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Re: EMS question



Kenny,  You are right about integrating the EMS into the business system.
No agency can help you do that.  However, I have been involved in several
Multi-State Working Group Projects where companies are voluntarily working
with the states on EMS for benefits programs.  In every case where process
mapping was used (after the company received ISO 14001 Certification) we
found many more ASPECTS than the "walk-around" consultant found and some of
them turned out to be SIGNIFICANT ASPECTS!  Perhaps the Agency or a
third-party using a proven tool like process mapping could actually help.
As you may know, EMAS EMS require that the company report on their
environmental management progress.  Unfortunately, ISO does not require
this reporting.  Maybe an outside party (even an Agency participating in
the MSWG - I believe there are more than 35 states doing this) could help
improve the credibility of this report.  I do not know of any companies
that have done this.

There is the whole area of Supplemental Environmental Projects (SEP's) or
plea bargains for environmental compliance excursions.  They USED TO allow
the company to propose an EMS or Audit program to satisfy the SEP.  I think
that provision was stricken during the last revision of the SEP guidance by
EPA.  Maybe someone from EPA could comment on that and provide a URL on
their web site.

Not withstanding these comments, the statement in Biocycle is curious indeed.

Bob Pojasek

At 03:13 PM 6/4/99 -0600, you wrote:
>I wanted to pose this question in hopes of understanding the thought
>process behind this statement.  I was reading the latest edition of
>Biocycle today.  Page 30 features an article entitled, "How to
>Successfully Manage a Compost Facility."  The articles make the
>following statement concerning Environmental Management Systems:
>
>"It is often meaningful and credible if an EMS is implemented at the
>request or suggestion of the regulating agency.  If a facility is willing to
>proceed with EMS development, the permitting or regulating agency can
>lend support and value to the process by sharing in any public
>disclosure.  The agency can and should then protect its reputation by
>participating in the review and approval of the final EMS."
>
>My question begins with why an organization would value its EMS as
>credible only if its initiation was a direct result of a regulatory agency's
>request.  It seems to me that an EMS is a much better business system
>for management of a company's environmental impacts.  However, its
>development is independent of the regulatory community.  Am I way off
>base?
>
>Thanks!
>
>Kenny
>Kenny Steward
>Pollution Prevention Group
>Pantex Plant
>ksteward@pantex.com
> 
Bob

Dr. Robert B. Pojasek 
Pojasek & Associates 
P.O. Box 1333 
E. Arlington, MA 02474-0071
(781) 641-2422 
(617) 788-0288 (FAX)

http://www.PollutionPrevention.com
rpojasek@PollutionPrevention.com