Implementation Strategy

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Environmental Management System
ImplementationThe Draft Navy EMS Implementation
Guide
25 July 2002 Workshop
2
Topics
What is EMS? Tami McVey, CNO N451G Plan/Do/Check/
Act Andrew Kissell, NAVFAC, Atlantic
Division Pre-Planning John Cece, Potomac
Hudson Policy Chris Fafard, Potomac Hudson
Planning Chris Fafard Implementation Jerry
Peters, Potomac Hudson and Jim Steinberg,
NAVFAC, Atlantic Division Check
Corrective/ Brian Stockmaster, Preventive
Action NAVFAC, Southern Division Management Revi
ew Brian Stockmaster Wrap-up Tami McVey
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What is an EMS?

• Tami McVey

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Executive Order 13148Greening the Government
through Leadership in Environmental Management

• April 21, 2000
• PART 4 Promoting Environmental Management and
  Leadership
• Mandates EMS across ALL 16 agencies in the
  Executive Branch
• All facilities by 2005
• Planning based on Aspects

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Policy and Guidance

• OPNAV 5090.1B, CH-2, Chapter 20, 9 Dec 99
• EQA Guide, 31 Aug 99 (check phase of PDCA cycle)
• CNO EMS Policy memo, 6 Dec 01
• DOD EMS Policy memo, 5 April 02
• Draft Navy EMS Implementation Guide, July 02

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EMS Definition OPNAVINST 5090.1B Ch-2
That part of the overall management system which
includes organizational structure, planning
activities, responsibilities, practices,
procedures, processes and resources for
developing, implementing, achieving, reviewing
and maintaining the environmental program, and
achieving environmental goals.
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Key Components of Navy DOD EMS Policies

• Public commitment to environmental compliance,
  pollution prevention, and continual improvement
  of the management system
• Integrated planning, including goals and targets
  for reducing environmental impacts and supporting
  mission priorities
• Operations to assure attainment of those goals
  and targets, and training to ensure individual
  competence and responsibility
• Procedures for self-evaluation and corrective
  action, and including identified needs in budget
  processes
• Periodic review of the management system by
  senior leadership

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Elements of Navy EMS

• Environmental Policy
• Planning
• Legal Requirements and Voluntary Commitments
• Practices,Aspects and Impacts
• Pollution Prevention Opportunities
• Objectives Targets
• PPBS
• Evaluation
• Monitoring and Measurement
• Problem/Cause Identification Corrective/Preventi
  ve Action
• EMS Review

• Implementation
• Structure, Responsibilities and Programs
• Training
• EMS Documentation, Document Control and Records
• SOPs
• Emergency Preparedness and Response
• Management Review

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EMS In-Place by 12/05 means

• EMS Description Document/EMS Manual
• Environmental policy
• Organizational structure and key responsibilities
• A description of how the organization satisfies
  EMS requirements
• Objectives and targets
• At least one documented Management Review
• By Installation/Region Senior Management
• Is EMS suitable, adequate, and effective?
• Looks at results of audits, extent to which
  objectives and targets are met, performance
  measures
• Addresses needs for changes to policy, objectives
  and elements of the EMS

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Navy EMS to Minimize Risk to Mission

• Our operations and activities that we use to
  accomplish mission pose risk to environmental
  resources
• When we adversely impact environment, we risk
• Regulatory agency censure
• Loss of public support
• Loss of access to training sites
• Shutdown of operations and activities
• Unnecessary cost and wasteful use of manpower
• EMS means
• Identify impacts to the environment and risk to
  mission
• Concentrate on reducing risk/improving
  performance in highest risk areas first
• Everyones job--Practice owner understands how
  his/her practice impacts environment how to
  control the impacts

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Why Implement An EMS?

• Meet DoD/Component requirements
• Address admin and operational deficiencies
• Use data to make risk
• management decisions
• Mission integration
• Facilitate turnover
• Increase command level attention
• Assist, train, support vs. police or do
• Analyze prevent vs. detect correct

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What elements are lacking?

• Inventory of practice impacts/aspects
• Risk analysis integrating mission
• Priorities targets, objectives, measures of
  success
• Communication protocols
• EMS Documentation
• Delegation/accountability Practice Owners
• Senior management review

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Keys To Success

• Management commitment
• Buy-in
• Compliance assurance and pollution prevention
• Training at all levels, frequently
• Clear objectives, reiterated
• Performance and accountability
• Measurement and improvement

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Plan, Do, Check, ActThe continual improvement
cycle
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NOVs by Root Cause
PPBS
Training
1
System Failure - project
9
10
System Failure - action
Facility/Equipment Design
9
16
Multi-cause
6
Management Emphasis
16
Supplies Contracts
4
Plans and Procedures
29
Analysis of all Navy NOVs received Oct 97-Mar 00
(293)
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Navy Environmental Compliance Posture
100
Detect/correct plateau
80
60
Compliance
40
20
Claimant
RCRA
CERCLA
Regionalization
FFCA
ECEs
WPCA
1970
1990
2000
1980
RCRAA
CAAV
CAAA
SDWA
CAA
Base Closures
CWA
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EMS
Paradigm shift
detect analyze correct prevent consolidate
delegate comply manage improvement media
focus process focus separate
integrate dictate involve inspection accou
ntability competitive cooperative police a
ssist efficiency effectiveness reactive plan
, do, check, act fire fighters fire
preventers squeaky wheel high risk
Transformation managers
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How? Enter the improvement
cycle at any point.
Policy Objectives, Targets Gap, Aspect
analysis Requirements, PPBS P2

• Plan

Revise targets Update
SOPs Retrain
Improve policy Incorp. new standards
Corrective, preventive action

• Act

• Do

Document control Delegation, SOPs
Methodology Communication

• Check

Monitoring, Internal/External assessment,
Oversight, EMS/management review, reporting
(measurement)
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Objectives Targets
Risk
Policy
Plan
Implementation strategy
Turn- over
Do
Training
SOPs
IAP
Check
POUCL
Act
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Comprehensive
Objectives Targets
Risk
Policy
Plan
Turn- over
Do
Training
SOPs
IAP
Check
POUCL
Act
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Risk
S e l e t i v e
Policy
Plan
Turn- over
Do
Training
IAP
Check
POUCL
Act
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Implementation Strategy Depends on Goals

• Meet requirements
• Improve practices
• Share responsibilities
• Management involvement
• Integrate w/ mission
• Ease turnover
• Early success

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Implementation Strategy Depends on Available
Resources

• Staff
• EFD/A
• Region
• Contract

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Models for Export/Adaptation

• Web site as an implementation tool
• Support Team Region, EFD/A, Contractor
• EMS Guide

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Web Site

• Training Modules by claimant/region
• Skill levels management, environmental staff,
  process/practice owner
• Sample products POUCLs, Turnover books, IAPs,
  SOPs, Policies, Risk analyses, etc.
• Clearinghouse news, policy, forum

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Implementation Support

• Regional POC consistency, resource support,
  advocacy
• EFD/A on-site assistance, Web site maintenance,
  consultation, training
• Contractor on-site assistance, staff extension,
  expertise

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EMS Guide

• Step by Step approach
• Policies Purpose
• Elements and Terms
• Tools Templates (examples)
• Gap filling orientation
• Integration w/IAP

EMS In 16 Easy Steps
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Pre-Planning
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EMS Implementation Strategies

• What ?
• All 16 EMS elements in sequential order
• Start with individual elements
• Where ?
• Limited geographic area
• Select organizations or units

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Command Support

• Stress benefits to mission
• Make risk-based decisions
• Improve environmental performance
• Improve public image and relationship with
  regulators
• Improve environmental awareness, facilitate
  personnel turn-over
• Describe proposed scope and strategy

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EMS Team

• Commanding Officer
• Environmental Quality Board (EQB)
• Environmental office
• Environmental POCs

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Gap Analysis

• Compare existing environmental policies,
  procedures, and programs against the
  components/elements of the Navys EMS
• Could identify gaps as
• Implemented and documented
• Implemented but not documented
• Documented but not implemented
• Not documented and not implemented

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Implementation Plan

• Analyze results of gap analyses and develop plan
  to fill gaps in EMS
• Plan should contain what who - when
• Future DoD metric (hint, hint)

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Getting Started

• Do what you can with existing resources
• Everything does NOT have to be done at once
• EMS continual improvement
• Deadline is 31 December 2005 but you can and
  should start NOW

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Elements of the Navy EMS

• Present each Navy EMS Element
• Based on Draft Guidance

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PolicyPlanningImplementationChecking
Corrective ActionManagement Review
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Environmental Policy Statement

• Sets environmental direction and goals
• Basis for objectives and targets
• Most installations have an environmental policy
  in place

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Policy-First Steps

• Develop or revise environmental policy statement
• Ensure senior management participation in process

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PolicyPlanningImplementationChecking/Corrective
ActionManagement Review
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Requirements

• Environmental staff currently track new and
  changing environmental requirements
• Installations may not
• Translate requirements into procedures and
  checklists useful to practice owners
• Negotiate/establish responsibilities
• Provide point of use training on
  procedures/responsibilities

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Requirements-Current Resources

• RECS and NAVFAC
• Internet resources including
• Federal Register (http/www.gpo.gov/nara/index.htm
  l)
• NFESC (regdesk_at_nfesc.navy.mil)
• DENIX (http//128.174.5.51/denix/dod/dod.tml)
• NES checklists

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Requirements-Relationships
Track Requirements
Negotiate/Assign Responsibilities
Implement Checklists
Establish Procedures
Point of Use Training
Plan
Do
Check

• Most installations do not translate requirements
  into procedures, responsibilities, and POU
  training understandable and usable by practice
  owners.

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Practices, Aspects, Impacts-Concepts
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Practices, Aspects, Impacts-Inventory

• Installations have an EQA inventory in place
• Practices
• Practice Owners and Locations
• Compliance Inspection and Oversight Evaluation
  Frequencies and Responsibilities
• Need to make comprehensive and add
• Aspects
• Impacts

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Practices, Aspects, Impacts-Relationships
Monitoring and Measurement
Inventory
Risk-Based Priorities
Objectives and Targets
Actions, Projects
Plan
Check

• Inventory is basis for risk evaluation and
  objectives and targets
• Inventory is basis for EQA Internal Assessment

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Practices, Aspects, Impacts-First Steps

• Update existing EQA inventory with aspects and
  impacts information
• Initially may not be comprehensive
• Goal to get EMS implementation underway
• Follow implementation strategy established in
  Pre-Planning phase

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Risk to Mission
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Impacts and Risk
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Practices, Aspects, Impacts - Risk Ranking

• Evaluate relative risk to mission to prioritize
  practices/aspects
• Process should be repeatable, documented,
  defensible, and periodic
• May apply qualitative approach initially and
  apply quantitative method later

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Pollution Prevention Opportunities

• Navy installations have mature P2 Programs in
  place
• The practice inventory may suggest P2
  opportunities not considered within the
  traditional HW/industrial process focus of P2

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Pollution Prevention Opportunities- First Steps

• Review practice inventory for P2 opportunities
• Apply P2 approach to identify and develop
  solutions for
• Industrial practices not previously identified
• Non-industrial practices
• Environmental aspects

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Objectives and Targets

• Objectives define an end-state supportive of the
  installations environmental policy goals
• Targets are detailed performance standards that
  quantify each objective
• Should be achievable and measurable
• Periodically review and revise

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Objectives and Targets-Types
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Objectives and Targets-Relationships
Environmental Policy Goals
Requirements
Objectives and Targets
Media Programs
Risk-Based Priorities
Actions, Projects
Mission, Local Conditions
Plan
Do
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Actions and Projects

• Actions - behavioral/administrative initiatives
  or outside support within the COs means
• Realign existing R/R
• Develop and provide training or procedures
• Secure NAVFAC support
• Projects - initiatives requiring external
  funding, requested and justified through PPBS
• P2 investments
• Studies
• Plan development

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Actions and Projects-Relationships
Risk-Based Priorities
Actions
Monitoring and Measurement
Objectives and Targets
POM
Projects
Programs
Plan
Do
Check
57
PolicyPlanningImplementationChecking/Corrective
ActionManagement Review
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Structure The EMS Team

• Designated by Installation/Regional Commander
• Includes Senior Management (EQB)
• CO/XOs of installation and tenants
• Department/Division managers
• Environmental office manager
• Includes Technical Support and EMS Implementation
• Media managers and other environmental office
  staff
• Environmental POCs

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EMS Team may include personnel from

• Tenants
• Production
• Maintenance
• ROICC
• Supply

• Quality
• Human Resources
• Environmental
• Safety and Health
• Public Affairs
• Comptroller
• BOS Contractors

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Structure Environmental Office

• Media programs
• Mature
• Already in place
• EMS elements in place
• P2
• Legal requirements
• Emergency response
• PPBS
• Training

Cultural Resources
Solid Waste
Noise
NEPA
UST
IPR
Drinking Water
Pesticides
Radon
Asbestos
P2
Air
Natural Resources
Infectious Wastes
HM/HW
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Structure Practice Owners

• Command, unit, or office that uses a practice to
  accomplish its mission
• Authority to accomplish their mission using a
  practice responsibility to control its
  aspects
• Accountability Responsibilities Authority

4
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Accountability Responsibilities Authority
Environmental Office
EMS Team
Practice Owners
EMS Elements
4
Media Programs
4
Practices
63
Training -Current

• Required by Regulation
• Media related HW worker, WWTP operation,
  asbestos worker, emergency response
• Job Related
• Generally for environmental staff NEPA, ERMS,
  computer skills

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Training for EMS Implementation

• Initial EMS Team Training
• Senior Management
• Environmental Support Staff
• Practice Owners Training
• Environmental SOPs
• Video
• Interactive
• Web

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EMS Description Document

• Include installation EMS Policy
• Demonstrates communicates implementation
• Objectives and targets
• Organizational structure and key responsibilities
• EMS elements
• Incorporate or provide a roadmap to information
  supporting each EMS element

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Communication

• Internal
• Senior managements role
• Environmental staff translate requirements into
  procedures and distribute to practice owners
• Mechanism for practice owners to communicate with
  Environmental Office
• External
• Public Affairs Office

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Environmental SOPs

• Document for each practice
• Location, owner, POC
• Aspects and potential impacts

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Environmental SOPs

• Document for each practice
• Location, owner, POC
• Aspects and potential impacts
• Requirements, Procedures, Responsibilities for
• Operational control
• Communications
• Emergency preparedness and response
• Inspection
• Training

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Environmental SOPs

• Document for each practice
• Location, owner, POC
• Aspects and potential impacts
• Requirements, Procedures, Responsibilities for
• Operational control
• Communications
• Emergency preparedness and response
• Inspection
• Training
• Design, capacity, inputs
• Physical controls, P2 options, and BMPs in place

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Tailored Environmental SOPs

• Practice owners need to know or provide
• Location, owner, POC
• Procedures, Responsibilities
  for
• Operational control
• Communications
• Emergency preparedness and response
• Inspection
• Training

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Emergency Preparedness Response

• Plans prepared, not distributed
• Training up to date ??
• Distribute procedures in Environmental SOPs

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PolicyPlanningImplementationChecking/Corrective
ActionManagement Review
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Monitoring and Measurement

• Sampling and analysis
• Internal assessment efforts
• Tracking progress in meeting objectives and
  targets

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Problem/Cause Identification Corrective/Preventive
Action

• Review results of internal assessment efforts
• Conduct problem solving

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Problem/Cause Identification Corrective/Preventive
Action

• Suggested problem solving approach
• Define problem
• Analyze root causes
• Develop alternatives
• Select corrective action
• Develop corrective action
• Implement corrective action
• Follow-up

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EMS Review

• Answer two questions
• Does the EMS, as described in the EMS Description
  Document, meet current Navy criteria?
• Does the EMS, as implemented, effectively do what
  the EMS Description Document says it will do?

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PolicyPlanningImplementationChecking/Corrective
ActionManagement Review
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Management Review

• Analyze results of following
• EMS review
• Internal assessments
• Status of corrective/preventive actions
• Progress in meeting objectives and targets
• Implement improvements to EMS
• Revise policy
• Revise objectives and targets
• Revise EMS procedures
• Document results

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Conclusions

• You already have a lot elements in place
• Requirements
• P2
• Programs
• PPBS
• Emergency Response
• Checking and Corrective Action (EQA Program)

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Conclusions

• Initial EMS improvements you can do
• Designate EMS Team
• Obtain/provide initial EMS training
• Develop/distribute Policy
• Add aspects and impacts to practice inventory
• Conduct risk evaluation
• Develop objective and targets
• Complete EQA implementation

81
Questions? Discussion