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Re: EMS Advisory Tool - Guidance for Developing a P2-focused EMS

Dear Mr Kiefer:
Thanks for your interest in this.  I posted the draft of the EMS P2 advisory
tool with no specific deadline for comments, and hope that people like you
would be interested in it!  Please do have your group review and comment on
it.  I expect it will eventually be incorporated into the Topic Hub on EMS
for Small Business (or anyone actually), now on line at


I contributed a lot of the research on this, and Rick Yoder at U Nebraska
and co. did the great presentation and organization.

Below are the substantive comments that I have received back so far, all
from individuals (thanks guys).  I am still hoping for more input, hint hint
you P2techies.  Actually why not create a deadline, since P2RIC needs to get
it up on line sometime.  But Christmas is upon us....  How about last call
for comments by January 30?  Any other groups want to make an "official"
contribution?  The original post is attached below.

Burt Hamner

there are several of the 10 elements that you could incorporate the supply
chain into at some level.  e.g., evaluation/assessments, request them to do
some DfE, help them
establish goals/objectives, offer education/training/assistance, ask
suppliers for participation in meeting your env'l goals/targets, ...
We, at Sandia Labs in Albuquerque, are using New Mexico's Green Zia program
to aid in the development of an environmental management system.  There is
one aspect of the program I have found to be particularly effective in my
facilities sessions.  That is the word "how."  Often, people THINK they have
a good EMS in place but when asked to specifically state how they do
something, the answers start to get vague.  For instance, your first
statement under Environmental Policy could read:  "How does your
organization involve all staff at all levels to create practical solution
for process and environmental improvement?"  We write out these questions in
a matrix and follow them with some blank spaces for the participating
organization to fill in.  The blanks are titled:  "What we do now" and
"Actions--When and Who".  This way, we create a working document for
implementation in our meetings.
I would like to see more information on actual implementation.  What tools
are used, what are the barriers, etc., etc.
Ensure materials are tracked.  Develop measures of waste, use/waste
efficiency, use/product efficiency.
Ensure options analysis is complete and up-to-date and continuous.
Ensure expenses are allocated to the source and that options analysis is
done on the basis of full cost accounting.
Ensure performance rewards are tied to these concrete measurements.
Ensure creative suggestions are solicited and rewarded at all levels.

----- Original Message -----
From: "Colin Kiefer" <Colin_Kiefer@mail.dnr.state.ga.us>
To: <bhamner@cleanerproduction.com>
Cc: "Bob Donaghue" <Bob_Donaghue@mail.dnr.state.ga.us>; "Judy Adler"
Sent: Friday, December 14, 2001 11:50 AM
Subject: EMS Advisory Tool - Guidance for Developing a P2-focused EMS

Mr. Hamner,

Our organization, the Georgia Pollution Prevention Assistance Division, is
in the process of developing various tools and strategies to assist
organizations in Georgia (manufacturing, commercial businesses, educational
institutions, government agencies, etc.) develop P2-oriented environmental
management systems.  We currently have a large EMS project underway with the
Georgia Department of Corrections and are also planning to offer a
peer-focused EMS mentoring workshop for metal finishers in Georgia early
next year.  There are several other interesting potential EMS projects that
may be developed in 2002 as well.

One of our goals as the state source for pollution prevention and resource
conservation is to develop guidance material based upon the very issue you
brought up in a recent email,  "How Can an EMS be Designed to Promote
Pollution Prevention?".   We would be very interested in reviewing and
perhaps providing comments or additions to the draft EMS advisory tool.   Is
there a time deadline in which you would like comments returned by?

Thank you,

M. Colin Kiefer
Pollution Prevention Engineer
Metal Finishing Initiative Project Manager
Pollution Prevention Assistance Division
7 Martin Luther King Jr. Drive Suite 450
Atlanta, GA 30334-9004
404 651 5128


Hi all.  Earlier this year I created a webpage on EMS resources on the
Internet on behalf of Univ of Nebraska and P2RX.  It is still online tho not
recently updated at http://www.cleanerproduction.com/Ecolink/emspage.htm.
Since then we have been thinking a lot about how to make sure an EMS
promotes Pollution Prevention.  So I have prepared a table of P2 actions for
each of the 10 standard elements of an EMS as spec'd in the somewhat
authoritative report, Improving Environmental Performance and Compliance: 10
Elements of Effective Environmental Management Systems
The draft is included below.  If you are interested in EMS and P2, I hope
you will review this list and offer your own suggestions or comments how to
make it more effective and realistic.  If there is enough input (I will
track and acknowledge contributions) then perhaps some group like the
National Pollution Prevention Roundtable might adopt it as an advisory
document.  You can type in your additions to the list below and reply direct
to me at bhamner@cleanerproduction.com (please don't send to the listserv, I
will compile all suggestions and send a clean update).  Please make your
additions in CAPS or some other different font so they are obvious.  Thanks
for your help, now you can skip that boring meeting and think about
something useful.

send comments to Burton Hamner, bhamner@cleanerproduction.com

How Can an EMS Be Designed to Promote Pollution Prevention?

An Environmental Management System (EMS) is a system to improve
environmental performance in an organization.  This can be achieved by
compliance and end-of-pipe controls, Pollution Prevention (P2) focused on
process and product improvement, or a combination of these.  An EMS does not
promote P2 in itself; it must be specifically designed to encourage and
promote P2.

The basic principles of an EMS are described in the publication, Improving
Environmental Performance and Compliance: 10 Elements of Effective
Environmental Management Systems (published by the Commission for
Environmental Cooperation of the North American Agreement on Environmental

We have identified P2 strategies appropriate for each of these elements.
The table below identifies some of them.  We are interested in feedback and
suggestions how to make this more effective and authoritative.

1. Environmental Policy
o Involve all staff at all levels in practical solutions for process and
environmental improvement
o Constantly improve resource efficiency and EMS performance
o Account for all the costs of waste and pollution and assign them to their
o Design products that minimize environmental impacts throughout their life
o Purchase environmentally preferable products and services when practical,
especially less-toxic and recyclable materials

2. Environmental Requirements and Voluntary Undertakings
o Link all identified environmental aspects to the internal sources or
activities that affect them.
o Forecast environmental regulations and other external requirements and
brainstorm P2 solutions that can mitigate or avoid them.
o Identify process and product improvement requirements that will be
necessary for competitiveness and develop environmental performance goals
for them.
o Identify regulatory and other programs that encourage pollution prevention
and learn how to cooperate with them for business and environmental
o Ensure all plans for compliance support also include components for
pollution prevention related to compliance.

3. Objectives and Targets
o Establish quantifiable and readily-measured goals for resource efficiency,
toxics reduction and waste reduction at the process level.  Have process
workers design indicators that they can measure and manage themselves in
real time.
o Establish objectives and targets for improving the management accounting
process for assigning all compliance and environmental costs to responsible
o Develop an index for the environmental impact of products and services and
establish goals for improving the index performance.
o Create knowledge improvement targets to ensure that effective P2 solutions
from around the world are not overlooked.

4. Structure, Responsibilities and Resources
o Make all process supervisors and department managers responsible for the
environmental performance of their units.  Minimize the number of dedicated
environmental staff.
o Use full-cost accounting to link P2 performance to the budget and to
employee compensation rules.
o Include P2 performance in job descriptions and employee evaluations.
o If feasible, rotate staff between compliance and production
o Give highest decision-making priority to projects with potentially
signficant P2 benefits.

5. Operational Control
o Have activity workers produce simple process diagrams that are readily
available and have basic statistics on wastes and emissions at every step.
o Provide simple procedures for measuring and reporting on process or
product environmental impact that give the employees feedback in real time
(these might include process controls such as water submeters, run charts on
waste generation or water use, etc.)
o Establish a procedure to ensure that the P2 Hierarchy is followed
consistently in all decisions regarding environmental performance.
o When documented procedures for activities are required because their
absence could cause significant environmental impacts, establish additional
procedures to ensure that these activities are given highest priority for P2
o Have a procedure for regularly reporting on P2 progress to senior

6. Corrective and Preventive Action and Emergency Procedures
o Apply the P2 Hierarchy in all corrective and preventive actions.
o Use a hazard analysis to identify potential emergency situations and make
the related activities a priority for P2.

7. Training, Awareness and Competence
o Provide modules on P2 in all existing training.
o For staff with significant environmental aspects to manage, ensure that
required EMS training includes detailed P2 methods and solutions.
o Besides basic training in P2 concepts, ensure all staff have basic
training in specific P2 resources and solutions applicable to their
functions (such as accounting, marketing, design, etc.).
o Give key staff training in how to use the Internet to tap into the local
and global network of practical P2 solutions.
o Use case study data in training to show the real business benefits of P2.

8. Organizational Decision-making and Planning
o Use life-cycle analysis to identify environmental threats and
opportunities up and down the product or service chain that could affect
business performance, from natural resource harvesters to product disposers.
o Develop proactive strategies to minimize environmental risks in the
product or service chain.
o Ensure that all senior managers have specific P2 goals to meet.
Integrate P2 strategies into planning for business-driven process and
product changes.
o Empower and encourage work teams to pro-actively make P2 improvements that
do not need signficant capital or other resources.
o Give priority in decision-making to proposals that could significantly
improve environmental performance.

9. Document Control
o Ensure that data on process environmental performance, fully-loaded
materials costs (including waste management costs), and waste fate is made
readily available and understandable to relevant staff.
o Use electronic documentation to minimize paper use and improve records
o Document all P2 suggestions, implemented or not, in a standard form and
collate them as a reference tool for staff.  Ensure the documents are
reviewed and updated regularly.

10. Continuous Evaluation and Improvement
o Ensure that environmental evaluation is directly linked to evaluation of
responsible products and processes.
o Encourage self-evaluation and improvement processes among worker teams.
o Use performance audits as P2 opportunity assessments.
o In P2 assessments, use cross-discipline teams including representatives of
all line departments and support departments.
o Establish a solid process for getting P2 improvement ideas from outside
the organization, including training, networking, use of Internet, etc.
o Establish benchmarks for P2 performance with leading competitors and/or
others and use these to evaluate and improve performance.

If you have any suggestions, comments or ideas how to improve these
recommendations for promoting P2 in an EMS, please contact Burt Hamner at
bhamner@cleanerproduction.com.  Contributions will be acknowledged in the
final.  The revised "living" document will be posted at
CleanerProduction.Com for all to use.