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Review & Improvement
Regular reviews
are key to continual improvement and to ensuring that your EMS
will
continue to meet your college or university’s
needs over time. Learn how to effectively measure, correct, record,
audit, and review your EMS by visiting the sections and using
the tools listed below.
Measurement and Monitoring
Decisions and operational improvements that you make as part of
your EMS should be based on quantified environmental performance
data. Measurable parameters, or metrics, must be developed to allow
you to quantify your progress.
Identify and
measure specific parameters to track progress toward each of
your EMS’s
objectives and targets. For example, if campus-wide energy use
is a significant environmental aspect and
energy use reduction is an objective, parameters must be identified
and periodically measured to determine whether the target is reached.
In this example, a typical parameter that could be included is
kilowatt-hours consumed annually.
Establishing baselines and monitoring programs can be especially
difficult on campus. In some cases, a single department may not
have complete control over an aspect, such as energy use, which
makes measurement and monitoring particularly challenging. It is
important to make regular reporting a standard operating procedure
and the responsibility of one person. Measuring and monitoring
programs is also a good area to utilize student assistance; they
can help to identify parameters, establish baselines, and maintain
an established monitoring program.
Target-specific metrics are unique to your objectives and targets.
Examples of metrics that relate to common objectives and targets
include:
• Energy use from on-campus dormitory lighting
• Water use in recreational and athletic facilities
• Monthly volume of halogenated solvents used by chemistry department laboratories
• Monthly use of floor strippers containing toxic chemicals by janitorial
operations
• PC energy consumption from campus computer laboratories
• Monthly volume of pesticides used on campus for vector control in buildings
• Tons of waste concrete landfilled per quarter
Because all schools use water and energy, conservation of those
two resources is a common target. Laboratory-generated wastes are
another common target, and should be more easily measured because
of regulatory compliance records.
Examples
Washington
State University Monitoring and Measurement Procedure
Tools
EPA
New England EMS Guide 
This guide was developed by EPA New England and colleges and
universities nationwide. Use it to design a cost-effective EMS
that improves
compliance and environmental performance, promotes pollution
prevention, and saves money. The guide provides a framework to
systematically identify, prioritize, manage, mitigate, and document
the environmental aspects and impacts of your school’s
activities.
PEER
Center Steps for Implementation
The information and guidance provided on this Web site is structured
to address the needs and issues that a public entity might encounter
as they prepare for, develop, and implement an EMS
EMS Nonconformance and Corrective
Action
EMS audits, day-to-day EMS procedure implementation, and administration
reviews will occasionally reveal deficiencies in your EMS or activities
that do not conform to the EMS. When nonconformance is identified,
corrective action must be taken to address and rectify the causes
of the nonconformance to continually improve the EMS. Examples
of EMS nonconformance include:
• Monthly EMS Meetings not held on a routine basis
• EMS participants are unaware of their EMS-related responsibilities
• Labeling in laboratories still shows deficiencies
Typical causes
of EMS include inadequate “buy-in” from
critical EMS participants: administration, specific departments/groups
within the school, etc. Causes may include:
• Over-ambitious EMS scope, schedule, or goals
• Insufficient labor resources or delegation of responsibility
• Poor communication
• Faulty or missing procedures
• Failure to enforce procedures
• System or equipment malfunction due to lack of monitoring or maintenance
• Inadequate training
• Inadequate EMS awareness
Examples
Washington State
University Nonconformance and Corrective and Preventive
Action Procedure
Michigan
State University Corrective and Preventive Action Procedure
Tools
EPA
New England EMS Guide
This guide was developed by EPA New England and colleges and
universities nationwide. Use it to design a cost-effective EMS
that improves
compliance and environmental performance, promotes pollution
prevention, and saves money. The guide provides a framework to
systematically identify, prioritize, manage, mitigate, and document
the environmental aspects and impacts of your school’s
activities.
PEER
Center Steps for Implementation
The information and guidance provided on this Web site is structured
to address the needs and issues that a public entity might encounter
as they prepare for, develop, and implement an EMS
Corrective and Preventive Action
for Compliance
Regulatory compliance audits, self-inspections, and measurement
and monitoring activities will occasionally reveal:
• Instances of noncompliance with regulations
• Situations that are contrary to objectives and targets
When these situations occur, corrective action must be taken to
address and rectify the causes of the noncompliance or realign
actions to meet specific objectives and targets.
Preventive
actions should be taken when breakdowns in administrative systems
and measurement
and monitoring of operational systems indicate
critical processes are not "in control." For example,
if wastewater discharge monitoring shows a steady increase in pollutant
concentrations that approach the discharge limit, preventive action
should be taken to ensure that the wastewater treatment system
is operating correctly.
Similarly, if internal hazardous waste storage self-audits indicate
improper labeling or exceedences of 90-day storage limits, corrective
action must be taken immediately to rectify the situation and preventative
action must be taken to avoid reoccurrence. In this way, the measurement
and monitoring program and preventive action are directly linked.
Measurements taken to evaluate progress toward various pollution
prevention targets (for example, microscale chemistry or product
substitution) may suggest preventive actions to ensure continued
progress.
Tools
EPA
New England EMS Guide
This guide was developed by EPA New England and colleges and
universities nationwide. Use it to design a cost-effective EMS
that improves
compliance and environmental performance, promotes pollution
prevention, and saves money. The guide provides a framework to
systematically identify, prioritize, manage, mitigate, and document
the environmental aspects and impacts of your school’s
activities.
PEER
Center Steps for Implementation
The information and guidance provided on this Web site is structured
to address the needs and issues that a public entity might encounter
as they prepare for, develop, and implement an EMS
Records
Records management enables you to prove that your school is implementing
the
EMS as designed. Records management is often viewed as bureaucratic,
but it is hard to imagine a process or system operating consistently
without keeping accurate records.
Good records
will primarily benefit the EMS team while they develop, implement,
review, and
revise the EMS. Occasionally it may be necessary
to prove the effectiveness of the EMS to people outside the school
including community organizations, environmental groups, or a “registrar” that
has been asked to certify the EMS as conformant to an environmental
standard such as ISO 14000/14001.
Examples
Washington
State University Records Retention Procedure
Washington
State University Records Retention Table
Tools
EPA
New England EMS Guide
This guide was developed by EPA New England and colleges and
universities nationwide. Use it to design a cost-effective EMS
that improves
compliance and environmental performance, promotes pollution
prevention, and saves money. The guide provides a framework to
systematically identify, prioritize, manage, mitigate, and document
the environmental aspects and impacts of your school’s
activities.
PEER
Center Steps for Implementation
The information and guidance provided on this Web site is structured
to address the needs and issues that a public entity might encounter
as they prepare for, develop, and implement an EMS
EMS Audits
After the EMS has been established, it will be critical to verify
the implementation of the system.
To identify and resolve EMS deficiencies, the EMS team must actively
seek them out.
• In
smaller schools, EMS audits are particularly relevant because
managers are often
so close to the work that they may not
see problems or bad habits that have developed.
• In larger schools, managers may develop too much distance to operations
and conditions within the school making EMS audits important.
Periodic EMS audits will establish whether or not all requirements
of the EMS are being carried out in the appropriate manner.
To ensure that your EMS audit program is effective:
• Develop audit procedures and protocols
• Establish an appropriate audit frequency
• Train your auditors
• Maintain audit records
To get started, consider the following questions:
• How frequently do we need to audit? As a rule of thumb, all parts of
the EMS should be audited at least annually. You can audit the entire EMS at
one time or break it down into discrete elements for more frequent audits.
• Who will perform the audits? You will need trained EMS auditors. Auditor
training should be both initial and ongoing. Commercial EMS auditor training
is available, but it might be more cost-effective to utilize students and faculty
as part of a planned curriculum to obtain trained auditors. EMS auditors should
be trained in auditing techniques and management system concepts.
• How should audit results be used? EMS audit results can be used to identify
trends or patterns in EMS deficiencies. The school must also make sure that any
identified system gaps or deficiencies are corrected in a timely fashion, and
that the corrective actions are documented.
The audit procedure should describe:
• Audit scope (areas and activities covered)
• Audit frequency
• Audit methods
• Key responsibilities
• Reporting mechanisms
And when implemented, should result in:
• Continuous improvement
• Consistent EMS performance
• Avoiding or minimizing surprises anticipating
• problems
Examples
Washington State University
EMS Audit Procedure
Washington
State University Audit Report Form
Washington
State University Auditor Notes Form
Michigan
State University Internal Environmental Assessment Procedure
Tools
EPA
New England EMS Guide
This guide was developed by EPA New England and colleges and
universities nationwide. Use it to design a cost-effective EMS
that improves
compliance and environmental performance, promotes pollution
prevention, and saves money. The guide provides a framework to
systematically identify, prioritize, manage, mitigate, and document
the environmental aspects and impacts of your school’s
activities.
PEER
Center Steps for Implementation
The information and guidance provided on this Web site is structured
to address the needs and issues that a public entity might encounter
as they prepare for, develop, and implement an EMS
Administration Review
Administration reviews are the key to continual improvement and
to ensuring that the EMS will continue to meet your college or
university’s needs over time. Administration review is an
opportunity to promote the value and effectiveness of the EMS and
to receive constructive feedback.
Administration
reviews are also a good opportunity to keep your EMS efficient
and cost
effective. Some organizations have found
that certain procedures and processes initially put in place were
not needed to achieve their environmental objectives or control
key processes. If EMS procedures and other activities don’t
add value, eliminate them.
Key questions to ponder during administration reviews include:
• Did we achieve our objectives and targets? (If not, why not?) Should
we modify our objectives?
• Should we set new objectives and targets?
• Is our environmental policy still relevant and current?
• Are roles and responsibilities clear and do they make sense?
• Are we applying resources appropriately?
• Are the procedures clear and adequate? Do we need others? Should we eliminate
some?
• Are we monitoring our EMS (e.g., via system audits)?
• What effects have changes in procedures, facilities, and materials had
on our EMS and its effectiveness?
• Do changes in laws or regulations require us to change some of our approaches?
• What stakeholder concerns have been raised since our last review?
• Is there a better way?
• What else can we do to improve?
• If our current EMS looked at certain departments, should we expand our
EMS to other departments or campus-wide?
• Is a new aspects or impacts analysis needed?
The following are helpful hints to ensure a successful administration
review process:
• Two kinds of people should be involved in the administration review process:
people who have the right information and knowledge (e.g., EMS Manager, Team
members) and people who can make decisions (e.g., Chancellor, Provost)
• Determine the frequency for administration reviews that will work best
for your school. Some colleges and universities combine these reviews with other
meetings (such as administration meetings) while other hold “stand-alone” reviews
• Make sure that someone takes notes on what issues were discussed, what
decisions were made, and what action items were selected.
• The administration review should assess how changing circumstances might
influence the suitability, effectiveness, or adequacy of your EMS. Changing circumstances
may be internal to your organization (for example, new facilities or new materials,
changes in administration or budgets), or may be external factors (e.g., new
laws, new scientific information, new enforcement initiatives, or changes in
adjacent land use).
• As you evaluate potential changes to your EMS, consider other organizational
plans and goals. Environmental decision-making should be integrated into your
overall management strategy.
Examples
Washington State
University Management Review Procedure
Michigan
State University Administrative Review Procedure
Tools
EPA
New England EMS Guide
This guide was developed by EPA New England and colleges and
universities nationwide. Use it to design a cost-effective EMS
that improves
compliance and environmental performance, promotes pollution
prevention, and saves money. The guide provides a framework to
systematically identify, prioritize, manage, mitigate, and document
the environmental aspects and impacts of your school’s
activities.
PEER
Center Steps for Implementation
The information and guidance provided on this Web site is structured
to address the needs and issues that a public entity might encounter
as they prepare for, develop, and implement an EMS
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