Larry Stirling
U.S. Department of Energy
ABSTRACT
The Department of Energy (DOE) has been actively considering use of Environmental Management Systems (EMS). This approach represents a fundamental change in the way that DOE ensures environmental protection. It should not be evaluated as an add-on but a basic change in how business is done. This is important because DOE cannot afford business as usual. This paper outlines some of the issues to be considered by DOE programs, sites, and laboratories in adopting an EMS. It will also outline EMS activities within the Department and with other agencies.
INTRODUCTION
The Office of Environmental Policy and Assistance (EH-41) has taken a leadership role in assessing the potential and implementation issues involved in adopting an Environmental Management Systems (EMS) approach. This approach represents a fundamental change in the way that the Department ensures environmental protection. This change can be important because the Department cannot afford business as usual. This paper will discuss some of the issues to be considered in adopting an EMS in DOE programs, sites, and laboratories. It will also provide a review of selected EMS activities within the Department and in collaboration with other agencies.
BACKGROUND
An environmental management systems approach can be a better way to do business for DOE and other Federal agencies. It should not be considered as an add-on or additional layer. It can be a change as basic as moving to pollution prevention from end-of-pipe approaches. For 25 years, command and control was the most effective, and often the only, way to advance environmental protection. That is changing. The additional value to be gained by added command and control is diminishing. New approaches need to be thoughtfully evaluated and an EMS approach is one of the most promising. Implemented intelligently, it can complement command and control, trading centralized oversight for decentralized accountability. It can also support moving from one-size-fits-all to a graded approach that's keyed to work done at a facility. In addition, adopting an EMS can serve as a down payment, a way to show Departmental stakeholders and regulators that there is a commitment to acting efficiently and responsibly.
RETURN ON INVESTMENT
No Federal agency can afford business as usual. Resources are declining and expectations for public sector productivity are becoming increasingly like those of the private sector. This can be good news. When the public looks for return on their investment, the value of risk avoidance, waste minimization, resource management and EMS are easier to recognize as important. An EMS approach can be a tool for increasing public return on investment.
This return on investment should be considered in clear but broad terms. An EMS can provide a systems approach to management, including delivering reliable environmental protection. It also shows a commitment to continuous improvement in an organization's own management. This does not guarantee regulatory compliance but it can reduce unintended causes for being out of compliance. Thus while improvements in environmental performance cannot be guaranteed, they can be reasonably expected. This will not guarantee enthusiasm or flexibility from regulators and stakeholders. However,improving performance and a public commitment to continuous improvement in management can be a basis for broadening discussions with regulators. It can also help in DOE's transition to external regulation of health and safety concerns.
CORPORATE ENVIRONMENTAL FRAMEWORK
An EMS can provide an organization's corporate environmental framework. This framework is important because it provides vision for staff and managers. In confusing and often turbulent times, an understanding of the basic vision by which an organization operates helps people navigate. This does not imply uniformity of thought or application but a foundation giving staff and managers confidence in making the hundreds of decisions needed each day.
A related issue in considering the potential of EMS is its potential for supporting the use, integration, and deployment of related EH initiatives. DOE has numerous on-going initiatives. They have arisen in response to complex environmental, safety, and health concerns that have emerged over time. The range is wide. WorkSmart Standards, Voluntary Protection Program, Enhanced Work Planning, Responsible Care, and Safety Management Systems are examples that demonstrate the scope of issues facing the Department. Each of these initiatives can add value but they loose focus when unintegrated. EMS can be the platform for linking and efficiently deploying these related initiatives, pulling them together and expanding their impact.
COST-EFFECTIVENESS
DOE programs, sites, and laboratories have made large investments in programs for compliance management, regulatory tracking, emergency response, information management, training, document control, and many of the other elements needed for an EMS. Adopting an EMS should not require a DOE organization to throw out this investment start from scratch. Quite the opposite. DOE program, site, and laboratory managers should be encouraged to identify and use functioning structures or capabilities that best meet the requirements of an EMS. They can then make cost-effective improvements until programs and sites are in full conformance. This does not have to happen overnight and does not require computer programs or elaborate paperwork. Precisely because the core of EMS is management, it is a prime example where leadership can be as important as cash.
DOE EFFORTS
A wide range of efforts related to EMS are underway. An EMS approach could be introduced to DOE in several ways:
ISO 14001 could be used in responding to EPA's Code of Environmental Management Principles (CEMP).
Each of these is possible. However, this does not mean that DOE programs, sites, or laboratories will be required to be ISO 14001 registered or that DOE contracts will require ISO registration. What it could mean is that DOE facilities and contractors are evaluating EMS and moving toward an integrated approach. The incentives have been described above. People are getting ready; they are getting smart.
Within the Office of Environmental Policy & Assistance, there is a Program Plan for developing and providing EMS technical assistance to programs, sites and laboratories. Efforts are underway to work with Programs, sites, and laboratories, and to link with other EH initiatives. EMS performance indicators and methods for benchmarking cost-savings are being developed. A series of EMS Fact Sheets and training efforts are being conducted. On a broader scale, collaboration is underway with other agencies. DOE and EPA are also co-chairing an EMS Interagency Working Group. At last count, 22 people from 8 agencies were participating. DOE is also working with regulators. It actively supported EPA's Office of Federal Facilities Enforcement (OFFE) in working to recognize the role ISO 14001 can play in implementing EPA's Code of Environmental Management Principles (CEMP) which were developed in response to E.O.12856. DOE and OFFE are continuing to collaborate, developing an EMS Primer for Federal Facilities.
SUMMARY
There is a range of considerations in adopting an EMS approach. This paper has discussed key examples: showing regulators and stakeholders that the Department can operate responsibly, providing a corporate environmental framework for staff and managers during turbulent times, and expanding the value-added of related EH initiatives. None of these things is impossible but all are beyond business as usual. There is potential for real change in how the Department does business and it is a challenge that can be met.