Cathleen Sullivan
WASTREN

Jack B. Tillman
USDOE

Contractors at Federal Facilities operate under a pervasive scheme of regulations and agency orders. These requirements provide a firm foundation for developing an Environmental Management System under the ISO 14000 standard. The ISO 14000 Environmental Management System provides a framework for integrating existing environmental programs and management systems into a comprehensive approach to environmental stewardship in every day operations.

This paper presents a case study of the process used by WASTREN-Grand Junction (GJ), a Department of Energy contractor, to self-declare under the ISO 14000 standard. The Environmental Quality System was developed by integrating existing elements from programs associated with National Environmental Policy Act (NEPA) review, pollution prevention, emergency preparedness and response, public relations, and employee training and awareness. The Environmental Quality System provides both a baseline and a strategy for continual improvement in environmental management activities.

WASTREN-Grand Junction (GJ) is a small-business contractor with the U.S. Department of Energy (DOE) at the Grand Junction, Colorado, facility. The primary mission of the Grand Junction Office (GJO) is the application of project management, engineering, and geoscience expertise in support of national programs in environmental restoration, waste management, geoscience, and energy. The site has supported numerous programs during the past 50 years, including the Uranium Mill Tailings Remedial Action (UMTRA) Project, the National Uranium Resource Evaluation (NURE), and, originally, the Manhattan Project. The focus for the past 10 years has been the remediation of soils and buildings contaminated with radiation from uranium mill tailings.

The overall aim of ISO 14000 is to support environmental protection and prevention of pollution in balance with socioeconomic needs. To accomplish this, the standard specifies the requirements of an environmental management system and is written to be applicable to all types and sizes of organizations and to accommodate diverse geographical, cultural, and social conditions. Each organization is free to create an environmental management system tailored to individual needs and operating requirements. The success of the system depends on commitment from all levels and functions, especially from top management. A system of this kind enables an organization to establish, and assess the effectiveness of, procedures to set an environmental policy and objectives, achieve conformance with them, and demonstrate such conformance to others.

Understanding the elements of ISO 14000 and taking advantage of the flexibility of the standard are the basis for integration of existing systems into a "new" environmental management system. The final system must provide for the following essential elements:

1. Environmental Policy
2. Planning
3. Implementation and Operation
4. Checking and Corrective Action
5. Management Review

The environmental policy is the foundation for any environmental management system. When appropriately created, the policy should summarize the company's approach to environmental issues and define the structure for implementation, communication, and verification of its principles.

Planning within an environmental management system should encompass several elements such as identification of environmental aspects and impacts followed by a determination of the significance of the impact, establishing objectives and targets that are consistent with the environmental policy and that work to mitigate significant impacts, identification of legal and other requirements that govern operations, and the creation of an environmental management program that guides company activities to improve the relationship with the environment.

A company must define the structure and responsibilities for implementation and operation of the environmental management system. A company must provide adequate resources and appoint a specific management representative who will have defined responsibility and authority for ensuring that the environmental management system is established, implemented, and maintained in accordance with the standard, and who is responsible for reporting on the performance of the system to other management personnel.

Companies must commit to open communication, both internal and external, to advise employees and stakeholders about their activities, when appropriate. The standard calls for training and awareness of employees, especially those whose activities may have a significant impact upon the environment.

Documentation of the system is critical, not only to substantiate the system, but also to ensure that information is properly disseminated and that records are kept in a manner that allows for maximum retrievability. This requirement applies to business operation records and to environmental management system documentation.

Operational controls are necessary to plan activities, including maintenance, in order to ensure that they are carried out in a manner that is protective of the environment and that reduces the significant impacts of the operation of the environment.

Finally, the company must have in place an emergency preparedness and response plan to identify the potential for and respond to accidents and emergency situation, and for preventing and mitigating the environmental impacts that may be associated with them.

The organization must also establish a system to verify the functioning of the environmental management system. The key elements to this are monitoring and measuring, identification of nonconformance and corrective and preventive actions, record keeping, and environmental management system audits.

Finally, the organization's top management is required to review the environmental management system itself to ensure its continuing suitability, adequacy, and effectiveness.

Operations at most federally controlled sites are subject to numerous federal, state, and local regulations and directives issued by federal agencies and the President of the United States. This highly regulated environment produces numerous systems and documents that successfully capture and implement the philosophies and goals of ISO 14000. The task is to identify the existing systems that will meet the goals of ISO 14000 and package them into an environmental management system.

The first step is to create a team of people to review existing operations and documentation. The team should be trained in the concepts of ISO 14000, but more importantly, the team should be intimately familiar with the site operations and the regulatory requirements for those operations. Below are some examples of how the company connected the existing systems at the GJO to the requirements of ISO 14000.

WASTREN-GJ is a company with many years of experience in the environmental field. Protection of the environment and strong environmental stewardship principles permeate the culture of the company. Developing an environmental policy was the first and easiest of the steps to accomplish. Additionally, our performance toward the environment is determinative of our performance under the cost plus award fee system of our contract at the GJO-failure to implement strong environmental principles can result in significant financial loss. Essentially, the policy reflects our commitment to the environment, the management strategy for ensuring that the commitment is met, and our promise to our customers that we will meet their expectations for environmental protection.Planning

Reviewing actions to determine their environmental impacts may be a new concept to commercial companies, but is part of everyday life at a federal facility. All actions undertaken at federal facilities must be reviewed under the National Environmental Policy Act (NEPA) to determine if there are impacts to the environment. The company compared the philosophy and requirements of NEPA (as implemented by DOE) to the objectives of ISO 14000 and concluded that they were equivalent.

At the beginning of the process to implement ISO 14000 at a site, the company should review existing operations to determine

1. Environmental aspects (element of an organization's activities, products, or services that can interact with the environment).
2. Environmental impacts, if any (impact is defined as any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organizations activities, products, or services).
3. Significance of the impact (environmental impacts may be deemed "insignificant" and not require mitigation or management; the environmental management plan should only address those impact that are significant).

This review can be accomplished as an environmental audit or a step-by-step analysis of all existing activities. At the GJO, a site-wide environmental assessment had been written the year before that carefully analyzed existing operations, the affected environment, and environmental impacts. The process for creating an environmental assessment is very similar to those prescribed by ISO 14000 for analyzing environmental aspects and impacts. Both require a review of existing operations, consideration of environmental impacts, review by the public and incorporation of comments from stakeholders, and a final determination of the significance of the impact to the environment. Federal facilities that operate under a recent site environmental assessment or who are in the process of developing an environmental assessment can rely on the work done under NEPA for the basis of their environmental management system.

Grand Junction Operations also uses a large database application for process flow diagrams. Over the past 2 years, we have identified all the major components of each of our activities and diagramed their relationships in computer files. The system has been modified to include information on identified aspects and impacts of the activities and the objectives and targets identified for continual improvement.

Businesses must ensure that existing procedures are adequate to meet regulatory requirements. ISO 14000 calls for a formalized procedure to review and identify legal and other requirements and to ensure that new and changing requirements are integrated into procedures. At the GJO, one group is charged with reviewing published changes to regulations and determining whether the change will affect site operations. If a change in operation is necessary, Environmental Compliance contacts the manager responsible for the operation and requests a change in procedures. The change is documented in the manual system. This protocol existed prior to self-declaration as a sound business practice.

To ensure that new activities are evaluated, federal facilities are also required to review each new project under NEPA to determine the applicable regulatory requirements. This process includes a review of applicable DOE Orders and other Executive Orders that may apply to the activity. The analytical requirements of NEPA are again equivalent to the requirements for identification of legal and other requirements under ISO 14000. The procedures at the site were modified to include ISO 14000 language and forms were modified to include a review of established objectives and targets.

Developing meaningful objectives and targets proved to be the most challenging part of the creation of the Environmental Quality System. ISO 14000 requires that objectives and targets be established to mitigate the significant environmental impacts identified in the initial analysis of aspects and impacts. Because the site has always operated under the federal regulatory scheme and DOE direction, there are strong programs in place for pollution prevention, waste management, environmental monitoring, and recycling of materials. The primary mission of the site is such that there are no major physical processes or pollution sources; there was no "low-hanging fruit" for us to harvest. This situation does not preclude adoption of ISO 14000; instead we focused on taking credit for what we routinely accomplish. There are most likely many activities required by existing contracts or agreements that fulfill the goals and requirements of ISO 14000 that exist at your sites. Do not preclude achievement of these requirements as part of the environmental management system simply because you are already performing the necessary activities.

Our initial step was to recognize that the Task Plans we operate under define what we do and define the resources that are available to accomplish those assignments. The Task Plans are subject to frequent negotiation and evaluation. ISO 14000 requires that business regularly evaluate their operations to identify new areas for improvement. Therefore, it was logical to use the Task Plans as the basis for our objectives and targets.

The existing Task Plans included some very broad statements that could be adopted as objectives. For example, the Waste Management/Waste Minimization Task Plan includes the following statement:

The next step was to establish measurable targets that could help us gauge our progress toward this objective:

These targets simply embody existing programs. However, we are not restricted under ISO 14000 from taking credit for the good things we already do. The continual improvement required by the standard comes almost automatically as we attain these goals in an atmosphere of increasingly restrictive budgets and with ever-decreasing resources.

Another area that we identified for continual improvement was the actual implementation of the plan. Many groups selected objectives and targets based on the requirements of the Environmental Quality Plan. For example, the Training Group developed a series of course outlines and schedules for training in ISO 14000 principles. The training fulfills the requirement for communication of ISO 14000 principles and, again, allows us to take credit for steps we are already taking. The Records Group established an objective of creating the Environmental Quality System Records Index. Managing environmental management system records is an integral part of the requirements of the standard.

Remember, when you establish objectives and targets, not all of them will have the word "environment" in their text. There are many facets to the implementation of ISO 14000 and steps taken to achieve implementation are worthy objectives and targets.

Sound business principles dictate that all routine procedures and processes be captured in documents that employees can use to complete their assigned tasks. ISO 14000 calls for the definition of the structure and responsibilities for implementation and operation of the environmental management system. Again, take the time to look closely at the existing manuals and to review what you have in place. Chances are you will find many of the key components for a successful environmental management system. At the GJO, we had extensive documentation created to implement our approach to environmental management and the operational controls used to ensure compliance. Only minor modifications were required to create a fully functional environmental management system.

A good example of this is the emergency preparedness and response plan required by ISO 14000. The GJO has had in place for a number of years a detailed emergency response plan created in response to DOE Orders. Sites that manage environmental hazards usually have spill prevention and response procedures, agreements with local emergency response agencies, and preventive measures in place to prevent environmental harm. As a suggestion, look closely at your evaluation of legal and other requirements. If you are required to conform to the Resource Conservation and Recovery Act (RCRA) or the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), you will have an emergency response plan somewhere on your site. Take advantage of this opportunity to review the plan if necessary, but do not reinvent the wheel.

We were also able to incorporate the detailed records management systems that are in place at the site to meet the requirements of the National Archives and Records Act.

The company did add a new job title to our bank of job descriptions: the Environmental Quality System Manager. This function is absolutely critical to the success of any ISO 14000 implementation. Senior management must have a contact for the environmental management system and the environmental management system needs a strong advocate to speak to senior management. The environmental management system manager should have ultimate responsibility and adequate authority for the implementation of the plan.

If at all possible, the environmental management system manager should be appointed at the beginning of the implementation process in order that he/she may participate in and direct the ISO 14000 Committee. ISO 14000 envisions this person as the environmental manager. That function may already be filled at your company. If so, creation of a specific job function is not necessary. However, do ensure that the person who is appointed to this function has adequate time to devote to the program. The environmental management system manager will implement and oversee the requirements of the environmental management system. This involves scheduling of management reviews, document control, training, information dissemination, ISO 14000 review of documents and projects, tracking targets and objectives, integrating the environmental management system objectives into existing documents and programs, and participating in management decisions to ensure conformance to the plan and to the standard. The environmental management system manager should be the primary point of contact with stakeholders for ISO 14000 issues (after consultation with management, of course). The environmental management system manager should have the authority to talk directly to managers, to issue findings and request corrective action plans (when necessary), and to raise issues.

The standard requires that companies provide adequate resources for implementation of the environmental management system. At WASTREN-GJ, the Task Plans and budgets dictate not only what we will do, but how much money there is to do the work. Thus, the objectives and targets are tied to the Task Plans to ensure resources are available to achieve conformance. Your budgeting process can also be incorporated into the environmental management system. Similarly, existing contracts or work agreements can provide many objectives and targets for your program and tying performance to the budge will ensure that the economic component of ISO 14000 is integrated.

ISO 14000 requires that you verify and document your performance under the environmental management system. This is accomplished by monitoring and measuring, identification of nonconformance, implementing corrective and preventive actions, documenting the actions, and specialized environmental management system audits. The Standard calls for a very proactive approach and requires a high level of self-policing.

Most businesses today have a quality assurance or quality control system in place. Many companies have quality assurance systems that are equivalent to or registered under ISO 9000, "Quality Systems." If a system is adequate to meet the demands of good business practice, it will likely suffice under ISO 14000 with limited or even minor revision.

At the GJO, we were fortunate to have an award-winning quality system in place that was designed to meet the requirements of ISO 9000 and numerous DOE orders and directives. Adapting the system required minor changes to the manual system to incorporate ISO 14000 language.

We also have the Commitment Tracking and Management System, a database that tracks corrective actions and audit findings. All managers can access the information and they are held accountable for items entered into the system. The use of the CTMS provides valuable documentation for our activities.

Senior managers for WASTREN-GJ are very active in reviewing all documentation, proposals, plans and procedures, and actions implemented at the site. As a small business, this hands-on approach is both necessary and prudent. The managers were asked to develop and adhere to a schedule for management reviews under the Environmental Quality System. Essentially this meant two things: 1) documenting the actions they are already taking (such as weekly walk around inspections) and 2) reviewing the entire Environmental Quality System each quarter to identify deficiencies and require corrective action.

Every 6 months we are required by our Task Plans to submit a self-evaluation of our actions during the previous 6 months. The process provides valuable information for our client, the DOE, and for each of the managers who are working toward continual improvement. This review is also the basis of our cost-plus award fee. WASTREN-GJ has elected to adapt this system and complete a similar review of the Environmental Quality System each quarter. Eventually, if we are successful at incorporating Environmental Quality System criteria into the Task Plans, the review completed for DOE will meet the requirement for review of the Environmental Quality System for two of the four required reviews.

Our experience at WASTREN-GJ has provided valuable information for others who are looking at implementing ISO 14000. By working with existing systems and analyzing ways in which those systems could be integrated, WASTREN-GJ has achieved a comprehensive environmental management system with minimum costs and minimal impact to existing procedures. Such an integration is possible only because of the quality of the existing systems that were created to satisfy the many regulations and administrative orders that dictate how we do business.

The process outlined above may sound simple. In fact, the process took enormous effort and cooperation among all members of the implementation committee, senior managers, and all WASTREN-GJ employees. An analysis of existing system will fail if the people responsible for implementation do not take the time to acquaint themselves with all of the existing processes. The integration into the environmental management system must be sensible and realistic: systems do what they do, but must be modified when necessary to meet the goals and philosophy of ISO 14000. The "simple" part occurred because of the planning involved and the emphasis that was placed on making what existed work. Employees are more receptive when they are told that the way they do business is the right way and that an ISO 14000 environmental management system will ensure that they receive the proper credit and recognition.

The bottom line is that implementation of ISO 14000 should not mean an entire restructuring of a company that has performed effectively for a number of years, and this is especially true for companies that operated as federal contractors. Companies should take the time to analyze their existing systems, refine their approach, and then package their systems into an environmental management system that the community and the regulators can recognize as protective of the environment.

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