Figure 1. The ongoing cycle of an effective environmental management system offers economic, environmental and community relations benefits.

An environmental management system (EMS) is a set of systematic processes and practices that allows an organization to manage its interactions with the environment. At the core of an EMS is an ongoing cycle of planning, implementing, reviewing, and improving the processes and actions an organization takes to meet its business and environmental goals (see Figure 1). A well-thought-out and implemented EMS can provide many benefits to an organization, including:

• Increasing the likelihood of maintaining compliance with regulatory requirements
• Reducing environmental risks and liabilities
• Reducing scrutiny by regulators
• Improving corporate image
• Meeting customer demands
• Achieving competitive advantages (resulting from reduced energy usage and raw material consumption, increased pollution prevention, decreased production losses, etc.)

The benefits of implementing an EMS are many; however, the implementation of an EMS is often very challenging, as those who have participated in this process can attest. Particularly challenging is the task of implementing an enterprise-wide EMS, especially if the organization is large, multinational and includes diverse operations. In addition, while there are many resources available to assist individual sites with EMS implementation (e.g., the U.S. Environmental Protection Agency's EMS website at www.epa.gov/-ems), it is typically more difficult to find such resources for implementation of an enterprise-wide EMS.

This article discusses some considerations that should be made when implementing a large-scale, enterprise-wide EMS. Rather than providing an all-encompassing guide, it focuses on those considerations that are particularly important for enterprise-wide EMS implementation and not those that may also be important for individual site implementation. It should also be noted that the actual process of implementation differs greatly from organization to organization depending on culture, ownership, priorities, size and diversity.

Understanding and Communicating Goals

The desire to implement an enterprise-wide EMS may originate with the shareholders or other stakeholders of the organization. A particular incident or series of incidents, such as regulatory compliance issues, might have alerted the organization to a systemic lack of management in the environmental area and the need for an EMS. Customer requirements may also be driving the need to implement the EMS. Some organizations may strive to obtain a recognized certification (such as ISO 14001) for their EMS once implemented, while others may be satisfied without obtaining such a certification.

Regardless of the incentive, in order for an enterprise-wide EMS implementation to be successful, all participants in the process (which will likely include all of the organization's employees) must understand to some extent the driver and goals of the EMS, as well as what a successful implementation means to the organization. Site-level management should fully understand the goals of the EMS and support those goals when communicating to their site staff. Furthermore, those responsible for developing the structure of the EMS must ensure that the approach being used will result in an EMS that meets the established goals.

Communication of the organization's intent to implement an EMS, the goals of the EMS and the anticipated impact on site-level personnel are all important to the success of the project. Due to the size and scope of an enterprise-wide implementation and the number of people involved and affected, communication of the goals is even more important than when implementing an EMS at only one site. How this communication will be accomplished will differ among organizations, but a robust strategy for such communication should be developed early in the project timeline.

Moreover, communication regarding the progress should continue throughout the implementation phase. As most people and groups need to hear or read about something more than once to really understand it and integrate it into their thinking, communication of the same message may need to be made multiple times and through the use of multiple vehicles.

Dealing with a "Patchwork" of Existing Systems

A large organization, particularly if it is made up of numerous diverse operations, will likely already have many processes in place that cover at least some of the elements of a robust EMS (e.g., incident reporting forms and procedures, emergency response plans, regulatory compliance audits, etc.). These processes will typically only be implemented at some sites or in some business units of the organization. Some processes may be effective, while others may not. Across the organization, more than one process might be used to achieve the same objective, and it may be difficult to get employees to abandon current systems for one that is more robust or simply more consistent with what others across the company are doing.

One of the challenges of an effective, enterprise-wide EMS implementation is to determine if this patchwork of existing systems is acceptable. In some cases it may be acceptable, although enterprise-wide mandates may be needed to ensure that certain minimum standards are met. These minimum standards should allow for flexibility in processes as long as the desired end is achieved. This "corporate minimum standard" approach allows sites and business units to retain current processes while adapting them to meet the minimum standards.

In other cases, however, it may be more appropriate for the organization to mandate very specific processes and workflows that must be followed and that will replace local processes and workflows. This type of approach works well for organizations with very similar operations across the entire company. It can also be desirable when consistency across the organization is valued more highly than the advantages associated with allowing existing processes to remain.

One of the advantages of mandating specific processes and workflows to be used enterprise-wide is that this approach produces greater consistency across an organization. Consistency can result in more efficient audits (since everything is organized in the same way and on the same forms no matter what site is being audited), better environmental metrics (ensuring that environmental performance of sites and business units are compared "apples to apples"), easier transfers of personnel from site to site, etc.

Mandating specific processes and workflows to be used enterprise-wide also allows for greater corporate control over these processes, which may or may not be desired. Disadvantages of this approach are that sites may not feel as if they truly own the EMS and may resent having to replace their existing processes (which they may think are working fine).

Potential Use of a Pilot Site

It is often advantageous to begin with a pilot site when conducting an enterprise-wide EMS implementation. Using this approach, the EMS is first implemented at one pilot site (or a small number of pilot sites, in some cases) in accordance with the guidance or principles the organization has established for its enterprise-wide EMS (e.g., corporate minimum standards or corporate procedures). The experience of implementing the EMS at the pilot site leads to the creation of a toolbox containing guidance documents, templates, examples, etc. This toolbox is distributed to the rest of the organization in order to increase consistency and communicate lessons learned.

Use of a pilot site also allows the organization to "try out" the corporate minimum standards, corporate procedures or other enterprise-wide guidance related to the EMS. If standards, procedures or guidance are found to be unworkable, they can be modified prior to implementation across the entire organization.

Integration with Existing, Non-Environmental Systems

The elements of a robust EMS are similar to those associated with good management systems in other areas, such as safety and health, quality, and financial. A successful enterprise-wide EMS implementation should include an assessment of existing, non-environmental systems and a determination of which of these can be leveraged to include environmental concerns.

Integration with existing, non-environmental systems can be particularly important when developing processes and workflows for activities that span multiple sites or multiple departments. For example, change management is an essential component of a robust EMS. Effective change management often requires communication and workflows across a variety of levels, departments and sites. Therefore, developing a new process for environmental change management can be a daunting task. However, if an existing process is already in place for change management as it relates to quality issues, it may be relatively easy to take this existing process, determine what additional reviews and gates are necessary to address environmental concerns, and make the appropriate changes.

Integrating the EMS with existing, non-environmental systems can also be important for employee acceptance of the EMS. Employees are more likely to accept changes to a familiar process and workflow than they are to accept an entirely new process and workflow.

Implementing Electronic Data Management Systems

During the planning of an enterprise-wide EMS, the team often discovers a lack of the electronic data management systems (such as document control, incident reporting, routing of change management reviews, action tracking, etc.) that are needed to effectively manage tasks associated with an EMS. An enterprise-wide EMS implementation provides the opportunity to put a data management system in place that can be used across the entire organization to provide consistency and allow for reporting at many levels of the organization.

Dealing with Multiple Languages

If the organization is multinational, it is likely that EMS documentation, guidance, training and communication will need to be translated into other languages. This fact should be considered during the development of all documents. Simple language should be used whenever possible, and both U.S. and non-U.S. examples should be included (e.g., care should be taken to not only refer to U.S. environmental regulations when discussing legal requirements that might apply to a site).

Multiple language needs can be a particular concern if the organization decides to utilize a software tool to electronically manage data as part of the EMS. If the end users of the software require non-English versions, additional costs may apply in order to develop and implement the electronic data system.

Substantial Benefits

The implementation of a large-scale, enterprise-wide EMS brings many challenges in addition to those faced during EMS implementation at an individual site. However, with proper planning, decision making, and communication, the benefits can be substantial. In fact, results of a successful, enterprise-wide EMS implementation often include robust methodologies for managing environmental compliance, risk and liabilities, as well as a greater level of consistency across the organization with respect to environmental management.

Reprinted with permission from Trinity Consultants, Inc. For additional information regarding environmental management systems, contact Trinity at 12770 Merit Dr., Suite 900, Dallas, TX; (800) 229-6655; fax (972) 385-9203; or visit www.trinityconsultants.com.