Where to Start: Addressing Operational Issues
This is where the EMS Manager, working with the CO and senior line managers (e.g., heads of directorates, production unit managers etc.) lays out the strategy for how the EMS will be put in place over a relatively lengthy period of time (often even beyond the tenure of the CO and line managers).
There isn't a one-size-fits-all, correct approach to establishing a successful EMS. Each organization must design and implement an environmental management system that addresses the installation's mission, size, multiple organizations and environmental objectives. Before tackling the tactical and operational level issues, the first step is to address some key strategic issues:
Often staff responsible for implementing the EMS are distracted by tactical issues before resolving these strategic issues. For example, staff perform a "gap analysis" prior to making these strategic decisions. There are two problems with this. First, in an attempt to address all operations within the CO's purview, the status assessment may focus too broadly and at too high a level. Second, and probably more importantly, staff focus on the "gaps" too early in the effort. In the beginning, the EMS effort should focus on an inventory of what currently is being done. Identifying a gap implies that someone knows what is being done (or not being done) and that someone already knows what should be done--the difference being, therefore, the "gap!" Unfortunately this is often too soon to identify what must be done, other than very high level checklist activities that don't require a "gap analysis" to understand (selecting an EMS Manager, developing an EMS Policy, having compliance programs to meet legal requirements). The devil is in the details and to do a gap analysis at that detailed level, and to do it efficiently, requires that the strategic issues be addressed first.
2-1 Whether to address the entire installation from the start
As stated above, each organization must design and implement an environmental management system that addresses the installation's mission, size, multiple organizations and environmental objectives. One of the first decisions is where the EMS will apply. The area or operation participating in the EMS is defined by the "fenceline." Once the fenceline is established, the EMS applies only to those activities, products or services that the organization or organizations within it can control or influence. You can draw the fenceline as small or as large as necessary -- from a single activity, to an entire installation; however, the most effective approach is to start small, achieve success and then expand.
Consider selecting a single organization for your initial EMS implementation effort. The criteria for selecting that organization will be installation specific. You may choose the organization with the most compliance issues or the organization with the most formal environmental program or the one with proactive management. Once this organization's EMS is in place and fully functional, you can begin to roll out the program to other line operations. When all of your operations are participating, you can consider bringing your tenants into the program, followed by contractors and suppliers. Eventually, your fenceline will encompass the entire installation and every operation and organization on-site.
2-2 What "impacts" to address in the short term, versus longer-term horizons
Phasing in implementation is a common management consulting approach; phase one is typically to address a "known goal" and then make sure that the current management system (i.e., the one that management thinks is in place to address that goal) is complete and operating as management believes it should. To reiterate, the objective of this first phase is to assess and improve the "current management system;" there is no immediate setting of new goals (i.e., no aspects and impacts analysis) in phase one.
Typically for most installations the "known goal" is compliance and, implicit if not directly stated, compliance assurance (i.e., making sure of staying in compliance). This is a goal that most organizations are aware of without doing additional research into legal and other requirements or working through a full blown aspects and impacts analysis. There might be some question (tactically) as to what compliance means for purposes of this phase; compliance with enforceable regulations (e.g., air, water, and waste) is most common rather than executive orders and policies. This is not to say these others are not important; they are just not as likely to create the bad publicity and financial penalties as will a problem with regulatory non-compliance.
The effort under phase one will be focused, therefore, on the Implementation and Operations EMS components (e.g., 4.4 of ISO 14001), Checking and Corrective Action components (e.g., section 4.5 of ISO 14001), and Management Review components (e.g., section 4.6 of ISO 14001) specifically for the goal of compliance with all applicable federal, state and local environmental laws and regulations. You may be surprised to find that some of these components are lacking in some form, whether merely documentation, or in actual understanding and consistency (i.e., in substance as well as actual use) of the components themselves.
Addressing the status of these EMS components that management believes already exist for known
compliance goals will begin the EMS design and implementation. Furthermore it will allow the line staff
and environmental services employees to understand and "buy-in" to the need for a clearly defined management
system to meet a goal that they have long accepted and understood.
2-3 What supporting elements are needed (contractors, implementation software)
One strategic issue that immediately links to tactical decisions is the installation's resource needs. Because the work of the Environmental Division is not going to be put on hold while the EMS design and implementation is taking place, these resources are typically not available to provide major support for this effort. Also, because EMS implementation, if done correctly, will span numerous line management operations, as well as contractors and suppliers, the communications and project management are complex and extended. Therefore, the third strategic issue concerns resources to ensure that the EMS moves forward.
Labor -- Often new hires, temporary hires, onsite contracted employees, or contractor-supplied services are needed to handle the pulse of additional EMS implementation work that is over and above the usual efforts of your staff (both line staff and environmental services staff).
Environmental Management System Software -- There are numerous EMS software systems available as Conventional-Off-The-Shelf (COTS) and GOTS (Government-Off-The-Shelf) technology, as customized solutions, and as "from-scratch" systems built by the facilities themselves. Senior management should be aware that many systems are little more than document management systems or GIS systems that identify program component locations (e.g., SWMUs or satellite storage areas for RCRA).
An EMS software system should at minimum include some project management components such as scheduling, team identification, and resource identification. Better systems should include basic tracking systems, communications support systems, and document review systems. Better yet, systems should include e-mail interface, calender- and event-driven notification systems, live tracking systems, and other programmed options. GIS support systems may be effective in this effort. They should be more than merely mapping support (location of components) but should allow management system activities to be identified and inventoried per operating unit (e.g. motor pool, paint shop) that is under a common management and has a set of unit-specific environmental objectives and targets.
Obtaining Management Commitment
| Developing a Design and Implementation Strategy
| Tactical Issues for Design and Implementation
| Addressing Operational Issues
