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Version 2.1 – April 2, 1999 THE UNIVERSITY OF NORTH CAROLINA AT CHAPEL HILL John J. Villani Assistant Professor Director of Graduate Studies Curriculum in Public Policy Analysis CB# 3435, Abernethy Hall Chapel Hill, NC 27599-3435 (919) 962-2789; Fax: (919) 962-5824 e-mail: [email protected] Data Protocols for Use in EMS/ISO 14001 Pilot Projects Background Regulatory agencies at both the state and federal levels are currently evaluating the impact of voluntary environmental management systems (EMS), based on the ISO 14001 standard, as a possible tool in public policy innovation and decision making. This evaluation is being conducted through a series of pilot projects with a wide variety of regulated organizations who voluntarily choose to participate and share information on the design and implementation of their EMSs. States and EPA are collaborating on these pilot projects and seek input from a variety of other parties as they are conducted. The evaluation of pilot project EMSs and the subsequent public policy decisions will only have credibility if they are based on the collection of comparable information of known quality backed up by vigorous analysis and research. To this end, a number of states, with participation from EPA and others, have developed a common framework for collecting information through

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Page 1: Protocol I - ibiblio.org  · Web viewWithin these processes, waste production is prevented or reduced rather than curbed after its production. Pollution prevention does not include

Version 2.1 – April 2, 1999

THE UNIVERSITY OF NORTH CAROLINA AT

CHAPEL HILL

John J. VillaniAssistant ProfessorDirector of Graduate StudiesCurriculum in Public Policy Analysis

CB# 3435, Abernethy HallChapel Hill, NC 27599-3435

(919) 962-2789; Fax: (919) 962-5824e-mail: [email protected]

Data Protocols for Use in EMS/ISO 14001 Pilot Projects

Background

Regulatory agencies at both the state and federal levels are currently evaluating the impact of voluntary environmental management systems (EMS), based on the ISO 14001 standard, as a possible tool in public policy innovation and decision making. This evaluation is being conducted through a series of pilot projects with a wide variety of regulated organizations who voluntarily choose to participate and share information on the design and implementation of their EMSs. States and EPA are collaborating on these pilot projects and seek input from a variety of other parties as they are conducted.

The evaluation of pilot project EMSs and the subsequent public policy decisions will only have credibility if they are based on the collection of comparable information of known quality backed up by vigorous analysis and research. To this end, a number of states, with participation from EPA and others, have developed a common framework for collecting information through pilot projects. This framework is described in detail in the attached Protocols.

The remainder of this summary describes the purpose and intended use of the data protocols and gives an overview of their content and structure. The protocols were developed by the University of North Carolina (UNC) and the Environmental Law Institute (ELI). They have been reviewed extensively by both states and EPA offices and are now ready for use by pilot project managers and facilities.

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Purpose and Intended Use of the Protocols

The primary function of the protocols is to guide the collection of standardized and comparable data from a wide variety of pilot project facilities. Only in this way can the information be incorporated into a common database for use by state and federal regulatory as well as the public. The data called for in the protocols are based on the kinds of information that facilities seeking to establish an EMS based on ISO 14001 would generally need to collect. As such, they have been constructed so as to minimize any additional burden that participating facilities might face.

The primary users of the protocols are state personnel managing pilot projects and participating facilities themselves. Most states have chosen to take on primary responsibility for ensuring that the necessary data are collected according to the protocols. These states are assisted, as necessary, by staff from both UNC and ELI. In these cases, state agency staff must have a thorough understanding of the protocols. To that end UNC and ELI have provided training on use of the protocols to state agency staff that interact with pilot facilities. Also, UNC and ELI staff work closely with state agency staff to resolve any ambiguities or other questions about the protocols in a consistent and timely manner. Finally, some states have elected to have UNC and ELI play a larger role in primary data collection, requiring less state resources and more direct interaction with firms by UNC and ELI.

Facilities that have decided to or are considering participating in a pilot project should be given these protocols as soon as possible. State agency staff should be in a position to answer questions posed by these facilities. UNC and ELI staff are also available to assist states, as necessary.

UNC, with the assistance of staff from ELI, are responsible for establishing the database to receive and process pilot facility data. They are also be responsible for ensuring data quality, maintaining the integrity of the data base, and producing periodic reports based on the data submitted that follow the protocols. Over time, data will also be available to other organizations that wish to pursue their own independent research. In all cases, states and EPA will seek to ensure the confidentiality of facility-specific data in the database.

Finally, EPA and states believe the collection of data in all categories contained in the protocols will allow the fullest understanding and evaluation of the benefits of an EMS. As such, pilot project participants are encouraged to make every effort to complete the Protocols in their entirety over the life of the project.

Content and Structure of the Protocols

The protocols cover the following categories considered important by the states and USEPA: (1) environmental performance; (2) regulatory compliance; (3) environmental conditions; (4) costs and cost savings; (5) pollution prevention; (6) interested party involvement; and (7) the nature of the management system.

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The protocols are organized into three documents – Baseline Protocols, EMS Design Protocols, and Update Protocols. This is the second of the three. It is a one-time study to be completed when the facility designs it EMS. The EMS Design Protocol asks the facility to describe in detail the nature of its EMS, and the process the facility used to create the EMS.

Questions or comments about the protocols should be directed to:

John VillaniUniversity of North Carolina at Chapel Hill(919) [email protected]

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Data Collection Protocols for ISO 14001 Pilot Project Research

EMS Design Protocols

Version 2.1

April 2, 1999

Direct questions and comments to:

John VillaniUniversity of North Carolina

CB# 3435, Abernethy HallChapel Hill, NC 27599Phone: (919) 962-2789

Fax: (919) 962-5824e-mail: [email protected]

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Protocol II ISO 14001-based EMS Design

Timing: Protocol II is to be completed while the facility is designing its EMS. Since it is meant to be an ongoing recording of the design process, the facility is asked to complete relevant sections of the survey at two stages in the EMS design process. First, the facility is asked to submit relevant sections after it has completed the “Setting Objectives and Targets” stage of ISO EMS design. Second, the facility is asked to complete the balance of the EMS Design Protocols after the facility has reviewed its completed EMS.

Overview: Protocol II is intended to elicit information about the decisions the pilot facility has made at critical stages during EMS design, and the process by which these decisions were made. The ISO 14001 standard affords the facility great flexibility to make decisions about many aspects of its EMS, including the means and extent of public involvement in EMS design and operation, the definition of environmental aspects and impacts and the determination of the significance of these aspects and impacts, the scope and extent of operations covered under the EMS, the level of participation of various levels of the facility’s management, etc.

The questions in this protocol are based on relevant portions of the ISO 14001 International Voluntary Standard for Environmental Management Systems. The requested information is similar to, but not as detailed as the information that would be collected during the course of an external ISO 14001 EMS certification audit. The protocol has been designed to minimize the time and effort needed to complete it.

We ask that the pilot facility agree to be interviewed either in person or by phone by a member of the Core Research Staff to clarify facility responses, if necessary. While we will not complete the survey for you, we will be able to assist you and answer specific questions about the information being requested.

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Facility Name:Facility Contact:Phone Number:

1. Rationale for Adopting an ISO 14001-based EMS

(1.A) From the list of options below, please circle the appropriate letter (H= high importance; M= medium importance; L= low importance; N/A= not applicable) to rank the following items in terms of how important each one was to your facility’s decision to design and adopt an ISO 14001-based EMS.

H M L N/A Parent company requires adoption of an ISO 14001-based EMS

H M L N/A Pressure by regulators to implement an ISO 14001-based EMS

H M L N/A Domestic customers demand ISO 14001 certificationH M L N/A International customers demand ISO 14001 certificationH M L N/A Shareholders or owners demand certificationH M L N/A Insurers may reward ISO 14001 certificationH M L N/A ISO 14001 may be a valuable public relations or marketing

toolH M L N/A Other facilities like ours are adopting ISO 1400-based

EMSsH M L N/A Adoption of an ISO 14001-based EMS may reduce our

costsH M L N/A Adoption of an ISO 14001-based EMS may provide a

competitive advantage

H M L N/A Adoption of an ISO 14001-based EMS may lead to regulatory benefits

H M L N/A Adoption of an ISO 14001-based EMS may improve environmental performance

H M L N/A Adoption of an ISO 14001-based EMS may improve facility compliance with environmental regulations

H M L N/A Environmental management professionals are increasingly supporting ISO 14001-based EMSs

H M L N/A Availability of government assistance programs to aid in EMS development makes EMS adoption attractive

H M L N/A Other (please specify: _____________________________)H M L N/A Other (please specify: _____________________________)

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2. Corporate-Facility EMS Relationship

(2.A) If your facility is part of a larger organization, how did that organization affect your facility’s decision to adopt an ISO 14001-based EMS? Choose one:Note: a larger organization is the parent enterprise, if such an enterprise exists, with

which a facility is affiliated.___ N/A This facility is not part of a larger organization (Please proceed to the next

section: 3. Environmental Policy)___ The larger organization requires (or will require) all its facilities to adopt an ISO

14001-based EMS.___ The larger organization encourages all its facilities to adopt an ISO 14001-based

EMS.___ The larger organization is neutral (neither encourages nor discourages) all its

facilities to adopt an ISO 14001-based EMS. ___ The larger organization discourages its facilities to adopt an ISO 14001-based

EMS.

(2.B) Did your larger organization provide any of the following kinds of support to your facility in the adoption of its ISO 14001-based EMS? (Check all that apply)___ The larger organization provided financial support.___ The larger organization provided technical expertise.___ The larger organization provided a template EMS that all facilities would follow.___ Other (Please explain:

________________________________________________)___ Other (Please explain:

________________________________________________)

(2.C) Are the larger organization’s individual facilities communicating about or cooperating on the design and implementation of facility-level ISO 14001-based EMSs? ___ No___ Yes (Please explain: __________________________________________________

______________________________________________________________________________________________________________________________)

3. Environmental Policy

(3.A) What is your facility’s documented environmental policy? (Please attach)

(3.B) Please answer the following questions about your environmental policy:

(3.B.1) What personnel and what organizational levels (e.g., plant manager, environmental manager, health and safety manager, operator, etc.) in your facility were responsible for and involved in its development? If an external consultant was involved, please state so here.

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________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

(3.B.2) Were any persons involved in its development who were not employees of the facility? ___ No (Please proceed to Question 3.C)___ Yes (Please complete EMS Design Table 1a: Interested Parties Involved

with Environmental Policy Development, attached)

(3.B.3) Were these interested parties part of a formal stakeholder group? (A formal stakeholder is an assembly of individuals who are interested in a facility’s environmental activities. The group is organized by the facility and meets periodically to provide input on the facility’s environmental affairs.)___ No___ Yes (Please explain: ____________________________________________

__________________________________________________________________________________________________________________________________________________________________________)

(3.B.4) Approximately how long did it take your facility to develop your environmental policy? _____________________________________________

(3.C) Has your environmental policy been communicated to your employees?___ No___ Yes (Please explain: _________________________________________________

____________________________________________________________________________________________________________________________________________________________________________________________)

(3.D) Has your environmental policy been communicated to the public?___ No___ Yes (Please explain: _________________________________________________

____________________________________________________________________________________________________________________________________________________________________________________________)

(3.E) In your opinion, what differences, if any, would there have been in your answers to Questions (3.B), (3.C), and (3.D) if your facility:

(3.E.1) Did not adopt an ISO 14001-based EMS? ___ No difference___ Some difference (Please explain: __________________________________

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____________________________________________________________________________________________________________________________________________________________________________________)

(3.E.2) Did not participate in a state-sponsored pilot program?___ No difference___ Some difference (Please explain: __________________________________

____________________________________________________________________________________________________________________________________________________________________________________)

4. Identification of Environmental Aspects and Impacts

(4.A) Please list your facility’s environmental aspects in EMS Design Table 2: Aspects and Impacts, attached as determined in your EMS design process. For each aspect, please identify their associated environmental impacts.

(4.B) Please answer the following questions about your environmental aspects and impacts:

(4.B.1) Describe the process that your facility used to identify its environmental aspects and their related impacts. __________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

(4.B.2) Were priorities set among your aspects and impacts?___ No___ Yes (Please explain how these priorities were determined: ______________

____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________)

(4.B.3) What personnel and what organizational levels (e.g., plant manager, environmental manager, health and safety manager, operator, etc.) in your facility were involved in the identification of aspects and impacts? If an external consultant was involved, please state so here.________________________________________________________________________________________________________________________________________________________________________________________________

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________________________________________________________________________________________________________________________________

(4.B.4) Were any persons involved in the identification process who were not employees of the facility? ___ No (Please proceed to Question 4.B.6)___ Yes (Please complete EMS Design Table 1b: Interested Parties Involved

with Aspect and Impact Identification, attached)

(4.B.5) Were these interested parties part of a formal stakeholder group? (A formal stakeholder is a group of interested parties organized by the facility. It meets periodically to provide input on the facility’s environmental affairs.)___ No___ Yes (Please explain: ____________________________________________

____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________)

(4.B.6) Approximately how long did it take your facility to identify its environmental aspects and impacts? _____________________________________________

(4.C) In your opinion, what differences, if any, would there have been in your answers to Questions (4.B.1), (4.B.2), (4.B.3), (4.B.4), and (4.B.5) if your facility:

(4.C.1) Did not adopt an ISO 14001-based EMS?___ No difference___ Some difference (Please explain: __________________________________

____________________________________________________________________________________________________________________________________________________________________________________)

(4.C.2) Did not participate in a state-sponsored pilot program? ___ No difference___ Some difference (Please explain: __________________________________

____________________________________________________________________________________________________________________________________________________________________________________)

5. Determination of Significance of Environmental Aspects and Impacts

(5.A) In EMS Design Table 2: Aspects and Impacts, you indicated which of your environmental impacts were significant to your facility. Please answer the following

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questions about how you determined the significance of your environmental aspects and impacts:

(5.A.1) Describe the process that your facility used to determine the significance of environmental aspects and their impacts. __________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

(5.A.2) What personnel and what organizational levels (e.g., plant manager, environmental manager, health and safety manager, operator, etc.) in your facility were involved in the determination of significant aspects and impacts? If an external consultant was involved, please state so here.________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

(5.A.3) Were any persons involved in the significance determination process who were not employees of the facility? ___ No (Please proceed to Question 5.A.5)___ Yes (Please complete EMS Design Table 1c: Interested Parties Involved in

Determination of Significance of Aspects and Impacts, attached)

(5.A.4) Were these interested parties part of a formal stakeholder group? (A formal stakeholder is a group of interested parties organized by the facility. It meets periodically to provide input on the facility’s environmental affairs.)___ No___ Yes (Please explain: ____________________________________________

___________________________________________________________________________________________________________________________________________________________________________________________________________________________________)

(5.A.5) Approximately how long did it take your facility to determine the significance of its environmental aspects and impacts? _____________________________________________

(5.B) In your opinion, what differences, if any, would there have been in your answers to Questions (5.A.1) to (5.A.4) if your facility:

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(5.B.1) Did not adopt an ISO 14001-based EMS?___ No difference___ Some difference (Please explain: __________________________________

____________________________________________________________________________________________________________________________________________________________________________________)

(5.B.2) Did not participate in a state-sponsored pilot program?___ No difference___ Some difference (Please explain: __________________________________

____________________________________________________________________________________________________________________________________________________________________________________)

6. Setting Objectives and Targets

(6.A) Please list your environmental objectives and targets in EMS Design Table 3: Timetable of Objectives and Targets, attached. Include for each the facility’s timetable for attaining the objective or target.

(6.B) Please answer the following questions about how you determined the significance of your environmental aspects and impacts:

(6.B.1) Please describe how your facility determined its environmental objectives and targets.________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

(6.B.2) Were priorities set among environmental objectives and targets?___ No___ Yes (Please explain how these priorities were determined: ______________

____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________)

(6.B.3) What personnel and what organizational levels (e.g., plant manager,

environmental manager, health and safety manager, operator, etc.) in your facility were involved in the identification of objectives and targets? If an external consultant was involved, please state so here.

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________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

(6.B.4) Were any persons involved in setting objectives and targets who were not employees of the facility? ___ No (Please proceed to Question 6.B.6)___ Yes (Please complete EMS Design Table 1d: Interested Parties Involved in

Setting Objectives and Targets, attached)

(6.B.5) Were these interested parties part of a formal stakeholder group? (A formal stakeholder is a group of interested parties organized by the facility. It meets periodically to provide input on the facility’s environmental affairs.)___ No___ Yes (Please explain: ____________________________________________

___________________________________________________________________________________________________________________________________________________________________________________________________________________________________)

(6.B.6) Approximately how long did it take your facility to set objectives and targets? _____________________________________________

(6.C) Briefly describe the system that the facility will use to measure and track its environmental performance against its objectives and targets (e.g. spreadsheet that is linked with accounting, life-cycle analysis, materials accounting, etc.).____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

(6.D) Of the measures that your facility will use to track its environmental performance, will any of them be made available to the public? ___ No___ Yes (Please explain: _________________________________________________

___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________)

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(6.E) In your opinion, what differences, if any, would there have been in your answers to Questions (6.A), (6.B), (6.C), and (6.D) if your facility:

(6.E.1) Did not adopt an ISO 14001-based EMS?___ No difference___ Some difference (Please explain: __________________________________

____________________________________________________________________________________________________________________________________________________________________________________)

(6.E.2) Did not participate in a state-sponsored pilot program?___ No difference___ Some difference (Please explain: __________________________________

____________________________________________________________________________________________________________________________________________________________________________________)

7. Structure and Responsibility

(7.A) Were persons in your facility given the responsibility by top management to ensure that the EMS is established, implemented, and maintained?___ No___ Yes (Please explain: __________________________________________________

___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________)

(7.B) Is environmental performance incorporated into the incentive structure of employees and managers?___ No___ Yes (Please explain: __________________________________________________

___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________)

8. Training

(8.A) Are programs in place for training employees at all levels about the significant environmental impacts, actual or potential, of their work activities, and about their roles and responsibilities in the EMS?___ No (Please proceed to 8.C)___ Yes (Please explain: __________________________________________________

_____________________________________________________________________________________________________________________________)

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(8.B) Does the facility evaluate the effectiveness of this training?___ No___ Yes (Please explain: __________________________________________________

_____________________________________________________________________________________________________________________________)

(8.C) In your opinion, what differences, if any, would there have been in your answers to Questions (8.A) and (8.B) if your facility:

(8.C.1) Did not adopt an ISO 14001-based EMS? ___ No difference___ Some difference (Please explain: __________________________________

____________________________________________________________________________________________________________________________________________________________________________________)

(8.C.2) Did not participate in a state-sponsored pilot program? ___ No difference___ Some difference (Please explain: __________________________________

____________________________________________________________________________________________________________________________________________________________________________________)

9. External Communications

(9.A) Does the facility have a procedure to receive, document, and respond to relevant communication from external interested parties?___ No___ Yes (Please explain: __________________________________________________

_____________________________________________________________________________________________________________________________)

(9.B) In your opinion, what differences, if any, would there have been in your answer to Question (9.A) if your facility:

(9.B.1) Did not adopt an ISO 14001-based EMS? ___ No difference___ Some difference (Please explain: __________________________________

____________________________________________________________________________________________________________________________________________________________________________________)

(9.B.2) Did not participate in a state-sponsored pilot program? ___ No difference___ Some difference (Please explain: __________________________________

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____________________________________________________________________________________________________________________________________________________________________________________)

10. Monitoring and Measurement of Regulatory Compliance

(10.A) Please describe the processes and/or procedures associated with fulfilling legal environmental requirements that:

(10.A.1) identify potential instances of non-compliance,__________________________________________________________________________________________________________________________________________________________________________________________

(10.A.2) determine the cause(s) of the potential instances of non-compliance, and__________________________________________________________________________________________________________________________________________________________________________________________

(10.A.3) prevent recurrence of the potential instances of non-compliance. __________________________________________________________________________________________________________________________________________________________________________________________

(10.B) Are procedures in place to evaluate the facility’s new or modified activities (e.g., production processes, products lines, services, etc.) to determine their impact on regulatory compliance?___ No ___ Yes (Please explain: ________________________________________________

____________________________________________________________________________________________________________________________________________________________________________________________)

(10.C) In your opinion, what differences, if any, would there have been in your answers to Questions (10.A) and (10.B) if your facility:

(10.C.1) Did not adopt an ISO 14001-based EMS?___ No ___ Yes (Please explain: __________________________________________

__________________________________________________________________________________________________________________________________________________________________)

(10.C.2) Did not participate in a state-sponsored pilot program?__ No difference

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__ Some difference (Please explain: _________________________________________________________________________________________________________________________________________________________________________________________________________________________)

11. Environmental Management System Audits

(11.A) Are audits performed on the facility’s EMS?___ No (Proceed to the next section: 12. Management Review)___ Yes

(11.B) Who is responsible (job title) for performing each EMS audit?_______________________________________________________________________________________________________________________________________________________________________________________________________________

(11.C) How often will these audits be performed?_______________________________________________________________________________________________________________________________________________________________________________________________________________

(11.D) Do any external interested parties have access to the results of these audits?___ No ___ Yes (Please explain how information on the results of these audits will be made

accessible: ___________________________________________________ ____________________________________________________________________________________________________________________________________________________________________________________)

12. Management Review

(12.A) Does top management review the facility’s EMS?___ No (Please proceed to next section, 13: ISO 14001 Certification)___ Yes

(12.A.1) Which managers review the EMS (job title)? __________________________________________________________________________________________________________________________________________

(12.A.2) How frequently top management reviews the EMS? ____________________________________________________________________________________________________________________________________

(12.A.3) How does top management conduct the EMS review? ___________________________________________________________________________________________________________________________________

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__________________________________________________________

(12.B) Is the EMS review process integrated with other periodic management reviews?___ No ___ Yes (Please explain: ________________________________________________

______________________________________________________________________________________________________________________________________________________________________________________)

(12.C) What information does the facility use when carrying out management reviews?____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

13. ISO 14001 Certification

(13.A) Please check the category that most closely describes your facility's auditing and certification plans:___ My facility does not intend to become ISO 14001-certified, and will do internal

audits___ My facility does not intend to become ISO 14001-certified, and will use third-

party audits___ My facility does intend to become ISO 14001-certified, and will use third-party

audits

14. Costs of ISO 14001-based EMS Design

(14.A) What were the costs of developing your EMS? Please document these costs using EMS Design Table 4: Cost of EMS Design, attached.

(14.B) Relative to other steps in your facility’s EMS design process, how costly (including staff time, materials, equipment, consultants, etc.) were each of the following major EMS design steps? Please circle the appropriate letter (H= high relative cost; M= medium relative cost; L= low relative cost; N/A= not applicable).

H M L N/A Formulating and communicating your facility’s environmental policy

H M L N/A Identifying environmental aspects and impacts

H M L N/A Determining significance of environmental aspects and impacts

H M L N/A Setting objectives and targets

H M L N/A Training your employees

H M L N/A Externally communicating your EMS

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H M L N/A Monitoring and measuring regulatory compliance

H M L N/A Auditing the EMS

H M L N/A Top management review of the EMS

H M L N/A Obtaining ISO-14001 certification (if applicable)

(14.C) Does your facility have a certified quality management system (QS or ISO 9000) in place?___ No ___ Yes (Please explain if and how its presence has impacted the costs of designing

your facility’s EMS)______________________________________________________________________________________________________________________________________________________________________________________________________________________________________)

(14.D) In general, were the costs of designing your EMS generally higher or lower than originally expected?___ Higher than we expected*

___ About what we expected*

___ Lower than we expected*

*Please explain: ________________________________________________________ __________________________________________________________________________________________________________________________________________

(14.E) Please describe the benefits, if any, that your facility realized as a result of its EMS design process. ______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

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EMS Design Table 1a: Interested Parties Involved withEnvironmental Policy Development

Interested party classification

How was interested party

identified?

How was the interested party

involved?

Was financial support provided to this interested

party?

How, if at all, were the views of this interested party reflected in

your facility’s actions at this stage of EMS design?

Facility's or parent firm's owners or shareholders1)2)3)4)

Facility's non-management employees (job category)1)2)3)

Business interests1)2)3)

Consultants1)2)

Citizens or Citizen groups1)2)3)

Government1)2)3)

Environmental groups1)2)3)

Unions1)2)

Community Advisory Groups/Boards/Panels

Local Emergency Planning Committee (LEPC)

Other1)2)

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EMS Design Table 1b: Interested Parties Involved with Aspect and Impact Identification

Interested party classification

How was interested party

identified?

How was the interested party

involved?

Was financial support provided to this interested

party?

How, if at all, were the views of this interested party reflected in

your facility’s actions at this stage of EMS design?

Facility's or parent firm's owners or shareholders1)2)3)4)

Facility's non-management employees (job category)1)2)3)

Business interests1)2)3)

Consultants1)2)

Citizens or Citizen groups1)2)3)

Government1)2)3)

Environmental groups1)2)3)

Unions1)2)

Community Advisory Groups/Boards/Panels

Local Emergency Planning Committee (LEPC)

Other1)2)

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EMS Design Table 1c: Interested Parties Involved with Determination of Significance of Aspects and Impacts

Interested party classification

How was interested party

identified?

How was the interested party

involved?

Was financial support provided to this interested

party?

How, if at all, were the views of this interested party reflected in

your facility’s actions at this stage of EMS design?

Facility's or parent firm's owners or shareholders1)2)3)4)

Facility's non-management employees (job category)1)2)3)

Business interests1)2)3)

Consultants1)2)

Citizens or Citizen groups1)2)3)

Government1)2)3)

Environmental groups1)2)3)

Unions1)2)

Community Advisory Groups/Boards/Panels

Local Emergency Planning Committee (LEPC)

Other1)2)

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EMS Design Table 1d: Interested Parties Involved with Setting Objectives and Targets

Interested party classification

How was interested party

identified?

How was the interested party

involved?

Was financial support provided to this interested

party?

How, if at all, were the views of this interested party reflected in

your facility’s actions at this stage of EMS design?

Facility's or parent firm's owners or shareholders1)2)3)4)

Facility's non-management employees (job category)1)2)3)

Business interests1)2)3)

Consultants1)2)

Citizens or Citizen groups1)2)3)

Government1)2)3)

Environmental groups1)2)3)

Unions1)2)

Community Advisory Groups/Boards/Panels

Local Emergency Planning Committee (LEPC)

Other1)2)

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EMS Design Table 2: Aspects and Impacts

Environmental Aspect Signifi-cant

Aspect(Y/N)?*

Why did you make this determination of

significance?

Associated Impacts Signifi-cant

Impact(Y/N)? *

Why did you make this determination of

significance?

Aspect 1-- Impact 1.1--Impact 1.2--Impact 1.3--

Aspect 2-- Impact 2.1--Impact 2.2--Impact 2.3--

Aspect 3-- Impact 3.1--Impact 3.2--Impact 3.3--

Aspect 4-- Impact 4.1--Impact 4.2--Impact 4.3--

Aspect 5-- Impact 5.1--Impact 5.2--Impact 5.3--

Aspect 6-- Impact 6.1--Impact 6.2--Impact 6.3--

Aspect 7-- Impact 7.1--Impact 7.2--Impact 7.3--

Aspect 8-- Impact 8.1--Impact 8.2--Impact 8.3--

* Include the extent to which your facility used information on environmental conditions (if any) in determining significance? (For example, did your local air attainment/non-attainment status affect your significance decisions? See EMS Design Appendix 1 for more information on Environmental Condition Indicators.)

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EMS Design Table 3: Timetable of Objectives and Targets

Objective or Target Timetable

1.

2.

3.

4.

5.

6.

7.

8.

9.

10.

11.

12.

13.

14.

15.

16.

17.

18.

19.

20.

21.

22.

23.

24.

25.

26.

27.

28.

29.

30.

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EMS Design Table 4: Cost of EMS Design

Cost Category Total Cost

Staff time:

Materials:

Equipment:

Consultants:

Other cost: (Please specify_____________________________)

Other cost: (Please specify_____________________________)

Other cost: (Please specify_____________________________)

Other cost: (Please specify_____________________________)

Other cost: (Please specify_____________________________)

Other cost: (Please specify_____________________________)

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EMS DESIGN APPENDIX 1

Environmental Condition Indicators

You may choose to use Environmental Condition Indicators as you design and implement your EMS. Environmental Condition Indicators measure the condition of the environment that surrounds your facility. These measures may be local, regional, or global. You may choose to use one or more of the following measures, depending on the extent to which you impact them.

Possible Measures:

Ambient airshed air quality (for example, pollutant levels, odor, visibility, attainment level)

Ambient watershed water quality - groundwater or surface (for example, contaminant levels, dissolved oxygen, temperature, turbidity, nutrients)

Land quality surrounding the facility (for example, contaminant levels, erosion) Flora (vegetation quality, population, endangered species, diversity) Fauna (contaminant levels, population, endangered species, diversity) Human health and welfare (measures of health of the population surrounding the

facility.) Quality of life measures

For each measure you select, please describe the source or method of collection your facility will use for this data.

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EMS DESIGN APPENDIX 2: GLOSSARY OF TERMS

Confidential Business Information (CBI): Data which may be withheld if its disclosure would be likely to harm the competitive position of the company that submitted the information. Confidential business information may include information on a company's marketing plans, profits, or costs. Please consult applicable state CBI laws for state-specific definitions and other relevant information.

Customers: The external end-users of a facility’s product or services.

Direct Costs: The immediate expenses incurred by a product, process, or management change. Direct costs include increases in staff time, materials expenditures, energy expenditures, equipment purchases, consultant purchases, consultant fees, etc.

Environmental Aspect: Element of an organization’s activities, products or services that can interact with the environment. A significant environmental aspect is an environmental aspect that has or can have a significant environmental impact.

Environmental Impact: Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organization’s activities, products or services.

Environmental Condition Indicator: Measures the condition of the environment surrounding a facility using local, regional, national or global measures.

Environmental Performance Indicator (EPI): A value or gauge that is actually used by a facility as an evaluative tool in determining a facility’s environmental accomplishment or status. These values or gauges may include measurable emissions or discharge data, compliance measures, number of spills or accidental releases, materials use, waste generation, energy use, time or money spent, number of exceedences of a regulatory limit, etc. Values or measure that are not actually used to evaluate a facility’s environmental accomplishment or status--for example, items that are measured to fulfill environmental regulatory requirements, but are not used as an internal environmental evaluative tool--are not environmental performance indicators. Formal Enforcement Action: A notice of violation (NOV), administrative order, civil action seeking penalties or injunctive relief, or referral for a criminal prosecution for violation of an environmental requirement.

Formal Pollution Prevention Plan: A set of waste reduction protocols that are adopted throughout a facility as a standard operating procedure. The plan may include specific goals, objectives, or targets and measures of success.

Formal Stakeholder Group: An assembly of individuals that are interested in afacility's environmental activities. The group is organized by the facility andmeets periodically to provide input on the facility's environmental affairs.

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Indirect Costs: The secondary benefits incurred by a product, process, or management change. Indirect costs include decreases in market share, stock prices, bond ratings, sales, etc. They also include increases in insurance rates, cost of capital, environmental liability, liability associated with employee health and safety, etc.

Inside Interested Parties: Any individual or group within a facility who is not responsible for the design of its EMS and may be concerned with or affected by the facility’s environmental performance.

Larger Organization: The parent enterprise, if such an enterprise exists, with which a facility is affiliated.

Materials Accounting: The specific set of processes that raw materials, parts, and subassemblies follow as they move through the facility and the manner in which they minimize waste production.

Multi-State Working Group (MSWG): A voluntary group of participants from state, federal, nongovernmental, business, and higher education organizations who are interested in determining the effectiveness of Environmental Management Systems (EMSs). The group’s focus is in six areas: environmental performance, environmental conditions, environmental compliance, pollution prevention, costs and benefits, interested party involvement, and how these areas are affected by environmental management systems. The MSWG has published a guidance document entitled, Environmental Management Systems Voluntary Project Evaluation Guidance.

Non-compliance: Non-conformity in fulfilling legal requirements.

Non-normalized Value: An unstandardized output value which is often a total value per time period. For example, wastewater discharge might be measured in total gallons per day (or per month).

Normalization Factor: The output measure (e.g., “pounds of product”) for an Environmental Performance Indicator. It is sometimes called a “Production Activity Index.”

Normalized Value: A standardized output value which allows somewhat unrelated items to be compared. It corrects output values for production fluctuations so that changes in output can be viewed separately from changes in production due to business cycles and other factors. Normalized values are calculated by dividing non-normalized values by a normalization factor (such as total facility output, pounds of waste, total sales, etc.) For example, wastewater discharge might be measured in total gallons per day per pound.

Outside Interested Parties: Any individual or group not associated with a facility but concerned with or affected by the facility’s environmental performance (e.g., local non-governmental organizations or neighborhood associations).

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Pollution Prevention: Pollution prevention is synonymous with source reduction; i.e., reducing waste at its source before it is even generated, and is fundamentally different from pollution control. Pollution prevention focuses on industrial and organizational processes. Within these processes, waste production is prevented or reduced rather than curbed after its production. Pollution prevention does not include activities such as recycling/reuse of pollutants or waste (except for in-process recycling), waste treatment, and disposal of waste or its release into the environment because, in each of these examples, waste is first produced and later controlled. Pollution prevention does include materials substitution, process changes, and other activities that reduce waste before it is even generated.

Potential Non-compliance: Any situation in which a non-compliance would occur without action by the facility.

Regulatory Requirements: Each state or federal emission or discharge limit made applicable to a facility by its permits.

Regulatory Status: A facility’s categorization under various environmental regulatory programs, such as large or small quantity waste generators under RCRA or major or minor sources under the Clean Air Act.

Significant Change: The definition of significant change may vary from facility to facility, but in general reflects what a particular facility regards as a significant change in its environmental performance.

Suppliers: Vendors whose products serve as the inputs in a facility’s production cycle.

Violation: Non-compliance discovered by environmental agency personnel or reported to agency personnel which results in a formal enforcement action against the facility.

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