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Implementation

• Where to Start
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• Sample EMS Manuals
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Where to Start: Tactical Issues for Design and Implementation

Having decided on the strategic issues of what will be the Fenceline (a unit, or the entire base) and what will be the Goal Level (Phase 1 - Compliance or, on the other end of the range, sustainable installations), and what type of support will be engaged, several tactical issues need to be addressed. These usually include the following:

• Inventory Existing Programs -- What existing components of an EMS are already in place for your initial target operations and which must be developed;
• Designate EMS Implementation Team -- Whose input is needed to design the EMS and ensure that its components are appropriate and efficient? Your Team should include Managers of all major activities including procurement and facility maintenance.
• Provide EMS Training -- Determining when and what kind of startup training is needed for the implementation team as well as EMS awareness training for the operational unit involved in the phase one efforts.

3-1 Inventory Existing Programs

An inventory of existing programs to determine existing EMS components often is done under the misnomer of "gap analysis." This effort is intended to evaluate what is present at an installation (the "inventory"), not what is missing (the "gap"). Programs that should be inventoried and evaluated for relevance to the EMS include the following:

Quality Management System (ISO 9000)

• Document control systems
• Roles and Responsibilities
• Management review systems>/

Environmental Compliance Management Programs (Regulatory drivers)

• Waste Management Programs (RCRA)
• Air Management Programs(CAA)
• Wastewater management programs (CWA)
• Right-to-Know management programs (EPCRA)

Beyond Compliance Programs

• Pollution Prevention (including Waste Minimization)
• Energy Efficiency Programs (Power or fuel conservation)
• Water Resource Management Programs (Water minimization)
• Resource Conservation Programs (Wetlands, Woodlands, Waterways, endangered species)

Sustainability (include community in initiatives)

• Community Support Programs
• Encroachment Management Programs
• Public Relationships

Other Risk Categories

• Occupational Health
• Safety
• Hazardous Material Management Systems
• EHS Security (securing WWTP, Hazardous Materials/Waste)

3-2 Designate EMS Implementation Team

At least one senior staff person in each of the installation's business units should be assigned responsibility for assisting in the design and implementation of the EMS, to ensure that environmental considerations are integrated throughout the facility's operations. Environmental Program staff will focus on compliance-related policies and programs. Staff from all other operating units will serve as points of contact and provide information to ensure that their activity's environmental responsibilities are properly identified and characterized and that all organizations coordinate with other functions on interrelated activities that affect environmental issues and programs. Your Team should include Managers of all major activities including procurement and facility maintenance.

3-3 Provide EMS Training

Implementation Team Training -- Before starting up the actual implementation, the implementation team selected should be trained in:

• the basics of EMS,
• basic principles of process management systems (separation of oversight and activity, continual improvement concepts, leverage approaches, linkage of roles to responsibilities--responsibilities to objectives--objectives to goals, system metrics),
• basics of project management (scheduling, schedule recovery, resources management, budgeting)
• implementation issues (buy-in by employees, roll-out strategies, phased/incremental approaches, feedback and improvement)

EMS Awareness Training -- Every individual and function in the organization has a role in the EMS. The objective of EMS awareness training is to ensure that they understand the EMS Policy, understand the environmental impacts of their work, and understand the specific EMS procedures and responsibilities that will apply to them. Staff should understand that environmental responsibilities may be incorporated into existing procedures and new procedures may be introduced. The content of the EMS training will be installation-specific. EMS training can be a stand-alone training or can be incorporated into existing training opportunities, such as new employee orientation or annual HazCom refreshers.

At this point in the implementation employees with specific environmental management responsibilities may be receiving additional environmental management training. This training is being performed despite the EMS planning activities, rather than as a part of them. This is not necessarily a problem, as long as an awareness of ongoing or upcoming EMS planning and implementation activities is considered.

Obtaining Management Commitment | Developing a Design and Implementation Strategy | Tactical Issues for Design and Implementation | Addressing Operational Issues

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