Environmental Management SystemsA new standard for environmental management is coming.

BY ROBERT N. CARROW AND KEVIN A. FLETCHER

Identifying your golf course's environmental attributes and impacts is an important part of the planning process(Itasca Country Club, Itasca, Illinois).

M anagenlent of the naturalenvironment by businesses hasbeen dominated for nearly 40

years by legal, regulatory, command-and-control approaches. From theClean Water Act to chemical use andregulation, business owners and man-agers, including in golf, have addressedenvironmental issues in prescribedmanners - answering to federal, state,and even local law. While legal require-ments are not going away in the nearfuture, more and more agencies andbusinesses are gravitating toward a newstandard for enhancing environmentalmanagement and stewardship, one thatemphasizes proactivity and systematicdetail. This new focus on Environ-mental Management Systems is some-thing that is sure to infiltrate themanagement of golf courses in theyears to come.

Environmental ManagementSystems (EMS) are rapidly becomingthe accepted standard to identify andmanage all environmental issues com-prehensively for all enterprises ( manu-

facturing plants, restaurants, businesses,waste treatment facilities, agriculturalfacilities, golf course facilities, etc.).The EPA's position statement on EMSillustrates this point (USEPA 2007):• EPA will encourage widespread useof EMSs across a range of organizationsand settings, with particular emphasison adoption of EMSs to achieveimproved environmental performanceand compliance, pollution preventionthrough source reduction, and con-tinual improvement ....• EPA will promote the voluntaryadoption of EMSs. To encouragevoluntary adoption of EMSs, EPA willrely on public education and voluntaryprograms.• This document is EPA's strategy foraddressing the question of whether -and if so, how - it may also beappropriate to consider EMSs in thecontext of the Federal regulatorystructure, either to improve the designof regulatory programs, to encouragethe use ofEMSs, or both. EPA wishesto make clear that it has no intention

of mandating the use of EMSs in rulesand permits. Rather, the aim of thisstrategy is to determine whether therecould be benefits from providingoptions within the regulatory structurefor organizations that choose to adoptan EMS. In addition, this strategy doesnot signal any intent on the part of theagency to modify its existing policy ofpromoting the widespread use ofEMSs on a voluntary basis.

Prior to the EMS concept, manage-ment of environmental issues for afacility was issue by issue, but an EMSis: a) a new management approach,b) for the whole system, c) for allenvironmental issues, and d) for dailyenvironmental management decisionsat all management levels within anorganization to be the normal practice.As the EMS approach is increasinglyadopted by golf courses, it willdramatically impact how managementand operations are conducted in allcomponents of a facility. Thus, it isimportant for course owners, officials,and members to understand it. In a

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second paper in this two-part series,we will focus more specifically onwhat a golf course EMS may entailand the implications, but in the currentpaper the focus will be on understand-ing the EMS concept. For additionalinformation, Carrow and Fletcher(2007) recently developed an educa-tional guidebook for golf courses onthe EMS concept and implications .

HISTORY OF EMSWith the birth of the environmentalmovement in the 1960s, businesses ofall shapes and sizes found themselvesresponding to a new set oflegal andsocial demands. Most of the earlyimpacts on businesses were centeredon legal and regulatory compliance.However, the past decade has seen agrowth in the number of new toolsbusinesses are using to manage theirenvironmental issues. One verysimple, yet growingly pervasive trendin business is the implementation ofEnvironmental Management Systems(EMSs).

An EMS is a proactive approachto environmental stewardship thatinvolves establishing an environmentalpolicy and a long-term commitment

Figure IKey components of USEPA.

to environmental management. Themost common EMSs are based uponthe framework developed by the Inter-national Organization of Standards(ISO), a non-governmental networkof national standards institutes fromvarious countries. ISO is the world'slargest organization devoted to thedevelopment of standards, especiallytechnical standards (ISO 2007) andstandards for quality (ISO 9000). In1996, with revision in 2004, the ISOdeveloped a standard for environmentalmanagement entitled "ISO 14001Environmental Management System."The ISO 14001 standard is defined as"the part of the overall managementsystem that includes organizational

structure, planning activities, responsi-bilities, practices, procedures, processes,and resources for developing, imple-menting, achieving, reviewing, andmaintaining the environment." ISO14001 (1996) consisted offive principalor key components in a cyclic process:• Commitment and Policy• Planning• Implementation• Measurement and Evaluation• Review and Improvement

Within agriculture, horticulture,and the golf course industries, theEMS concept is the furthest developedin Australia. The February issue ofAustralian Journal ifExperimentalAgriculture, Volume 47(3), 2007, wasdedicated to EMS in agriculture andhorticulture. Environmental BusinessSolution (EBS, 2007, Australia) devel-oped the e- PAR program in conjunc-tion with the AU EPA and AustralianGolf Course Superintendents Associa-tion, and it is the most advanced pro-gram applying the EMS concept togolf courses in the world. Other volun-tary environmental programs, such asthe Audubon Cooperative SanctuaryProgram for Golf Courses, also relyupon this general approach.

RELATED ENVIRONMENTAL TERMS OR CONCEPTSTerms or programs that may be confused with EMS areEnvironmental Management Plan (EMP), EnvironmentalAudit (EA), and National Environmental PerformanceTrack (NEPT) program (NEPT, 2007). An EMP is much narrowerthan an EMS and is generally considered a plan to mitigate andmonitor a single environmental issue. A very similar concept to anEMP is Best Management Plans (BMPs), which are developed tomanage a particular environmental issue (Carrow et aI., 2005).Thus, EMPs or BMPs are part of an overall EMS, while the EMSrefers to the whole system or approach.

An Environmental Audit is a means to determine whetheran EMS is effectively implemented or not. As such, an EA is a partofthe overall EMS- Le., one ofthe components. The ISO 14001definition of an EA is, "An EMSAudit is a systematic and docu-mented verification process of objectively obtaining and evaluatingevidence to determine whether an organization's EMS conformsto the EMS audit criteria set by the organization and for com-munication of the results of this process to management" (ISO2007). The Club Manager's Full Facility Environmental Audit(www.cmaa.org/audubon.htm) is one example of a stand-alonefacility audit.

The EPA has a National Environmental Performance Track(NEPT 2007) program that is "a voluntary partnership program that

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recognizes and rewards private and public facilities that demonstratestrong environmental performance beyond current requirements.Performance Track is designed to augment the existing regulatorysystem by creating incentives for facilities to achieve environmentalresults beyond those required by law. To qualify, applicants musthave implemented an independently assessed environmentalmanagment system (Le., EMS), have a record of sustained com-pliance with environmental laws and regulations, commit to achievingmeasurable environmental results that go beyond compliance, andprovide information to the local community on their environmentalactivities. Members are subject to the same legal requirements asother regulated facilities. In some cases, EPA and states have reducedroutine reporting or given some flexibility to program members inhow they meet regulatory requirements. This approach is recog-nized by more than 20 states that have adopted similar performance-based leadership programs." Thus, a facility that has an EMS maywish to participate in the NEPT program as an addition, but it is nota part of the EMS. One of the criteria for the NEPT program is tohave a comprehensive independent assessment of the organization'sEMS. Thus far, only one golf facility, Colonial Acres Golf Course inNew York, has completed the NEPT process - using much of thedocumentation required for certification in the ACSP for GolfCourses as a baseline EMS.

Improving environmental performance has numerous benefits, including risk reduction, improvedefficiency, enhanced image and reputation, and reduced costs. (Sterling National Country Club,Sterling, Massachusetts).

USEPA EMS MODELThe ISO 14001 was, therefore, devel-oped to "standardize" a managementapproach for entities to manageenvironmental issues in a systematicmanner. Since 1996, the ISO 14001EMS approach has been increasinglyadopted in many areas of the world,including the USA, but often withsome modification. The USEPAmodified the ISO 14001 so that theEPA EMS entails a continual cyclewith four key components, summarizedin a plan, do, check, act format, wherethese key components are defined as(USEPA 2007a):• Plan: Planning, including identifyingenvironmental aspects and establishinggoals .• Do: Implementing, including trainingand operational controls .• Check: Checking, including moni-toring and corrective action .• Act: Reviewing, including progressreviews and acting to make neededchanges to the EMS.

The cyclic design of EMS illustratesthat management of environmentalissues is to be an ongoing process withchanges made over time.

ELEMENTS OF THETRADITIONAL EMSThe principal components (plan, do,check, act) of the USEPA EMS are nor-mally expanded into 17 key elementsor steps related to the development andimplementation of an EMS for anentity. The 17 key elements as outlinedby the EPA are (USEPA 2007b):

1. Environmental principles andpolicy: Develop a statement of yourorganization's commitment to theenvironment. Use this policy as aframework for planning and action.

2. Legal and other requirements:Identify and ensure access to relevantlaws and regulations, as well as otherrequirements to which yourorganization adheres.

3. Identify/assess significantenvironmental aspects and impacts:Identify environmental attributes of

your products, activities, and services.Determine those that could have sig-nificant impacts on the environment.

4. Objectives and targets: Estab-lish environmental goals for yourorganization in line with your policy,environmental impacts, the views ofinterested parties, and other factors.

5. Develop environmentalmanagement programs: For eachenvironmental issue, an action plan isformulated. Plan actions necessary toachieve your objectives and targets.

6. Structure and responsibility:Establish roles and responsibilities forenvironmental management and pro-vide appropriate resources.

7. Training, awareness, andcompetence: Ensure that youremployees are trained and capable ofcarrying out their environmentalresponsibilities.

8. Communication and outreach:Establish processes for internal andexternal communications on environ-mental management issues.

9. EMS documentation: Main-tain information on your EMS and

related documents. This would includeBMPs for each environmental impactIssue.

10. Document control: Ensureeffective management of proceduresand other system documents.

11. Operational control: Identify,plan, and manage your operations and

activities in line with your policy,objectives, and targets.

12. Emergency preparedness andresponse: Identify potential emergen-cies and develop procedures for pre-venting and responding to them.

13. Monitoring and measure-ment: Monitor key activities andtrack performance. Conduct periodicassessments of compliance with legalrequirements.

14. Nonconformance and cor-rective and preventive action:Identify and correct problems andprevent their recurrence.

15. Environmental records:Maintain and manage records of EMSperformance.

16. EMS audit: Periodically verifythat your EMS is operating as intended.

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17. Management review:Periodically review your EMS with aneye to continual improvement.

A review of the 17 steps revealsseveral important points. First, when afacility embarks on development andimplementation of an EMS, manage-ment, policy issues, training, and com-munications are significant activities interms of time and commitment. Whenreading USEPA or other governmentalagency materials related to EMSs,most of the material will be related tothe areas of management structure,management activities, development ofeffective communication lines within afacility, and educational needs at variouslevels. Much of the discussion alsorelates to facilities larger than most golfcourses, where management structureand activities, communications, andeducational aspects can be integratedinto existing management structureswith fewer challenges than facilitieswith more complex management hier-archies. However, when reading thesematerials, one can easily get "boggeddown" in the management emphasisand suggested changes.

Second, in contrast to the extensivematerials on management, communi-cations, and education, limited infor-mation will be noted relative to the real((core" ifan EMS plan, which includes:a) Element 3 - Identify/assess signifi-cant environmental aspects and impacts,and b) Element 5 - Develop environ-mental management programs for eachsignificant environmental issue. Sincethe foundational ISO 14001 EMS isreally a standardized approach tomanaging environmental issues for alltypes of entities, their materials empha-size the common areas of manage-ment, communications, and educationchallenges. However, the actual envi-ronmental issues that may be present ata facility vary substantially, dependingon the nature of the entity - e.g., theenvironmental issues of a golf coursewould differ from those of a manufac-turing plant - and therefore are notdiscussed.

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Third, a central purpose of the EMSconcept is to incorporate environ-mental management into daily manage-ment decision-making at all manage-ment levels of a facility. Attention toenvironmental issues at all managementlevels is added to current parametersthat may influence daily managementdecisions. In this way, an EMS-typesystem can help to foster an environ-mental culture at a facility - makingenvironmental stewardship "the waywe do things around here."

EMS BENEFITS AND COSTSSince the EMS approach to manage-ment of environmental issues is volun-tary and integrated into daily manage-ment of a facility, the aspects of benefitsand costs related to an EMS are impor-tant components in the developmentand implementation of a facility EMS .Potential benefits and costs of EMS interms of both business and environ-mental aspects are (USEPA 2007a):

BENEFITS TO A BUSINESS• Improve overall environmentalperformance.• Prevent pollution.• Save money on landscape mainte-nance, energy, materials, etc.• Enhance existing compliance effortsrelated to environmental aspects.• Reduce or mitigate risks andliabilities.• Exhibit environmental due diligence.• Increase efficiency.• Reduce costs.• Enhance employee morale andpossibly enhance recruitment of newemployees.• Achieve/improve employee aware-ness of environmental issues, responsi-bilities, and initiatives.• Promote a positive, proactive corpo-rate image related to environmentalissues and club achievements withregulators, lenders, investors, and thepublic.• Qualify for recognition/incentiveprograms such as the EPA PerformanceTrack Program (NETP 2007) and

other state-based voluntary environ-mental performance recognitionprograms.

As noted, development and imple-mentation of an EMS by a golf clubdemonstrates to the public and regu-lators a proactive attitude towardenvironmental stewardship that doesenhance the corporate image. AnEMS program and associated docu-mentation can be valuable tools forplanned community outreach andeducational efforts by a golf course. Agood outreach and educational programinvolving club officials can result insignificant benefits at the communitylevel.

COSTS TO A BUSINESS• An investment of internal resources,including staff! employee time.• Costs for training of personnel.• Costs associated with hiring consult-ing assistance, if needed.• Costs for technical resources toanalyze environmental impacts andimprovement options, if needed.

Like any investment of resources,these potential costs must be balancedagainst the anticipated return oninvestment (benefits).

KEY IMPLICATIONSNot all in the golf industry or otherindustries will be pleased with anotherenvironmental program, concept, oracronym. More limited environmentalmanagement programs have evolved inthe past out of concern over particularenvironmental issues, and these havesubstantially impacted how golf coursesoperate. For example, starting about30 years ago, the u.S. EnvironmentalProtection Agency (EPA) Clean WaterAct, targeted to protection of surfaceand subsurface water quality frompesticides, nutrients, and sediments,resulted in the "Best ManagementPractices" (BMPs) concept as well asthe "Integrated Pest Management"(IPM) concept (Rawson 1995, EPA2005).

An Environmental Management System (EMS) offers an integrated environmentalstrategy for the entire golf maintenance program, from best management practices,to emergency preparedness, to employee training.

Over time, however, EMS will havea much more profound impact on thegolf industry than any previous envi-ronmental initiative, but it will be rela-tively easy to understand and imple-ment since it is built on encompassingcurrent BMPs, IPM programs, andeven traditional business managementapproaches (i.e., Total Quality Man-agement). It is good toremember that the alter-native to this voluntaryprogram is likely to bemore rigid regulations.

With acceptance atinternational and multipleindustry levels, EMSshould best be viewed asan opportunity rather thanan obstacle. It is wise forthe golf industry to under-stand and accept this con-cept. For golf courseowners and managers, thefollowing points areespecially pertinent:• The EMS concept ispromoted by regulatoryagencies on an inter-national basis as the best means tomitigate or manage environmentalissues for all businesses or entities thathave potential environmental impact.• EMSs are for all facilities of anindustry - i.e., all golf courses willvery likely need to develop their ownsite-specific EMS plan.• The EMS concept binds togetherall environmental issues at the wholefacility - i.e., clubhouse, maintenancefacility, general grounds, pool, golfcourse, and any other part of thefacility.• All environmental issues are tobe assessed and management plansdeveloped and implemented for allenvironmental issues at a facility.An EMS allows combining togetherinto one system the various BMPsfor each particular environmentalIssue .• The term Environmental Manage-ment Systems (EMS) truly reflects the

nature of EMS as: a) a new manage-ment approach, b) for the whole system,c) for all environmental issues, andd) for daily environmental managementdecisions at all management levelswithin an organization to be thenormal practice.• Since EMS is for the whole facility,upper management and organization-

wide commitment are necessary. Thisentails organization-wide training.

While this first article has provideda summary of the EMS concept, theapplication to golf course facilities stillrelies on wrestling with the "devil" inthe details. The second article of thisseries will focus more specifically ongolf courses and challenges that mayarise, especially in assessing environ-mental issues, developing BMPs foreach issue, and auditing. It is importantto remember that no one "owns" anEMS for golf-it is a concept andapproach available to anyone willingto think and act systematically towardthe environment. However, the ele-ments that golf owners and managersshould pay attention to are both thedetails of the process of an EMS as wellas the content of identified environ-mental issues and related BMPs. AnEMS alone will not solve all the envi-ronmental problems of golf course

management, but it can be an effectivepart of the solution.

REFERENCES1. Carrow, R. N., and K. A. Fletcher. 2007.Environmental Management Systems (EMS)for Golf Courses. An educational guidebookdeveloped by the University of Georgia andAudubon International. Posted on http://www.auduboninternational.org/e-Source/

and http://www.georgiaturf.com.2. EBS. 2007. EnvironmentalBusiness Solutions e-Parprogram for golf courses. Website. http://www.epar.com.au/brochure/Default.aspx.3. ISO. 2007. InternationalStandards Organization (ISO)Web site. http://www.iso.org/iso/ en/ISOOnline.frontpage.4. NEPT. 2007. NationalEnvironmental PerformanceTrack Web site. http://www.epa.gov/performancetrackl.5. Rawson,). M. 1995. Con-gressional Research ServiceReport to Congress: Sustain-able agriculture. CRC Reportfor Congress, 95-1062 ENRD.Congressional ResearchService, Committee for theNational Institute for theEnvironment, Washington,D.C. www.ncseonline.org/

NLE/CRSreports/ Agricul-ture/ag-14.cfm?&CFID = 962773 &CFTOKEN =76886153.

6. Stapleton, P.J., M. A. Glover, and S. P.Davis. 2001. Environmental ManagementSystems: An Implementation Guide for Smalland Medium-Sized Organizations. 2ndEdition. NSF International, Ann Arbor, Mich.Online at http://www.epa.gov/OW-OWM.htmlliso 14001/wm046200.htm.

7. USEPA. 2005. National ManagementMeasures to Control Nonpoint Source Pollu-tion from Urban Areas. EPA-841-B-05-004.U.S. EPA, Office of Water, Washington, D.C.8. USEPA. 2007. USEPS Web site on EMSposition statement. http://www.epa.gov / ems/position /position. htm.9. USEPA. 2007a. USEPA Web site onEnvironmental Management Systems.http://www.epa.gov / ems/index.html.10. USEPA. 2007b. Key elements of an EMS.http://www.epa.gov/ems/info/elements.htm.

DR. ROBERT N. CARROW is prcifessor)Turfgrass Stresses / Soils) The University ofGemgia) Griffin Campus; DR. KEVIN A.FLETCHER is director of programs andadministration) Audubon International)Selkirk) N. Y

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