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EPA Regions 9 & 10 and The Federal Network for Sustainability 2005
4.2 Policy
Top management shall define the organizations environmental policy and ensure that it:
a) is appropriate to the nature, scale and environmental impacts of its activities, products or services; b) includes a commitment to continual improvement and prevention of pollution;
4.2 Policy
c) includes a commitment to comply their relevant environmental legislation and regulations, and with other requirements to which the organization subscribes; d) provides the framework for setting and reviewing environmental objectives and targets; e) is documented, implemented and maintained and communicated to all employees; f) is available to the public.
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Planning
Identify Activities, Products and Services Identify Environmental Aspects and Impacts
4.3 Planning
Establish, Maintain, and Document:
4.3.1 - Procedure to identify Environmental Aspects.
a) Activities products and services that it can control and those that it can influence, Activities for Feds include Mission: what facility/Agency is designed to do, Activities that support the mission, Actions that are both regulated and not regulated.
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4.3 Planning
Establish, Maintain, and Document:
b) Those which have or can have significant impacts on the environment. Determined by you.
What is important in your situation Likelihood, severity, frequency, duration, boundaries, stakeholder concerns, Reflects normal, unique, emergency conditions, and environmental impact
4.3 Planning
Establish, Maintain, and Document: 4.3.2 - Procedure to identify legal and other requirements. a) Identify and have access to all legal requirements that apply to your facilitys aspects use audit guides or protocols, b) Identify other requirements to which you subscribe e.g., Executive Orders, agency/bureau policies or voluntary practices.
4.3 Planning
Establish, Maintain, and Document: 4.3.3 - Environmental objectives and targets. a) Considering: legal and other requirements, significant aspects, financial and technical limitations, interested parties input, policy commitment and commitment to pollution prevention, b) Results will guide how you measure progress.
4.3 Planning
4.3.3 - Program for achieving objectives and targets, a) including responsible individuals (assign responsibility - function and level), and b) time frames (what will be done, when, and how is it measured)
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Document Control Training, Awareness and Competence Structure and Responsibility Operational Control
Communication
Emergency Preparedness and Response
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b) c) d) e)
Address accidents and emergencies, Prevent, respond to and mitigate environmental impacts, Review and revise procedures after emergency or accident, Test where appropriate.
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4.5.2 Establish and maintain a procedure to periodically assess compliance with environmental regulations and other requirements
4.5.3 Establish and maintain procedures to address Non-Conformance and Corrective and Preventive Action, defining responsibility and authority to address non-conformance a) Mitigate impacts, b) Identify cause, c) Develop corrective action and implement it, d) Modify procedures if necessary to prevent recurrence.
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Management Review
Take account of: audit findings progress records on objectives changes to facilities changes in activities, products or services changes in technology concerns of interested parties other relevant information
To Assess the suitability, adequacy, and effectiveness of the EMS
In order to determine the need for change and improvement to: the environmental policy the objectives and targets other elements of the EMS
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An Effective EMS
1. Meets the requirements (conformance with the shalls) 2. Consistency with the various elements interrelated (i.e., Significant aspects reflected in emergency planning, etc.) 3. Mechanisms are in place for continual improvement. To improve the EMS and organizational performance supported by management commitment and support.
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Remember
The EMS and related measurement tools are just that, tools. Alone, they will not guarantee success. The organization must use the tools, not just have them.
An effective EMS is alive; constantly measuring performance, making adjustments, and looking for opportunities for continual improvement, Accountability is critical.
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An EMS...
Is a management system. Is more than compliance - includes safety, energy, water etc. and non-regulated impacts. Supports mission! Takes time - it is a process, not an event. Requires the environmental people to get out of their box. EMS requires commitment - its not a part-time job.
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