Washington State Department of Ecology An Environmental Management System Alternative to Pollution Prevention Planning EMS Implementation Part II: Communication.

Washington State Department of Ecology

An Environmental Management System Alternative to

Pollution Prevention Planning

EMS Implementation Part II:Communication & Engagement

December 11, 20122012 -2013 Webinar Series Partners:

National Pollution Prevention RoundtableStewardship Action Council

The Auditing Roundtable

2012 -2013 Webinar Series Overview

• Introduction to EMS – National Pollution Prevention RoundtableSeptember 25, 2012– Introduction to Ecology’s EMS Program– EMS Overview– ISO14001 Gap Analysis Tool

• Introduction to EMS – Part 2 National Pollution Prevention Roundtable

October 16, 2012– Ecology’s EMS Program– Toxics Reduction Overview– Objectives & targets

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2012 -2013 Webinar Series Overview

• EMS Implementation Part I – Stewardship Action Council (November 5, 2012)

– Monitoring & Measurement

• EMS Implementation Part II – Stewardship Action Council (December 11, 2012) – Ecology EMS Program– Global Reporting Initiative – Communications & Engagement

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2012 -2013 Webinar Series Overview

• EMS Auditing Session I - The Auditing Roundtable (January 22, 2013) conducted by Dennis Sasseville, Senior Associate with Normandeau Associates. – Preparing for and Conducting EMS Audits– Understanding EMS Auditing– EMS Auditor Qualifications– Pre-Audit Planning & Preparation– Conducting the EMS Audit– Ecology EMS Guidance

• EMS Auditing Session II - The Auditing Roundtable (February 19, 2013)– Audit Reporting, Evaluations and Management Review

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Ecology EMS Alternative

• Provides flexible approach to P2 planning. • Meets RCW 70.95C; Chapter 173-307 WAC

requirements• Work with Ecology to demonstrate

operating EMS is in place.

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EMS Alternative Process

Work with regional Ecology staff at earliest opportunity.

Submit request describing how EMS meets P2 planning criteria.

Submit EMS documentation for regional staff review & collaboration.

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EMS Alternative Process

Host an Ecology EMS Site Visit.

Conduct Facility Periodic Assessment (at least once every five years – 3 years recommended.

Submit annual progress report via TurboPlan or e-mail supporting materials to regional staff.

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Ecology’s Pollution Prevention Criteria

2.1 Pollution Prevention Policy2.2 Implementation2.3 Monitoring & Measurement

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Ecology’s Global Reporting InitiativeSustainability Report

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Why Engage?

• Enhanced engagement opportunities for employees and stakeholders.

• Continuous improvement. • Lead by example.• GRI database listed more than 4,700

organizations worldwide that had published over 10,400 reports.

Table of Contents

1. Strategy and Analysis

2. Ecology’s Organizational

Profile

3. Our Report

4. Governance

5. Environmental (EN)

6. Labor Practices (LA)

7. Social Impact (SO)

8. Economic Impact (EC)

CONCLUSION http://www.ecy.wa.gov/about/GRI/2011/index.html

Communications & EngagementKey Elements

• First environmental agency in North America.

• Integrates sustainability into our decision-making, employee education and ecological footprint.

Communications & EngagementKey Elements

• Highlights activities to reduce waste, improve efficiencies, engage stakeholders and promote lean innovation.

Communications Plan

• Report website

•A ‘printable’ pdf document

•Governor’s Alert

•Press release

•Statewide media listserv

•Business journals

Communications Plan

• Online sustainability blogs

• Twitter tweet (also appears on Facebook)

• Targeted emails

• Special distributions lists, e.g. sustainability

interests, business?

• Legislators

• GRI org coordinated promo

• Work with Focal Point USA external relations

Environmental Management Systems Training (EMS):

Communications and Engagement

Presented by

Stewardship Action CouncilAnne Vogel-Marr, Executive Director

Charlotte Valentine, Program Manager

Content

• Introduction• Review– Characteristics of an EMS– Basic Management System Framework

• Operational Controls– Communications and Engagement

Stewardship Action Council

• Who we are– Coalition of diverse stakeholders, including industry,

state government, NGO community, social investment groups and academia

• What we do– Drive and recognize sustainable performance though

• Webinars• Sharing of ideas• Creation of a learning network• Promoting the accomplishments of our members• Regional collaborative partnerships• Design and implementation of a sustainability index

Your Role In EMS

• Employees should understand all elements of your system and how they work together

• Each part of the EMS system is dependent upon the other parts functioning as intended.

• Failure of one part of the system can result in failure of the system as a whole.

• The role each person plays is absolutely critical.

External drivers, as well as internal ones, dictate the need for an EMS program.

• Assist in maintaining compliance

• Drive continuous improvement

• Replace P2 Planning in the state of Washington

Purpose

Why have an EMS?

•Reactive response to problems

•Recurring problems

•Overwhelmed “specialists”

• Inability to capitalize on opportunities to improve environmental performance

•Reinventing the wheel; inefficiency.

•Changes can cause upsets and compliance problems

What happens when you do not have a system in place?

Problems such as these can be fixed, but without a system in place, they will likely reoccur again and again.

How would you recognize an organization with a strong EMS?

•Consistent approach

•Continuous improvement

•Mistakes are caught before they become big problems

•Clear guidance

•Smooth adjustment to change

•Everyone understands their role

•Key persons can be absent and the system continues to operate well

•Management has tools to know performance status and to manage it

The Four Elements of an EMS: Cycle for Continuous Improvement

Management systems are similar whether you are managing environmental issues, finance concerns, safety, or any other business issue.

In addition to the policy, they consist of four critical elements:

Plan

•Site Activities (Aspects) and Impacts•Legal and Other Requirements•Objectives and Targets•Management of Change

Implement

•Roles and Responsibilities•Design, Construction & Operational Controls

•Training, Awareness & Compliance

•Communication•Community Outreach & Stewardship

•Documentation & Record keeping

Check, Correct & Prevent

•Monitor &Measure•Corrective & Preventative Actions•Self-Assessment Process

Review

•Management Review

This session will focus on:• Communicating Important Information to Stakeholders• Community Outreach and Engagement• Training Employees

Implementing Controls

Plan

•Site Activities (Aspects) and Impacts•Legal and Other Requirements•Objectives and Targets•Management of Change

Implement

•Roles and Responsibilities•Design, Construction & Operational Controls

•Training, Awareness & Compliance

•Communication•Community Outreach & Stewardship

•Documentation & Record keeping

Check, Correct & Prevent

•Monitor &Measure•Corrective & Preventative Actions•Self-Assessment Process

Review

•Management Review

Questions to Think About What systems are in place to report on environmental performance

internally?

How do you ensure senior management (corporate) is provided with required information and kept up to date?

What procedures are in place to receive, document, and respond to communication from external interested parties related to environmental issues, such as neighbor complaints, customer inquiries, regulator communications?

What communications does facility management have with external stakeholders, such as local community leaders, regarding information on progress in meeting targets and objectives and social, environmental, and economic performance?

Communication

Communicating InternallyCommunications to:

Staff ManagementContent: • Programs and Processes

• Changes• Requirements• Performance

• Regulatory• System• Performance Targets and

Objectives• Audit Results and Actions

• Performance• Regulatory• System• Performance Targets and

Objectives• Audit Results and Actions

• Required Improvements• Recommendations

Method: • Staff Meetings• Intranet• Trainings

• In-person• Computer based

• Tailgates• All Hand meetings• Memos

• Pre-Scheduled Meetings• Memos• All Hands Meetings• Email

• Emphasize why it is needed and how it will help them do their job

• Tie to performance appraisal• Tie to bonus• Provide recognition• Provide reward

Key Steps to Consider Methods• Trainings - classroom and

computer based • Meetings, tailgates, etc.• Appoint a dedicated and

energetic individual to drive and support the EMS

• Keep it simple• Management needs to

communicate support• Recognition and reward program

Getting Employee Support for EMS

Key Learning and Recommendations

• Link efforts directly to values, goals and principles articulated by executive leadership

• Include both professional and personal actions

• Give permission to innovate

• Provide tools and opportunities to collaborate

• Have Fun!

Activities

• Pollution Prevention Pays– 8,400 Projects Since 1975– Employee driven projects that prevent

pollution or raw material use and save money

– Any employee can participate

– Projects recognized by senior leadership and through nominal prizes

• Employee Education Programs– Sustainability Speaker Series– Internal newspaper– Sustainability Newsletter– New Hire Training on Sustainability– In-Depth Targeted Training (i.e Green

chemistry)

Examples of Employee Engagement3M

Examples of Employee EngagementContinuous Improvement – Energy Company

Key Learning and Recommendations

• Create competition within and across sites

• Tie to employee review/performance appraisal or bonus

• Communicate and promote program often

• Provide tools and opportunities to collaborate

• Have Fun!

Activities

Footprint Reduction Program

– Part of Company Bonus Program

– Required annual environmental improvements linked to footprint

– Projects approved by senior management

– Projects listed in detail on company intranet

– Over $30 MM saved in 3 years

Reduction of Energy Use Project Green Dollar Savings

Environmental Benefit

Modify primary air fans to reduce house load and increase efficiency

$0

Lighting project to reduce energy use by placing lighting on photocells

$41 69 MWH

Reduce house load at the SCR ammonium hydroxide dilution air heaters by ducting combustion turbine waste heat to the dilution air heater inlets

$39,491 274.4 MWH

Optimize heating of secondary containment areas by evaluating heat tracing for appropriate temperature and lines as well as turn off heaters when not needed.

$6,378 194 MWH

Re-sheaving limestone blowers to reduce energy use $27,859 1114 MWH

Optimize raw water pond by storing higher turbidity water for settling and pump from river when turbidity is lower, reducing energy use

$2,802 112 MWH

Scavenger/house load reduction by uncoupling atomizing air compressor from GT load gear

$168,030 3,734 MWH

Total $244,600 5,497 MWH

Sample Projects

Communicating ExternallyWho do you need or want to communicate with?

• Regulators• Community at large• Target community group• SRI’s• Other interested parties

What do you want to communicate?• Performance• Goals• General info about the facility

What communications mechanisms are available?• Press release• Open House• Website• Facility/company report• Community Project • Third party communication on your behalf

• Communication should be two-way• Ask stakeholders what they care about• Taylor communications to areas of

stakeholder interest• If stakeholders are critical, learn why

and engage them

Listen and Learn

• If shared interests exist, look for ways to work together– Energy company sponsoring energy

savings programs for customers– Healthcare company training sponsoring

training programs for nurses

Community Outreach

Benefits of Training• Ensures that all employees know what is

required and the proper ways to carry out tasks• Ensures each employee knows how their

actions and jobs can affect the environment• Communicates consequences of improper

actions

Training

TrainingQuestions to Think About• How do you identify and document training needs, by personnel role and

responsibility? • How do you ensure that all individuals with roles and responsibilities that

could create a significant environmental impact received appropriate training?• How do you track who has received training?• How do you ensure people get trained who were absent the day a training was

offered?• What training do new employees get? Those transferred between departments?• How do you measure if the training was effective?

• How do you ensure that employees are aware of environmental expectations, the environmental risks associated with their job, their role, and the consequences of departure from procedures?

• How do you ensure individuals are competent to perform their assigned responsibilities?

Required Environmental Training Reference Frequency

Req. #

SS

CRO

Plt. Op

Util. Op

Mechanic

Elect

I&C/ Chem

Mtce. Utility

Clerical

Mgmt. – Admin

Mgmt. – Tech

HAZWOPER - Operations Level (8 hours initial + refresher)

29CFR1910.120(q)(6)(iii) Annual

HAZWOPER-1st Responder 29CFR1910.120(q)(6)(i) Annual

HM-181 - Haz Mat 49CFR172.700 Every 2 years

Emergency Action Plan & Procedures 29CFR1910.38(A&B)/Franchise Manual

I&R

Hazardous Waste Overview 40CFR243.201-2(a); 262.34(d)(5)(iii)

I & R

SPCC 40CFR112.7 Annual NPDES Stormwater Permit 40CFR122.26 Annual Hazardous Materials - DOT 49CFR172.704 I&R RMP - Program Level 2 40CFR68.54 I&R RMP - Program Level 3 40CFR68.71 I&R RMP - Program Level 3 - (contractor training requirement)

40CFR68.87(c)

Company Environmental Policy Franchise Manual Annual Environmental - Awareness Training Franchise Manual Annual Environmental - EMS Computer Based Training

Franchise Manual Annual

Site specific plans, procedures, and permit requirements

Franchise Manual Annual

Contractor environmental orientation & awareness training

Franchise Manual Annual

Anne Vogel-Marr, Executive [email protected]

(301)482-2523

Charlotte Valentine, Program [email protected]

(202)296-3952

Stewardship Action Council1155 15th Street NW, Suite 500, Washington, DC 20005

www.stewardshipaction.org

Contact Information