements?

How does the procedure provide for identification and access to all applicable legal requirements?

How does the organization keep track of changes to legal requirements? How are local regulatory requirements identified? What actions are taken on discovered compliance deficiencies?)


EM.40.6.US. The facility/organization should correct and prevent the recurrence of noncompliance and process deficiencies (MP).

(NOTE: This checklist item is drawn from ISO 14001:2004, para 4.5.3 and ISO 14004:2004, para 4.5.3.)

Verify that the facility has established, implemented, and maintains a procedure for dealing with actual and potential nonconformity(ies) and for taking corrective action and preventive action.

(NOTE: Nonconformity is nonfulfillment of a requirement.)

Verify that known noncompliance is corrected to the extent possible within the abilities of the facility/organization.

Verify that the procedure includes requirements for:

identifying and correcting nonconformity(ies) and taking action(s) to mitigate their environmental impacts

investigating nonconformity(ies), determining their cause(s) and taking actions in order to avoid their recurrence

evaluating the need for action(s) to prevent nonconformity(ies) and implementing appropriate actions designed to avoid their occurrence



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recording the results of corrective action(s) and preventive action(s) taken reviewing the effectiveness of corrective action(s) and preventive action(s)

taken.

Verify that actions taken are appropriate to the magnitude of the problems and the environmental impacts encountered.

Verify that the facility ensures that any necessary changes are made to EMS documentation.

Verify that process deficiencies are reviewed and determination is made as to whether the process needs to change or not.

Verify that the facility/organization identifies and responds to the root cause of a deficiency and not only the deficiency itself.

(NOTE: Situations may occur where part of the system may not function as intended or environmental performance requirements are not met. Examples of such situations can include:

system performance: failure to establish environmental objectives and targets failure to define responsibilities required by an environmental

management system, such as responsibilities for achieving objectives and targets or for emergency preparedness and response

failure to periodically evaluate compliance with legal requirements environmental performance:

energy reduction targets are not achieved maintenance requirements are not performed as scheduled operating criteria [e.g. permitted limits] are not met.)




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EMS

EM.50Management Review

EM.50.1.US. In order for an EMS to be considered fully implemented, the EMS must have been the subject of a formal audit, the audit findings recognized by the appropriate level of the agency implementing the EMS, and the appropriate senior manager accountable for implementation has declared conformance (Instructions for Implementing EO 13423, Section II, paragraphs C and D).


Verify that the EMS has been the subject of a formal audit by a qualified party outside the control or scope of the EMS.

Verify that audit findings have been recognized by the appropriate level of the agency implementing the EMS.

Verify that the appropriate senior manager accountable for implementation of the EMS has declared conformance to EMS requirements.

Verify that, once conformance has been declared, the EMS is audited by a qualified party outside of the control or scope of the EMS at least every 3 yr from the date of the initial declaration.

(NOTE: Conformance declaration shall be renewed as appropriate based on agency guidance.)

(NOTE: EPA, in consultation with OFEE and DOE, will develop guidance on incorporating the new E.O. goals, including the multi-year energy and transportation goals, into EMSs. In addition, EPA, through the Interagency Environmental Leadership Workgroup, will develop additional EMS guidance from time to time, as needed.) (NOTE: The following portion of this checklist item is drawn from ISO 14001:2004, para 4.5.5, Appendix A, para A.5.5; ISO 14004:2004, para 4.5.5.)

Verify that the facility/organization has an EMS audit to ensure the EMS is functioning as intended.

Verify that internal audits of the EMS are conducted at planned intervals to determine whether the EMS:

conforms to planned arrangements for environmental management including the requirements of ISO 14001

has been properly implemented and is maintained,

(NOTE: Internal audits may also be performed to identify opportunities for improvement.)



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Verify that internal audits of the EMS are conducted at planned intervals to provide information on the results of audits to management.

(NOTE: Internal audits of an EMS can be performed by personnel from within the facility/organization or by external persons selected by the facility/organization, working on its behalf. In either case, the persons conducting the audit should be competent and in a position to do so impartially and objectively. In smaller facilities/organizations, auditor independence can be demonstrated by an auditor being free from responsibility for the activity being audited.)

Verify that audit programs are planned, established, implemented and maintained by the organization, taking into consideration the environmental importance of the operations concerned and the results of previous audits.

(NOTE: Each internal audit need not cover the entire system as long s the audit program ensures that all organizational units and functions, system elements and the full scope of the EMS are audited periodically.)

Verify that audit procedures are established, implemented, and maintained that address:

the responsibilities and requirements for planning and conducting audits, reporting results and retaining associated records

the determination of audit criteria, scope, frequency and methods.

Verify that the selection of auditors and conduct of audits ensures objectivity and the impartiality of the audit process.

Verify that management periodically reviews the EMS and looks specifically at:

environmental performance the ability to support mission and priorities.

(NOTE: The results of the internal EMS audit can be provided in the form of a report and used to correct or prevent specific nonconformities, fulfill one or more objectives of the audit programmer, and provide input to the conduct of the management review.)


What are the means to ensure the organization’s commitment to continual improvement?)

How has the policy been revised as a result of management review activities?)

How are audits scheduled to ensure adherence to all aspects of the EMS?



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How do audits determine whether or not the EMS conforms to planned arrangements for environmental management, including EMS requirements?

What procedures have been established to provide information on the results of audits to top management?

How do the audit procedures require that the audit cover the full scope of the system being audited?)


EM.50.2.US. Top management of the facility/organization should be involved in the EMS implementation beyond the declaration of a policy (MP).

(NOTE: This checklist item is drawn from ISO 14001:2004, para 4.6 and ISO 14004:2004, para 4.6.)

Verify that management participation in EMS goes beyond declaration of a policy.

(NOTE: Examples include: management participation in environmental committees inclusion of targets specific to management in the EMS allocation of funds for EMS-related issues attendance at management focused EMS training.)

Verify that top management reviews the facility’s EMS at planned intervals to ensure its continuing suitability, adequacy and effectiveness.

(NOTE: Each facility can decide for itself those who will participate in the management review.)

Verify that reviews include assessing opportunities for improvement and the need for changes to the EMS, including the environmental policy and environmental objectives and targets.

Verify that records of the management reviews are retained.

(NOTE: Input to management reviews shall include: results of internal audits and evaluations of compliance with legal

requirements and with other requirements to which the organization subscribes

communication(s) from external interested parties, including complaints



U.S. TEAM Guide



the environmental performance of the organization the extent to which objectives and targets have been met status of corrective and preventive actions follow-up actions from previous management reviews changing circumstances, including developments in legal and other

requirements related to its environmental aspects recommendations for improvement.)

(NOTE: The outputs from management reviews shall include any decisions and actions related to possible changes to environmental policy, objectives, targets and other elements of the EMS, consistent with the commitment to continual improvement.)

(NOTE: Records of management review can include copies of meeting agenda items, lists of attendees, presentation materials or handouts, and management decisions recorded in a memo to file, reports, minutes, or tracking system.)


How has top management reinforced organizational commitment to the environmental policy?)

How has top management communicated organizational commitment to the environmental policy?

What is the process for receiving and responding to employee concerns?)



Appendix 14-1

EMS Metrics

I. ENVIRONMENTAL MANAGEMENT SYSTEM SCORECARD METRICS

Instructions for Questions 1-7: For each topic listed, please indicate the one statement which best describes the status of your appropriate facility EMS during this reporting period. Responses should not reflect activities that will occur during the next reporting period. To ensure that summary data adequately reflects information from your agency please respond to each question. Where a facility does not respond to a question in this section, it will be scored as selecting response “A.”

1. ENVIRONMENTAL ASPECTS. A. Significant environmental aspects were not identified during this reporting period or previously.B. Significant environmental aspects were identified during this reporting period or previously; an

established procedure was not used for this process.C. An established procedure was used to identify significant environmental aspects during this reporting

period or previously; however, previously identified significant environmental aspects were not reevaluated during this period.

D. Environmental aspects identified in a previous year were reevaluated during this reporting period using an established procedure and updated (added/deleted/modified) as appropriate.

2. GOALS, OBJECTIVES, AND TARGETS. A. Measurable environmental goals, objectives, and targets were not identified, reviewed, and updated as

appropriate during this reporting period.B. Measurable environmental goals, objectives, and targets were identified, reviewed, and updated as

appropriate; 0-49% of targets were on schedule during this reporting period.C. Measurable environmental goals, objectives, and targets were identified, reviewed, and updated as

appropriate; 50-79% of targets were on schedule during this reporting period.D. Measurable environmental goals, objectives, and targets were identified, reviewed, and updated as

appropriate; 80-100% of targets were on schedule during this reporting period.

3. OPERATIONAL CONTROLS. A. Documented operational controls to address significant aspects consistent with goals, objectives, and

targets were not established during this reporting period or previously.B. Documented operational controls to address significant aspects consistent with goals, objectives, and

targets were established during this reporting period or previously and have been partially implementedC. Documented operational controls to address significant aspects consistent with goals, objectives, and

targets were established during this reporting period or previously and are fully implemented.D. During this reporting period, previously documented operational controls to address significant aspects

consistent with goals, objectives, and targets were fully implemented; in addition, they were reviewed during the year, and/or updated (i.e. supplemented, revised, deleted) as appropriate.

4. ENVIRONMENTAL TRAINING. [Note: These metrics pertain to competence training for those whose tasks have the potential to cause significant environmental impacts]

A. Training requirements to ensure individual competence and responsibility were not been identified during this reporting period or previously.

B. Training requirements to ensure individual competence and responsibility were identified during this reporting period or previously but training was not available and/or carried out.

C. Training requirements to ensure individual competence and responsibility were identified during this reporting period or previously and training was available and carried out, and recorded during this reporting period.


D. Training procedures were established to ensure that training requirements for individual competence and responsibility were identified; training was available and carried out during this reporting period; training is recorded and tracked; and training requirements are monitored, revised, and refresher training provided, as appropriate, to maintain competence.

5. CONTRACTS. [Note: An appropriate contract is one whose actions may have potential impact on the environmental aspects identified by the applicable EMS. Appropriate contracts may include legal arrangements with concessionaires.]

A. Facility has not carried out a process to identify appropriate contracts in which to include EMS requirements.

B. Facility has carried out a process to identify appropriate contracts, but has not modified appropriate contracts to include EMS requirements.

C. All new and renewed appropriate contracts were in the process of including EMS requirements during this reporting period; contractors were required to fulfill defined roles and specified responsibilities.

D. EMS requirements were included in all appropriate contracts and contractors fulfilled defined roles and specified responsibilities during this reporting period.

6. EMS AUDIT/EVALUATION PROCEDURES. A. EMS audit/evaluation procedures were not established during this reporting period or previously.B. EMS audit/evaluation procedures were established during this reporting period or previously but no audit

was conducted during this reporting period.C. EMS audit/evaluation procedures were established during this reporting period or previously; an audit

was conducted during this reporting period; nonconformities are not yet being addressed or corrected.D. EMS audit/evaluation procedures were established during this reporting period or previously and an audit

was conducted during this reporting period; nonconformities are being were addressed or corrected.

DATE LATEST FACILITY-WIDE INTERNAL EMS AUDIT/EVALUATION WAS COMPLETED: ________________

7. MANAGEMENT REVIEW. A. Senior leadership review of the EMS was neither planned/scheduled nor conducted during this reporting

period.B. Senior leadership review of the EMS was planned/scheduled, but was not conducted during this reporting

periodC. Senior leadership review of the EMS was conducted during the current reporting period:

recommendations for continual improvement were not addressed by top management during this reporting period.

D. Senior leadership review of the EMS was conducted during this reporting period and top management responded to recommendations for continual improvement.


II. QUESTIONS ON ENVIRONMENTAL MANAGEMENT SYSTEM EFFECTIVENESS (SINCE IMPLEMENTATION OF THE EMS)

1. BENEFIT OF EMS ON THE FACILITY:

Please estimate the effect of EMS since implementation on your facility or organization (where the EMS is implemented) with respect to:

N/A1 Reduced risk to facility mission 1 2 3 4 5

2 Improved fiscal efficiency or cost avoidance 1 2 3 4 5

3 Greater understanding of environmental issues at all levels of the organization. 1 2 3 4 5

4 Greater empowerment of individuals to contribute to improving the organization’s environmental footprint 1 2 3 4 5

5 Greater integration of environment into organizational culture or operations 1 2 3 4 5

6 Greater integration of environment into real property asset management 1 2 3 4 5

7 Improved community relations 1 2 3 4 5

8 Improved effectiveness in overall mission 1 2 3 4 5

9 Improved cooperative conservation with other groups 1 2 3 4 5

10 Other (specify) ___________________________________ 1 2 3 4 5

2. BENEFIT OF EMS ON ENVIRONMENT AND ENVIRONMENTAL ISSUES:

Please estimate the effect of EMS (since implementation) on your facility’s or organization’s environmental issues to include:

N/A1 Improved overall compliance management 1 2 3 4 5

2 Improved overall personnel health and safety 1 2 3 4 5

3 Improved overall pollution prevention 1 2 3 4 5

4 Improved water quality 1 2 3 4 5

5 Improved air quality 1 2 3 4 5

6 Improved hazardous material management 1 2 3 4 5

7 Improved hazardous waste management 1 2 3 4 5

8 Improved solid waste management 1 2 3 4 5

9 Improved conservation of natural resources 1 2 3 4 5

10 Improved conservation of energy in facilities 1 2 3 4 5

11 Improved conservation of fuel in vehicles 1 2 3 4 5

12 Improved conservation of water 1 2 3 4 5

13 Reduced number of permits needed to operate 1 2 3 4 5

14 Other (specify) ___________________________________ 1 2 3 4 5


For each item in Part 1 & 2, mark the number that best represents your answer: Please provide a response for each question. NA should be used if the EMS is not mature enough to respond or if other circumstances preclude an informed response

1 = Not at all 2 = A little bit 3 = Somewhat 4 = Quite a bit 5 = A great deal NA = Does not apply

For example, if you saw a great reduction in risk to your mission, mark “5.” If you saw no reduced risk, mark

III. QUESTIONS ON ENVIRONMENTAL MANAGEMENT SYSTEM EXPERIENCES

1. EMS BENEFITS/SUCCESSES: Please provide up to 3 bullet statements identifying benefits/successes associated with EMS implementation at your facility.

2. EMS BEST PRACTICES/LESSONS LEARNED: Please provide up to 3 bullet statements identifying EMS implementation best practices/lessons learned.

3. EMS CHALLENGES: Please provide up to 3 bullet statements identifying EMS implementation challenges.

4. EMS BENEFITS TO AGENCY MISSION: Please provide up to 3 bullet statements identifying how EMS implementation has enabled your organization or agency to operate more effectively in accomplishing its missions (e.g., reduced number of off-normal events that disrupt agency schedules or operations; greater interoperability among sites; better relations with host communities, states, and their elected representatives; greater speed and agility in responding to unexpected events; improved ability to write performance based contracts; etc.).


Appendix 14-2

Identification of Aspects and Impacts

(ISO 14001:2004, Appendix A, para A.3.1; ISO 14004:2004, para 4.3.1.2 through 4.3.1.5, and Annex A, Table A.1)

Almost all activities, products and services have some impact on the environment, which may occur at any or all stages of the activities, products or services life cycle, i.e. from raw material acquisition and distribution, to use and disposal. Such impacts may be local, regional or global, short or long term, with varying levels of significance.

Environmental Aspects

A facility/organization should identify the environmental aspects within the scope of its EMS, taking into account the inputs and outputs (both intended and unintended) associated with its current and relevant-past activities, products and services, planned or new developments, or new or modified activities, products and services. This process should consider normal and abnormal operating conditions, shut-down and start-up conditions, as well as reasonably foreseeable emergency situations.

Facilities/organizations do not have to consider each product, component or raw material input individually. Grouping or categorizing activities, products and services can assist a facility/organization in identifying common or similar environmental aspects. A grouping or category could be based on common characteristics, such as organizational units, geographical locations, operations workflow, materials or energy use in product groups, or environmental media affected (e.g. air, water, and land). To be useful, the size of a category should be large enough for meaningful examination, yet small enough to be clearly understood. NOTE See ISO 14031 for examples of categories of activities, products and services.

Although there is no single approach for identifying environmental aspects, the approach selected could, for example, consider:

a) emissions to air,b) releases to water,c) releases to land,d) use of raw materials and natural resources,e) use of energy,f) energy emitted, e.g. heat, radiation, vibration,g) waste and by-products, andh) physical attributes, e.g. size, shape, color, appearance.

In addition to those environmental aspects a facility/organization can control directly, a facility/organization should also consider aspects that it can influence, e.g. those related to goods and services used by the organization and those related to products and services that it provides. Some guidance to evaluate control and influence is provided below. However, in all circumstances it is the facility/organization that determines the degree of control and also the aspects it can influence.

To identify and have an understanding of its environmental aspects, a facility/organization should collect quantitative and/or qualitative data on the characteristics of its activities, products and services such as inputs and outputs of materials or energy, processes and technology used, facilities and locations, transportation methods and human factors (e.g. impaired vision or hearing). In addition it can be useful to collect information on

a) cause and effect relationships between elements of its activities, products, and services and possible or actual changes to the environment,

b) environmental concerns of interested parties, andc) possible environmental aspects identified in government regulations and permits, in other standards, or

by industry associations, academic institutions, etc.


Consideration should be given to aspects related to the facility’s/organization's activities, products and services, such as

design and development, manufacturing processes, packaging and transportation, environmental performance and practices of contractors and suppliers, waste management, extraction and distribution of raw materials and natural resources, distribution, use and end-of-life of products, and wildlife and biodiversity.

The control and influence over the environmental aspects of a product supplied to an organization can vary significantly, depending on the organization's market situation and its suppliers. An organization that is responsible for its own product design can influence such aspects significantly by changing, for example, a single input material, while an organization that needs to supply in accordance with externally determined product specifications may have little choice.

With respect to products provided, it is recognized that organizations may have limited control over the use and disposal of their products, e.g. by users, but they can consider, where practicable, communication of proper handling and disposal mechanisms to these users in order to exert influence.

The process of identification and evaluation of environmental aspects should take into account the location of activities, cost and time to undertake the analysis, and the availability of reliable data. The identification of environmental aspects does not require a detailed life-cycle assessment. Information already developed for regulatory or other purposes may be used in this process.

This process of identifying and evaluating environmental aspects is not intended to change or increase an organization's legal obligations.

Possible information sources for determining environmental aspects and impacts include:

a) general information documents, such as brochures, catalogues and annual reports,b) operations manuals, process flowcharts, or quality and product plans,c) reports from previous audits, assessments or reviews, such as initial environmental reviews or life cycle

assessments,d) information from other management systems, such as quality or occupational health and safety,e) technical data reports, published analyses or studies, or lists of toxic substances,f) applicable legal requirements and other requirements to which the organization subscribes,g) codes of practice, national and international policies, guidelines and programs,h) purchasing data,i) product specifications, product development data, Material/Chemical Safety Data Sheets (M/CSDS), or

energy and material balance data,j) waste inventories,k) monitoring data,l) environmental permit or license applications,m) views of, requests from, or agreements with interested parties, andn) reports on emergency situations and accidents.

Significant Environmental Aspects

Significance is a relative concept; it cannot be defined in absolute terms. What is significant for one facility/organization may not be significant for another. Evaluating significance involves applying both technical analysis and judgment by the facility/organization. The use of criteria should help a facility/organization to establish which environmental aspects and associated impacts it considers significant. Establishing and applying such criteria should provide consistency and reproducibility in the assessment of significance.


When establishing criteria for significance, an organization should consider the following:a) environmental criteria (such as scale, severity and duration of the impact, or type, size and frequency of

an environmental aspect);b) applicable legal requirements (such as emission and discharge limits in permits or regulations, etc.);c) the concerns of internal and external interested parties (such as those related to organizational values,

public image, noise, odor or visual degradation).

Significance criteria can be applied either to an organization's environmental aspects or to their associated impacts.

When developing information relating to its significant environmental aspects, the organization should consider the need to retain the information for historical purposes as well as how to use it in designing and implementing its EMS.

NOTE: The determination of significant environmental aspects does not require an environmental impact assessment.

Environmental Impacts

Changes to the environment, either adverse or beneficial, that result wholly or partially from environmental aspects are called environmental impacts. The relationship between environmental aspects and impacts is one of cause and effect. In some locations cultural heritage can be an important element of the surroundings in which an organization operates, and therefore should be taken into account in the understanding of its environmental impacts.

Readily available information on the types of environmental impacts associated with an organization's environmental aspects may be adequate for some facilities/organizations. Other facilities/organizations can choose to use cause-and-effect diagrams or flowcharts illustrating inputs, outputs or mass/energy balances or other approaches such as environmental impact assessments or life cycle assessments.

Regardless of the approach chosen, the approach should be capable of recognizinga) positive (beneficial) as well as negative (adverse) environmental impacts,b) actual and potential environmental impacts,c) the part(s) of the environment that might be affected, such as air, water, soil, flora, fauna, cultural

heritage, etc.,d) the characteristics of the location that might affect the impact such as local weather conditions, height of

water table, soil types, etc., ande) the nature of the changes to the environment (such as global vs. local issues, length of time for which the

impact occurs, potential for impact to accumulate in strength over time).

Examples of activities, products and services and their associated environmental aspects and impacts

Activity/Product/Service Aspects Actual and potential impacts

Activity: Road ConstructionMechanical compaction Emission of particulate matter to air

(dust)Pollution of air

Construction during heavy rain a Discharge of soil and gravel to land and water

Additional depletion of non-renewable natural resources (replacement of gravel-small stones)Degradation of localized landErosion of soilPollution of waterDegradation of wetland habitat

Activity: Boiler design (consideration of operational aspects)



Fuel efficiency Consumption of fuel Conservation of non-renewable energy sources (fossil fuels)

Low emissions Discharges to air Achievement of air quality objectives

Non hazardous materials Disposal at end of life Avoidance of hazardous wasteActivity: Fossil-fuel-based boiler operationsOperation of boiler Consumption of heating oil Depletion of non-renewable natural

resourcesEmission of sulfur dioxide (SO2), nitrous oxide (N2O) and carbon dioxide (CO2) (i.e. greenhouse gases)

Pollution of airRespiratory impacts on local residentsAcid rain impacts on surface waterGlobal warming and climate change

Discharge of heated water Changes to water quality (e.g. temperature)

Storage of boiler fuel in underground tanks

Discharge of oil to landa Pollution of soilPollution of groundwater

Delivery and transfer of heating oil Uncontrolled release of heating oil to surface water drainb

Pollution of surface waterBioaccumulation of toxic substances in fauna

Activity: Agriculture — Grain cultivationIn field operations during growth stage/phase

Consumption of water Depletion of groundwater supplyUse of pesticides Pollution of soil

Bioaccumulation of toxic substances in fauna resulting in chronic adverse health effects or species loss

Emission of methane (i.e. greenhouse gas)

Global warming and climate change

Activity: Wastewater managementAgro food industry wastewater treatment

Generation of sludge (which is applied in agriculture)

Soil correction through the addition of nutrientsd

Product: Printer toner cartridgeRefillable toner cartridge Use of raw materials Conservation of resourcesEnd of life — disposal Generation of solid wastec Land use

Recovery and reuse of components Conservation of natural resourcesProduct: Air conditionerConsumer operation of unit Use of electricityc Depletion of non-renewable natural

resourcesEnd of life – disposal Generation of solid wastec Land use

Recovery and reuse of components Conservation of natural resourcesService: Maintenance and repair service

Chemical handling and use Uncontrolled release during emergency b

Pollution of airPollution of soilInjury to humans

Subcontracted air conditioner repair Release of ozone-depleting substances (i.e. refrigerant)a

Ozone depletion

Service: Transportation and distribution of goods and productsFleet operation Consumption of fuel Depletion of non-renewable fossil

fuelsEmission of oxides of nitrogen Pollution of air – ozone production



(NOx) – smogGlobal warming and climate change

Generation of noise Discomfort or inconvenience to local residents

Routine fleet maintenance (including oil changes)

Emission of oxides of nitrogen (NOx)

Achievement of air quality objectives

Generation of waste oil Pollution of soila Abnormal conditions.b Emergency conditions.c Organization may be able to “influence” aspect.d Beneficial impact.


Appendix 14-3

Examples of Activities, Products and Services and Their Associated Environmental Aspects, Objectives, Targets, Programs, Indicators, Operational Control, and Monitoring and Measurement.

(ISO 14004:2004, Annex A, Table A.2)

Aspects Objectives Targets Programs Indicators Operational Control Monitoring and Measurement

Activity: Operation of fossil fuel-based boiler

Consumption of heating oil

Reduce the consumption of nonrenewable resources

Reduction of the consumption of heating oil (based on current year consumption) by 20% within 1 year

Installation of more efficient fuel burners

• Project plan milestones

• Consumption of heating oil per working hour of the boiler

• Procedures for installation of modified burners

• Procedures for documenting and recording oil consumption

• Quarterly evaluation of progress on project plan

• Monthly tracking of oil consumption rates

Discharge of heated water

Minimize the negative impacts to watershed quality from elevated effluent temperature

Reduce mean daily temperature of discharge water by 1 °C by 2008

Facility and design engineers re-engineer operations to extract and re-use heat from wastewater (i.e. co-generation)

• Daily mean temperature of water discharge

• Watershed water quality parameters

• Number and diversity of marine organisms

• Water quality sampling and analysis procedures

• Sampling plan of marine organisms

• Co-generation operational procedures

• Engineering controls

• Continuous monitoring of temperature of discharge water

• Quarterly monitoring of watershed water quality

Product: Air conditioner (consumer operation of unit and end of life — Disposal)

Use of electricity Encourage the consumer to use less energy

Reduce the operating temperature by 5% based on last year's operating temperature by end

Educate consumer on impacts of excessive energy use through distribution of energy-efficient

• Increased customer interest in energy use

• Increased customer interest in

• Design of effective product material

• Use of electrical energy

Survey of users



of current year materials with product (e.g. cost savings, reduced environmental impacts)

new energy efficient products • Consideration of

customer energy efficiency requests in new product design

Generation of solid waste

Reduce consumer solid waste generation from disposal of packaging by reducing quantity of packaging materials used

Achieve 35% reduction in packaging material for current product line by 2008

• Redesign product packaging (Engineering Dept., 6 months)

• Implement production changes (6 months)

• Test run and full production

• Quantity of packaging material per unit

• % reduction in packaging material used for product line

• Estimated reduction in consumer solid waste generation volume/unit

• Design control procedures

• Product packaging procedures

• Quarterly monitoring of quantity of packaging material used (purchased minus scrap)

• Product units shipped in product line

Service: Transportation and distribution of goods and products (fleet maintenance)

Emission of oxides of nitrogen (NOx)

Increase positive impact on air quality by improving effectiveness of fleet maintenance

Achieve 25% reduction of NOx emissions by 2008

Identify key maintenance parameters for reduction

• Revise maintenance program to incorporate key reduction tasks

• Optimize fleet maintenance schedule through

• % on-time maintenance

• NOx emissions/km

• Maintenance procedures

• Training of maintenance technicians

• Computerized notification of scheduled maintenance

• Tracking of maintenance frequency versus schedule

• Monitoring of vehicle fuel efficiency

• Quarterly testing of vehicle emissions

• Annual assessment of



computer program reductions achieved

Generation of waste oil

Manage oily wastes in conformity with requirements

Achieve 100% conformity with oily waste disposal requirements at service centers within one year

Develop and implement waste management training program at service centers

• % of service centre employees trained• Number of waste disposal nonconformities

• % of oily waste disposed per requirements

• Waste management procedures

• Training program for service centre employees

• Monitoring of service-centre employee training conducted

• Tracking of oily waste disposal quantities and disposal methods

• Quarterly assessments of oily waste management practices


Appendix 14-4

Examples of Environmental Training That Can Be Provided by a Facility (ISO 14004:2004, para 4.4.2)

Type of Training Audience PurposeRaising awareness of the importance of environmental management

Senior managers To gain commitment and alignment to the organization's environmental policy

Raising general environmental awareness

All employees To gain commitment to the environmental policy, objectives and targets of the organization and instill a sense of individual responsibility

Training in EMS requirements Persons with responsibilities in the EMS

To instruct on how to meet requirements, conduct procedures, etc.

Skills enhancement Employees with environmental responsibilities

To improve performance in areas of the organization, e.g. operations, research and development, and engineering

Compliance training Employees whose actions can affect compliance

To achieve compliance with regulatory training requirements and improve compliance with applicable legal requirements and other requirements to which the organization subscribes.


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