Tuesday, October 22, 2013

Planning for, and profiting by, pollution prevention

My last post dealt  briefly with the synergy between LEED and various ISO standards.  I thought that it might be useful if I delved deeper into creating an Environmental Management System (EMS).  An EMS is the central provision of ISO 14001.  It is a system to address environmental matters in a strategic fashion that follows the classic system for continual improvement pioneered by Quality Management Systems.  This is the PDCA or Plan-Do-Check-Act cycle or Deming cycle. 

Why would I do this?

Why should architects and designers be interested in this? Anyone involved the operation of building and the activities that take place within the building should be concerned about its environmental impact and related costs.  Architects, at the design phase, should be cognizant that the structure may benefit from having an EMS in place and this should be part of an integrated design process.  As this is largely a document and data driven endeavor, it is better to secure this vital information as early as possible. This is even more apropos for folks seeking LEED EBOM.  Why wouldn't you consider a building that is built in the best possible manner to also be operated and maintained to a similar high standard,and also, to have same high standards for the functions that occur within the structure. 

There are several convincing  business reasons for creating an EMS, reasons beyond just doing the right thing. These include market demands, regulatory compliance, demonstrating corporate core values, public perception, and of course, marketing.  I find that the  most compelling argument, from an environmentalist perspective and a business perspective is that identifying, controlling, and reducing an environmental footprint reaps financial as well as environmental benefits.  These include reduced costs, reduced overhead, more efficient processes, improved employee performance, reduced risk, and ensuring regulatory compliance. In some cases, regulatory agencies will provide incentives for adopting an EMS such as reduced frequency of inspections, technical assistance, and even modified regulatory requirements.  Also, the emergency preparation element of an EMS helps minimize threats to human and environmental health, as well as, minimize costs associated with mitigation and remediation.  

These benefits are cumulative and directly proportional to pollution prevention milestones. These are outlined in the white paper "Sustainability Nears a Tipping Point" by the MIT Sloan Management Review.  This paper shares that companies that were early adopters of rigorous sustainability programs  have now begun to harvest the benefits as a competitive advantage.  Furthermore many executives who embraced sustainability initiatives now consider the value of their programs not just in terms of corporate goodwill and theoretical costs avoided but as a profit center in and of themselves. One caveat, these benefits  are realized over time. According to the above referenced study, organizations that have less than 2 years of experience with a sustainability program are 50% less likely to report a profit from those activities than those with 12 or more years invested in their sustainability programs. An EMS can benefit any organization that is willing to commit to the process, regardless of size or business.  The range of entities that operate under an EMS include manufactures, office buildings, laboratories, small businesses, golf courses, and, athletic facilities. In short, any business that generates any environmental impact can have an EMS. If that impact represents waste or risk, then there is a compelling business interest. 

Step by Step

Obviously, a detailed procedure for establishing an EMS is beyond the scope of this blog article.  I will attempt to briefly outline the steps below. 

A critical step is creating an Environmental Policy.  This is an over arching statement of the entities intent, aspirations,  values and goals.  At the very least the policy must insure compliance with all local, state, and federal environmental laws. It must detail pollution prevention goals, preferably with quantifiable metrics , and it must detail managements commitment to continual improvement.  This policy needs to public and it must be communicated to the employees.  It is critical that the highest levels of management are invested and involved in this process and that they support this policy.  

Next would be an identification of all environmental "Aspects" and "Impacts". An Aspect is anything that can effect the environment and an Impact is the means and degree of that effect. An Impact may be positive as well as negative.  The list of Aspects and Impacts can be extensive and this is typically drafted by an EMS committee that is composed of relevant decision makers.  Unlike LEED, these Aspects need not be contained within the fence-line or project boundary.  For example, an Aspect may be the companies desire to only conduct business with other companies with an EMS or ISO 14001 compliance.  

Once the list of Aspects and Impacts is created. The next step is to prioritize those elements. Common means of prioritizing include a matrix with frequency of occurrence (high as daily commute to low like an unlikely emergency spill) , level of Impact, cost, benefits, legal risk, and employee and community concerns.  

Along with knowing what the environmental risks are and the potential consequences. The EMS needs to detail the legal and regulatory requirements surrounding those environmental issues. This establishes the baseline actions necessary.  

Once you know what the environmental Aspects/risks of your business are, and the potential Impacts that can result, and the minimum necessary actions - you can develop objectives and targets for all Aspects. Not every Aspect needs to have an objective beyond the minimum legal requirements. Low priority Aspects not addressed can be addressed through  the process of continual improvement at a later date.  The Aspect/Impact need not be mitigated in one fell swoop. It can be addressed incrementally over time. A goal that is unattainable or unrealistic is not valid objective.  Again, upper management needs to be involved from a resource commitment point of view.  Also it is wise to involve those "in the trenches" that will ultimately be responsible for the successful achievement of these objectives.  

Finally a formal program needs to be established and implemented. This sets up a consistent approach to achieve each objective.  This can include guidance, information, and references. It should include timelines, resources, and detail who is accountable and responsible for achieving the objectives and targets.  It should include necessary training to demonstrate competency of those involved in meeting each and every objective.  It should include procedures for communications and document control to insure that critical documents are maintained and updated and that important communications and records are logged.  Techniques, such as operational controls, administrative controls, or engineering controls should be detailed.  These can and should be amended as the program evolves.  Finally, mistakes will happen and therefore an emergency readiness and response plan needs to be formulated for each Aspect. 

Continuous improvement keeps rolling along

At this point the EMS should be developed and implemented. The management will be on board and will be supporting the efforts to meet the defined objectives.  The responsible parties will have been assigned and will be overseeing the ongoing efforts. All necessary personnel have been made aware of their respective roles and have received access to all training needed to insure their competence. 

 The next links in the PDCA cycle is check and act. This involves determining environmental performance, identifying corrective or preventive actions for situations where expected performance was not realized, auditing the systems to insure that all elements are functioning and up to date, and preserving any relevant records.   Management needs to review the effectiveness of the EMS on a periodic basis and needs to update goals, revise Aspects and Impacts, and address shortfalls uncovered by the review/audit.  Thus the cycle starts again.  

You are not alone

The process can can be a difficult and tedious ordeal. It is highly dependent upon investigation and documentation.   However, you are not alone. There are resources available.  Consultants can be hired that can guide you through the process. There are online services that will help draft a customized EMS from a stock template.  For those that wish to wish to do it themselves, the EPA has a wealth of information available. 

The most important thing is that the EMS process forces companies to think critically about their environmental impact.  This self reflection can lead to great rewards for themselves, their shareholders, their neighbors, and the planet.

Kevin Dufour is an Environmental Scientist with Viridis Advisors. He collaborates with Tom Irwin on creating greener greenscapes. The opinions expressed by member bloggers are their own and not necessarily those of the USGBC Massachusetts Chapter.

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