EMS Action Plan: Goal 2

EPA’s Position on EMS

• EMS Position Statement

• Agency EMS Policies
• Executive Order 13148
• Federal Sector EMS Resources

Promote Excellence in the Practice of EMS Inside and Outside the Agency

Element 5: Establish a Core EMS Coordination and Support Team Within EPA

Within EPA, most of the actual work on EMSs is conducted within national programs or
EPA's regional offices. The Office of Policy, Economics, and Innovation helps to
coordinate and plan this work, and provides leadership in setting EMS policy. EPA also
has internal policy groups, representing senior management and staff, to address issues
related to EMS use.

Actions:

EPA will establish an EMS practitioners forum to allow staff with EMS experience to
discuss and share experiences from their work. In addition, EPA will establish an EMS
support network so that EPA staff interested in EMSs can receive the advice and support
of their peers and avoid having to reinvent the wheel.

• Establish a practitioners forum for sharing EMS information among staff; and
• Create a support network to assist with developing new programs or policies
involving EMS use.

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Element 6: Support EMS Implementation at EPA and other Federal Agency

Facilities

EPA will model best practices for EMSs by implementing them at appropriate Agency
facilities, such as EPA's research laboratories and regional offices. EPA will emphasize
practices that improve regulatory compliance, pollution prevention, public/stakeholder
communication, and, where feasible, other indicators of environmental stewardship, such
as water or energy conservation.

EPA will also continue conducting Environmental Management Reviews (EMRs) with
federal partners at selected federal facilities. EMRs look at how various EMSs function
and are conducted at the invitation of a facility. They are meant to assure the effectiveness
of environmental programs--they are neither comprehensive audits nor compliance
inspections.

In addition, EPA will work closely with other federal partners that are taking a leadership
role on EMS issues or are interested in learning more about them. EPA will provide a
platform for inter-agency coordination and learning, and prepare a review of lessons
learned to assist federal agencies on future EMS adoption efforts. EPA will support
implementation of Executive Orders related to EMS use. These include Executive Order
13148, Greening the Government through Leadership in Environmental Management
, which combines requirements in several previous Executive Orders.

Actions:

• Issued Implementation Guide for the Code of Environmental Management

Principles (CEMP) for Federal Agencies and an Environmental Management
Systems Primer for Federal Agencies;
• In April 2001, reissued the Environmental Management Review Policy and
Guidance for Federal Facilities" to be consistent with EPA's Audit Policy;
• Conducted over 65 EMRs at Federal facilities through FY ‘00;
• Issued the EMR National Report: Lessons Learned in Conducting EMRs at
Federal Facilities;
• Developed an EMS awareness and auditing training program for EPA personnel
and began offering training classes;
• Developed 5 mini-workshops and delivered an 8-hour workshop at the National
Defense Industrial Association's 27th Environmental Symposium and Exhibition
in Austin, TX;
• Continue to offer the 8-hour EMS Workshop for Federal Facilities to the federal
community to assist with self-assessment and EMS implementation;
• Implement an EMS at EPA's Region 3 Environmental Sciences Center (Region 3
+ Office of Prevention, Pesticides and Toxic Substances) at Ft. Meade, Maryland;
• Develop an Agency Environmental Policy to responsibly manage the
environmental impacts associated with the activities, products, and services
related to Agency operations and facilities;
• Identify sites and begin implementing EMSs at 12 additional EPA facilities; and
• Continue to facilitate inter-agency working groups to focus on Executive Order
13148 goals, including EMS objectives and requirements.

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Element 7: Conduct Research and Evaluation of EPA's EMS Programs

While EPA recognizes the potential of EMSs to improve environmental performance,

compliance, and pollution prevention, and is committed to promoting their use, EPA
needs to learn more in order to make the best use of EMSs in its programs and policies.
In particular, EPA needs to study which EMSs are most effective, the results being
achieved, and the factors contributing to their success. Then, EPA will be in a better
position to determine whether changes related to EMSs are appropriate. To this end, EPA
will maintain and, in some cases, expand EMS research and evaluation activities. EPA
will take a targeted approach to ensure that its limited resources are invested in those
investigations with the greatest potential for learning.

Working in partnership with the Multi-State Working Group on EMSs , the

University of North Carolina (UNC), and the Environmental Law Institute, EPA will
continue support for the National Institute of Standards and Technology (NIST)
Manufacturing Extension Partnership . This database, which is being
established at UNC, will provide information on a variety of EMS performance measures
at 80 - 100 facilities across the nation over time. As the cornerstone of EPA's EMS
research efforts, EPA will use this database to study the effects of EMS implementation
on environmental and economic performance and to evaluate potential public policy
applications of EMSs in a variety of settings. In addition, EPA will support research by
UNC into the costs and benefits of EMS implementation, the role of outside stakeholders
in EMS design, and the impact that participation in federal or state pilot projects may
have on EMS design.

EPA worked with the National Academy of Public Administration to analyze ISO 14001
registration practices in the United States in order to increase the understanding of this
important process by many stakeholders. This research helped determine how registration
occurs and how this process could be used by regulators to build greater support for EMS
adoption. In addition, EPA will participate in national and international meetings or
conferences focusing on EMS research. EPA will also develop a list of EMS topics to
help set research priorities.

To best promote EMSs that achieve strong results and to determine how they might be
used to support public policy, EPA needs information about how well various systems are
working. To this end, EPA will make evaluations a priority in its own EMS activities, and
EPA will recommend them for those it is supporting.

Actions:

• Establishing the National Database on Environmental Management Systems

(NDEMS), including public access capabilities;
• Collecting and entering baseline data;
• Collect and enter EMS performance data;
• Work with the National Academy of Public Administration to complete study on
14001 EMS registration practices in the U.S.;
• Hold two workshops on government implementation of EMSs, and issue report
summarizing findings;
• Complete five initial research studies using baseline and EMS design data;
 • Conduct ongoing research as environmental and economic performance data
becomes available; and
• Issue EMS evaluation report based on NDEMS data.

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Element 8: Establish and Maintain an Active EMS Outreach and Engagement

Program

EPA's involvement in external EMS policy discussions has been marked by a conscious
and extensive effort to interact with key stakeholders domestically and internationally.
EPA has and will continue to sponsor and support outreach events that foster a dialogue
on EMSs and their potential public policy applications. EPA is also committed to
continuing leadership to advance, review, and revise international voluntary EMS
standards, specifically through participation in the U.S. Technical Advisory Group (U.S.
TAG). The U.S. TAG is the U.S. consensus body on environmental standards on behalf of
the American National Standards Institute and developed by ISO Technical Committee
207, which is responsible for the ISO 14000 series of standards3.

Domestic Outreach Actions:

• EPA will coordinate its participation in the U.S. Technical Advisory Group (U.S.
TAG) through the EPA Voluntary Standards Network;
• Provided funding to U.S. non-governmental organizations (NGOs) to enable them
to participate in the U.S. TAG and to establish an NGO information-sharing
network;
• Sponsored a series of conferences in 1996 - 1997 to discuss the newly adopted
ISO 14001 standard;
• Held a forum in EPA Region 9 in 1998 to explore potential financial benefits of
EMSs, and their potential use as a tool for promoting sustainable development;
• Developed recommendations for U.S. TAG to promote strengthening of ISO
14001 in areas of compliance, pollution prevention, and external communication;
• Requested that the U.S. TAG clarify the role of compliance for applications of
ISO 14001 in the U.S.; and
• Cosponsored a workshop on state and federal EMS pilot projects and an EMS
research summit with the Multi-State Working Group on EMSs.

EPA will sponsor events to promote effective EMSs, including events that target specific
geographic regions or industry sectors with an interest in EMS development. Also, EPA
will continue to support and encourage NGOs and other key stakeholders participation in
EMS dialogues and revision processes related to ISO 14001.
 • Continue to sponsor and participate in national workshops, conferences and other
outreach events to discuss the benefits of EMSs and to provide a constructive
forum for discussing relevant public policy issues;
• Promote EPA positions on ISO 14001 in U.S. and international standard-setting
forums;
• Increase EPA's understanding of national and international EMS
registration/accreditation systems and seek to influence changes to those systems
that are advantageous and consistent with EPA guidelines related to voluntary
standards use;
• Support and encourage NGO and other stakeholder participation in dialogues and
other venues related to EMSs (such as activities of the ISO Technical Committee
207, the U.S. TAG, the Multi-State Working Group on EMSs, and development of
EPA programs and policies); and
• Promote the use of the EMS elements described in Improving Environmental
Performance and Compliance: Ten Elements of Effective Environmental
Management Systems, issued by the Enforcement Cooperation Program of the
trilateral Commission for Environmental Cooperation in June, 2000.

International Outreach:

EPA's effectiveness in promoting beneficial EMS applications in the U.S. can be

enhanced significantly through international cooperation. Along with EPA's involvement
in the ISO 14000 standards development process, various EPA offices are engaged in
international initiatives involving EMS development and evaluation. EPA will use its
international engagement with various multilateral organizations (e.g. Organization for
Economic Cooperative Development and United Nations Environment Programme),
bilateral environmental cooperation programs, and partnerships with foreign assistance
agencies (e.g., USAID) to:

• Evaluate innovative EMS applications and policies being developed and tested
abroad;
• Collaborate on development and assessment of tools and other resources to
support EMS implementation, and improve mechanisms for exchanging and
accessing these materials;
• Conduct joint pilot projects that demonstrate results of EMS applications;
• Encourage other international partners to promote and support NGO involvement
in ISO 14001 implementation and in the development of any public policies based
on ISO 14001;
• Encourage other international partners to engage in research and evaluation
efforts, and promote research and data protocols that allow comparability of
results; and
• Share internationally EPA perspectives on elements of an effective EMS.

EPA will also continue tracking international developments on EMSs and their
ramifications in light of ongoing dialogues related to trade and the environment. EPA's
Trade and Environment Standing Committee is responsible for developing policies
related to trade and the environment. This EMS Action Plan has been, and will continue
to be, coordinated through this group to ensure consistency with international trade
obligations.

International Outreach - Actions:

• The Seven Principles of Environmental Stewardship for the U.S./Mexico Business

and Trade Community - In 1999, EPA, Mexico's Environment Secretariat, the
U.S./Mexico Chamber of Commerce, and the Border Environment Cooperation
Commission, announced a binational public/private strategic alliance to promote
environmental stewardship among private sector organizations in the U.S. and
Mexico. The Seven Principles of Environmental Stewardship, as they are known,
encourage companies to adopt EMSs (focused on compliance, pollution
prevention, energy efficiency, and improved environment performance, and which
are developed through open and inclusive processes) at all operational locations
throughout the U.S. and Mexico.
• North American Commission on Environmental Cooperation (CEC) – In June,
2000, the Enforcement Cooperation Program of the CEC issued a guidance
document entitled, Improving Environmental Performance and Compliance: 10
Elements of Effective Environmental Management Systems. The document
represents an agreement by the three CEC member countries – Canada, Mexico
and the United States – on how EMSs can benefit the public interest by
contributing to compliance assurance and improved environmental performance.
The key elements outlined in the document are compatible with many EMS
models based on the Plan-Do-Check-Act framework that are currently in use. The
document developed, in part, out of a public forum that CEC hosted in 1999 in
Washington D.C. to bring together representatives from industry, government, and
NGOs to explore key EMS elements needed to promote compliance. EPA's Office
of Enforcement and Compliance Assurance (OECA) is preparing a user-friendly
guide to implementing the CEC 10 Elements, aimed specifically at corporate
environmental managers. In addition, OECA is developing a pilot program to
promote the CEC 10 elements and the guide. The pilot program will include
offering technical assistance to pilot program participants, and collecting data on
how implementation impacts performance.
• Organization for Economic Cooperation and Development (OECD) - EPA is
participating with other OECD members in an EMS-related project through
Territorial Development Services group, which focuses on urban redesign and
renewal. The project will engage NGOs and other stakeholders at local levels in
developing and applying technical and economic tools on a city-wide basis to
foster waste minimization, pollution prevention and right-to-know types of public
reporting. EMSs based on ISO 14001 incorporating other performance elements
important to EPA are one of the tools being used.
• Screenprinting and Graphic Imaging Association International (SGIA) - Having
developed an EMS for their industry through EPA's DfE program, the SGIA is
conducting EMS training workshops in Canada in conjunction with small
business centers.
EPA will continue to advance projects described above through engagements with the
CEC, binational efforts with Mexico, and with OECD, as well as track U.S. and
international EMS developments that have trade and environmental implications. Other
ways EPA will expand its international engagement on EMS issues include:

• Improving EPA Access to Information on EMS Innovations Abroad and

Promoting Improved International Information Networking - EPA will examine
ways to improve access to new information about EMS innovations, tools, and
research. EPA will focus on having EMSs featured more prominently in existing
regional and international information exchange networks. EPA will also work to
more effectively channel these information resources to interested EPA and U.S.
partners, such as through linkages to the proposed EMS Resource Center.
• Organizing International Workshop on Ways to Promote EMSs through Public
Policy - EPA will help organize at least one international workshop on promoting
EMSs through public policies and regulations. EPA will likely focus organization
in Asia, where ISO 14001 is being marketed aggressively and fledgling regulatory
agencies and national governments are exploring alternative regulatory models.
• Binational Efforts with Mexico - EPA will work with Mexican authorities, the
U.S./Mexico Chamber of Commerce, and the BECC to expand public and private
sector support for the Seven Principles of Environmental Stewardship; conduct
outreach to companies operating in the U. S. and Mexico to encourage industry
implementation on a corporate-wide basis; and develop an implementation
strategy, which may include offering private sector recognition for outstanding
performers and training and technical capacity-building efforts.