Managing an EMS With Curtailed Resources

Con Underwood Consulting, LLC

378 Lost Trail RoadJefferson, Georgia 30549706-367-2647 (w), 706-338-9096 (mobile)[email protected]

Managing an EMS With Curtailed Resources

© Con Underwood Consulting, LLC, 2013 Page 1

Managing an EMS With Curtailed

Resources

mailto:[email protected]




Page 2© Con Underwood Consulting, LLC, 2013

• Many of us were not not originally environmental scientists

• Many of us inherited our jobs

• Many of us perform several other jobs

• Environmental is sometimes out-prioritized by other domains

• Many employees don’t understand “environmental”

• Things got much worse when the recession hit

Practical Advice for

Managing EMSs in Today’s Economy

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• We all want to protect our environment

• Methods exist for doing a good job environmentally despite these challenging circumstances

THE GOOD NEWS:






• Understand the scope – get macro data• Understand consequences

– Immediate health hazards– Clear violations of regulations

• Potentially serious pollution• Big fines

– 14001 non-conformances• Risk to certificate renewal• Loss of sales

– Work Instruction violations: CARs– Bad housekeeping: more aggressive

audits or inspections

Cleaning up Issues as HSE Specialists Leave

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• Triage your issues – find out what your most risky environmental aspects are:– Hazardous waste?– Storm water?– Used oil?– Reporting?

• Walk through with someone who knows some environmental – inside AND everywhere outside– Maintenance– Savvy operators– Facilities engineering– Quality

• Manage your time to address risky items first

Cleaning up Issues as HSE Specialists Leave






• Give experts time to document and train others before they go

• If Work Instructions are incomplete, request a series of cheat sheets:

– Hazardous waste procedures– Outfall sampling procedures– Used oil recycling– Universal waste procedures– Environmental reporting files– Filing system indexes

Document for a Smooth Transition - Crucial as Downsizing Occurs





© Con Underwood Consulting, LLC, 20133-11-13

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• Why?

– Reduce risk in audits and inspections

– Save time finding data daily

– Spend less of consultants’ time looking for your data

– Simplify delegating tasks

– Stand-alone documentation survives turnover of employees

Establish and Maintain an Environmental Filing System






• Get a fireproof, locking file cabinet for paper, permits, certifications, training log signatures

• Establish a detailed outline (don’t hesitate to copy someone else’s):

– Compliance top level: water, air, RCRA, CERCLA, EPCRA, etc.

– Conformance top level: elements of 14001 standard

• Mirror the filing system digitally:

– Server directories

– Intranet applications – BEWARE THE I.T. GUYS

– Email folder structures

• Back up hard drives, servers, email

Establish and Maintain an Environmental Filing System






• Interpretations of ISO 14001 conformance have been modernized

– ANAB (governing body) re-reinterpretations of standard promote more effective EMSs

– Focus is on results, less time wasted on paperwork

• Increase your EMS’s effectiveness with LESS time investment

• Remember: entire ISO 14001 is 9 pages long

– Intended to be robust

– Compliance methods subject to interpretation

– You are your registrar’s customer

Reduce Paperwork in 14001 Compliance






• Replace numerical schemes for assessing significance of environmental aspects with criteria

– Significant if training, monitoring or measurement and controls are needed

– Significant if had recent issues with aspect

• Labor-intensive “competency” evaluation

– Take credit for all forms of competency assessment:

• Routine supervisory interaction

• Other existing performance measures

Revise Paper-intensive Conformance Procedures











• Don’t internally over-audit

– Delegate internal auditing

– Audit significant aspects, elements in manageable chunks

• Avoid onerous management review meetings

– Implement a system of meetings – not one huge meeting

– Include all relevant management exposure to EMS

Utilize your Existing Procedures to Conform to 14001











• Remember who your audience is– In many cases they are legally

required to have awareness only– You are obligated to make them

environmentally effective– Reduce time spent on esoteric

topics• Focus on training that will help them

comply with regulations• Delegate some training to

supervisors, line chiefs

Train for Effectiveness

3-11-13






• Increase the frequency of exposure to topics

– Use supervisor safety briefings

• Spread training across the year

• Infer training priorities from your auditors, inspectors

• Assess real competency, not just test-taking ability

Make Sure Trainees Internalize the Message






• Many small facilities combine functions – it’s unavoidable

• Many areas of safety / environmental overlap – Hazard Communications– Management systems – VPP, SHARP

• Safety documentation and file organization is as important as environmental – for same reasons

• Use OSHA website resources– Good inspection checklist : “small business”

• Good list of training topics: – BLR 7-minute safety table of contents– KellerOnline toolbox talks

Managing Environmental and Safety






• Quality of their environment at home

• Non-compliance means money out of THEIR pockets and less job security

– Fines

– Insurance costs

– Lost new sales

– Less job security

– Poor product quality

• Reduced quality of life due to injury

Safety and Environmental Culture: Employees Need to Know Why They

Need Both






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• Plant management– Start here– Do not proceed without management backing

• Managing consultants– Write specific statements of work– Support them with good data and files to

minimize your expenditures• Corporate resources

– Sometimes invaluable– Sometimes irrelevant– Always: Understand and plan for their role

Your Best Hope: Use THE TEAM





© Con Underwood Consulting, LLC, 20133-11-13 Page 19

• Quality Assurance– Good for help learning 14001– Similar methodology to 9000, TS

• “Show Me the Shall” blog• Maintenance managers - you’re lost without them

– Key technology person in plant– Learn to communicate– Pick your battles– Learn to compromise– Earn their respect

• GTRI– In GA, invaluable free expert resource– Look for counterparts in your state– Confidential is good

Use THE TEAM






• HR– Closer to environmental than you may think– Environmental incidents require same HR

support as safety:• Investigation• Accountability

• Vendors – Reporting quantities

• Tier II usages, maximums• Ozone depleting substances

(refrigerants)– Waste haul records

• Most important: the employees

Use THE TEAM






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• This job is managing• Management skills required

– People skills– Time management– Persuasion– Prioritization– Investment of time up front– Personal organization– Organizational dynamics– Contract management

• 80% management, 20% technical

• THANK YOU FOR YOUR TIME!

EMS – Environmental MANAGEMENT System






CON UNDERWOODCon Underwood Consulting, LLC

706-338-9096

[email protected]

conunderwood.com



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Managing an EMS With Curtailed Resources