A well-thought-out and implemented environmental management system can provide many benefits to an organization.
Figure 1. The ongoing cycle of an effective environmental
management system offers economic, environmental and community relations
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
- 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
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
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.
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