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NOT MEASUREMENT
SENSITIVE
DOE G 450.1-1
02-18-04
Implementation Guide for use with
DOE O 450.1, Environmental Protection Program
[This Guide describes suggested nonmandatory approaches for
meeting requirements. Guides are not requirements documents and
are not to be construed as requirements in any audit or appraisal
for compliance with the parent Policy, Order, Notice, or Manual.]
U.S. Department of Energy
Washington, D.C. 20585
DISTRIBUTION:INITIATED BY:
All Departmental ElementsOffice of Environment, Safety and Health
PREFACE
DOE G 450.1-1, Implementation Guide for Use with DOE O 450.1,
Environmental Protection Program is the first of a series of
guides issued to provide suggested approaches for meeting the
requirements of DOE O 450.1. DOE O 450.1 requires DOE elements
to establish an EMS that is integrated into DOE's Integrated
Safety Management System (ISMS). DOE G 450.1-1 provides an
overview of this integration process. Subsequent guides in this
series will provide details regarding the integration process.
TABLE OF CONTENTS
1. PURPOSE……………………………………………………………………………………… 1
2. APPLICABILITY AND SCOPE……………………………………………………………... 1
3. USE OF GUIDANCE………………………………………………………………………….. 1
4. INTRODUCTION……………………………………………………….…………………… 1
5. BACKGROUND ……………………………………………………………………………… 3
5.1 Integrated Safety Management Systems……………………………………………… 3
5.2 Environmental Management Systems………………………………………………… 3
5.3 ISMS/EMS………………………………………………………………………………. 4
5.4 ISMS/EMS at Closure Sites…………………………………………………………..… 5
6. INTEGRATING ENVIRONMENTAL MANAGEMENT SYSTEMS INTO INTEGRATED
SAFETY MANAGEMENT SYSTEMS…………………………………..…. 6
6.1 Policy Statement……………………………………………………………..………….. 7
6.2 Summary of ISMS/EMS Integration…………………………………..……………… 8
7. PREPARING TO INTEGRATE AN ENVIRONMENTAL MANANGEMENT SYSTEM
INTO AN INTEGRATED SAFETY MANAGEMENT SYSTEM…………………………… 13
7.1 Task 1––Selecting the ISMS/EMS Team Leader ……………………………………… 13
7.2 Task 2––Establishing the ISMS/EMS Team…………………………………………… 14
7.3 Task 3–– Conducting the ISMS/EMS Gap
Analysis………………………………….. 14
7.4 Task 4–– Defining the Scope of the
ISMS/EMS………………………………….……. 15
7.5 Task 5––Writing the Environment, Safety and Health (ES&H)
Policy……………… 16
8. INTEGRATED SAFETY MANAGEMENT SYSTEM/ENVIRONMENTAL
MANANGEMENT SYSTEM FRAMEWORKS………………………………………………. 19
8.1 Framework 1: Self-Declaration ………………………………………………………… 19
8.2 Framework 2: Third-Party Registration to ISO
14001……………………………….. 19
9. ASSESSING AND REPORTING IMPLEMENTATION OF THE MANAGEMENT
SYSTEM REQUIREMENTS OF DOE O 450.1………………………………….………….… 20
9.1 Self-Declaration……………………………………………………………………….… 20
9.2 Third-Party Registration of ISMS/EMS…………………………………………….…. 21
9.3 DOE O 450.1 Report Letter Requirement………………………………………...…… 21
ATTACHMENT 1: GAP ANALYSIS WORKSHEET
ATTACHMENT 2: DOE ISMS/EMS SELF-DECLARATION PROCEDURE
ATTACHMENT 3: ELEMENTS OF AN ISMS/EMS --DOE O 450.1
ATTACHMENT 4: GLOSSARY
ATTACHMENT 5: REFERENCES
1. PURPOSE
This document provides discretionary guidance for implementing
the requirements of Department of Energy (DOE) Order (O) 450.1,
Environmental Protection Program. DOE O 450.1 requires
implementation of sound stewardship practices that are protective
of the air, water, land, cultural and ecological resources
impacted by DOE operations, and by which DOE meets or exceeds
compliance with applicable environmental, public health and
resource protection laws, regulations and DOE requirements in a
cost-effective way. This objective is to be accomplished by
implementing Environmental Management Systems (EMSs) as part of
existing Integrated Safety Management Systems (ISMSs) established
pursuant to DOE P 450.4, Safety Management System Policy at DOE
facilities. This Guide provides suggested approaches for meeting
the requirements of DOE O 450.1.
2. APPLICABILITY AND SCOPE
This Guide is for use by all DOE elements, including the National
Nuclear Security Administration (NNSA) and contractors required
to implement DOE O 450.1.
3. USE OF GUIDANCE
DOE Guides are not requirements documents and may not be
construed as requirements in any audit or assessment of
compliance with the associated Policy, Order, Notice, or Manual.
The information in this Guide will be useful for the
implementation of DOE O 450.1, Environmental Protection Program.
This Guide provides information on acceptable methods for meeting
the requirements of DOE O 450.1. Alternatively, other methods
that are equally effective in meeting desired levels of
environmental protection and that satisfy the requirements of DOE
O 450.1 may be used.
4. INTRODUCTION
DOE O 450.1 requires DOE elements to establish an EMS that is
integrated into DOE’s ISMS. This document provides background
information, an overview of the integration process and guidance
relating to the preliminary steps that DOE sites should undertake
in order to meet the requirements of DOE O 450.1. Detailed
guidance regarding how to implement the four phases of an EMS and
guidance on subject matter topics (e.g. cultural resources,
watershed management) will be issued in the near future.
The guidance contained in this document recognizes that many DOE
sites have already implemented ISMSs and should, therefore, have
most if not all of the elements of an EMS already in place. This
document focuses on providing guidance to assist DOE sites in
identifying those missing EMS elements and integrating them into
the site's ISMS. A brief description of the primary sections of
this guide is set forth below.
The remainder of this Guide is organized as follows. Section 5,
Background, provides a brief description of EMSs, ISMSs, and an
ISMS/EMS. This section also provides a brief discussion of
implementing an ISMS/EMS at closure sites. Section 6,
Integrating Environmental Management Systems into Integrated
Safety Management Systems, explains the parallels between an EMS
and ISMS and summarizes the ISMS/EMS integration process.
Section 7, Preparing to Integrate an Environmental Management
System into an Integrated Safety Management System, provides
guidance on the preparatory tasks that a DOE site should
undertake prior to integrating an EMS into the site’s existing
ISMS. Section 8, Integrated Safety Management
System/Environmental Management System Frameworks, provides
guidance regarding possible options that DOE sites can use to
meet the requirements of DOE O 450.1. Section 9, Assessing and
Reporting Implementation of the Management System Requirements of
DOE O 450.1, provides guidance on how DOE sites can demonstrate
that its EMS meets the requirements of DOE O 450.1.
5. BACKGROUND
In April 2000, Executive Order (E.O.) 13148, Greening the
Government through Leadership in Environmental Management was
issued, requiring Federal Agencies to implement an EMS at all
appropriate facilities by December 31, 2005. Responsive to E.O.
13148, DOE issued DOE O 450.1, Environmental Protection Program,
which requires DOE elements to establish an EMS that is
integrated into the site's ISMS.
5.1 Integrated Safety Management Systems
An ISMS represents DOE’s overall umbrella framework for managing
environment, safety and health. It was developed in response to
Recommendations 95-2 and 98-1 issued by the Defense Nuclear
Facility Safety Board, and was implemented at virtually all DOE
sites by October 2000. The framework for ISMS is provided in DOE
P 450.4, Safety Management System Policy, and guidance is
provided in DOE G 450.4-1B, Integrated Safety Management System
Guide. In addition, ISMS is incorporated in DOE contracts
through several Department of Energy Acquisition Regulations
(DEAR) clauses. Within ISMS, the term “safety” is defined to
encompass environment, safety, and health, including pollution
prevention.
5.2 Environmental Management Systems
An EMS is a systematic and structured approach for addressing the
environmental consequences of an organization's activities,
products and services. DOE O 450.1 defines an EMS as “a
continuous cycle of planning, implementing, evaluating, and
improving processes and actions undertaken to achieve
environmental missions and goals." Although several recognized
EMS frameworks exist, most are based on the International
Organization for Standardization (ISO) 14001 EMS standard. As a
result, ISO 14001 is the framework upon which organizations most
frequently choose to base their EMS, and, this is proving to be
the case with U.S. Federal facilities. However, DOE O 450.1 does
not prescribe the type of EMS framework that DOE elements must
use (see attachment 3 of this Guide for a list of the EMS
elements required by DOE O 450.1).
The basic ISO 14001 EMS model (see Figure 1) consists of the
following four phases:
Phase I: Planning
The organization identifies how its operations interact with the
environment and develops objectives and programs to manage these
interactions/environmental aspects.
Phase II: Implementation and Operation
The organization implements programs to manage environmental
interactions/aspects, as well as other procedures for general
system administration.
Phase III: Checking and Corrective Action
The organization assesses the effectiveness of the programs it
established to manage environmental interactions/aspects, in
addition to general system operational effectiveness.
Phase IV: Management Review
Senior management determines what changes to the EMS are
necessary based on a performance assessment of the system’s
effectiveness (Phase III).
Phase IV may indicate that adjustments to programs, objectives
and procedures are necessary. Output from this phase is fed back
into Phase I, Planning, to make necessary changes and additions
designed to bring the EMS to the desired level of effectiveness.
This system feedback propels the continual improvement of the
EMS.
The EMS continually moves through this cycle, fine-tuning its
management of those areas of the organization’s operations that
interacts with the environment. This continual improvement cycle
is a core tenet of the EMS that allows the system to adapt to the
dynamic nature of the organization’s operations.
Implementing an EMS brings a number of benefits to DOE sites. It
will enable sites to cost-effectively protect the environment
while executing their primary organizational missions. The
inherent flexibility provided by these EMS elements allow users
to implement an EMS at facilities of varying size, complexity,
and missions, whether they be offices, laboratories, facilities,
programs or agencies. Moreover, the EMS provides consistency and
reliability in the management, assessment, and continuous
improvement of environmental programs and controls. Finally, in
contrast to crisis management, an EMS approach incorporates top
management involvement, employee participation and other
mechanisms that shift the culture of the organization towards the
establishment of the environmental ethic that results in the
continual improvement of environment, safety, and heath
performance.
5.3 ISMS/EMS
DOE O 450.1 requires DOE elements to ensure that site ISMSs
include an EMS which meets several listed requirements. In those
instances where ISMS is not applicable, DOE elements must ensure
the implementation of an EMS. The integration of an EMS into an
ISMS (hereinafter referred to as ISMS/EMS) provides a unified
strategy for the management of resources, the control and
attenuation of risks; and the establishment and achievement of
the organization's environment, safety and health goals. The
ISMS/EMS should be viewed as an enhancement of ISMS that adds
those EMS elements not previously included in the ISMS. For
example, elements dealing with document control and records
management have already been integrated into the ISMS and need
not be replicated. The elements dealing with the identification
of significant environmental aspects on the other hand may need
to be added to the ISMS. Ultimately, the ISMS/EMS is intended to
fully address the environment, safety, and health risks at DOE
sites.
5.4 ISMS/EMS at Closure Sites
Several sites within the DOE complex are designated as closure
sites, i.e., sites that have ceased operations and have
identified near term closure activities and schedules. Most of
the sites are conducting clean up and closure activities under
the regulatory requirements of the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA), or other legal
agreements with the Environmental Protection Agency (EPA) and/or
state environmental agencies.
A site conducting near term closure activities may have most of
the elements of the ISMS/EMS available or completed. For
example, identification of significant environmental aspects and
impacts may have been identified in the Remedial
Investigation/Feasibility Study (RI/FS) process under CERCLA.
Environmental Impact Statements conducted pursuant to the
National Environmental Policy Act (NEPA) may also yield important
information.
Sites in the near term closure phase should consider how well
environment was integrated in their existing ISMS and use a
graded approach to supplement their existing ISMS to meet the
requirements of DOE O 450.1.
6. INTEGRATING ENVIRONMENTAL MANAGEMENT SYSTEMS INTO INTEGRATED
SAFETY MANAGEMENT SYSTEMS
ISMS and EMS both strive for continual improvement, through a
plan-do-check-act cycle. This cycle calls for defining the scope
and purpose of the system, followed by a planning (plan) step to
develop programs and procedures that must then be implemented
(do). Once implemented, programs must be assessed (check) and
any problems corrected (act) to improve the effectiveness of the
management system, and to achieve improved environment, safety
and health performance.
An EMS should consist of the following elements:
· Environmental Policy Statement
· Planning
· Implementation and Operation
· Checking and Corrective Action
· Management Review
Under ISMS, the term "safety" also encompasses health and
environment (DOE Policy 450.4). Therefore, the guiding
principles and core functions in ISMS are as applicable to the
protection of the environment and protection of employee health,
as they are to safety. The ISMS Guiding Principles and Core
Functions are:
Guiding Principles
· Line management responsibility for environment, safety and
health
· Clear roles and responsibilities
· Competence commensurate with responsibilities
· Balanced priorities
· Identification of environment, safety and health standards
and requirements
· Hazard controls tailored to work being performed
· Operations authorization
Core Functions
· Define scope of work
· Analyze hazards
· Develop and implement hazard controls
· Perform work within controls
· Provide feedback and continuous improvement
This section provides a description of the similarities between
EMSs and ISMSs and provides a summary of the integration of these
two systems. Figure 2 depicts how EMSs and ISMSs relate to each
other.
Figure 2. Overlap of ISMS Core Functions and EMS
6.1 Policy Statement
An environmental policy statement addresses several of the core
management system themes, such as:
Ø Showing clear management commitment is a critical element of
nearly all recognized EMSs, and essential in practice for an
effective EMS. A policy statement sends a message to employees,
contractors, suppliers, regulators, and the general public that
management is committed to the system.
Ø The policy statement can be the core framework for the
entire EMS. It sets out the broad principles such as regulatory
compliance, pollution prevention, and continual improvement; it
describes the approaches by which principles will be achieved and
communicated to interested parties.
Ø Although organizations usually measure their EMS performance
by assessing progress toward reducing identified environmental
risks, it is the environmental policy that usually provides the
ultimate benchmark of the system's performance. In a periodic
management review, the ultimate question is whether the system is
achieving the principles and spirit of the policy.
The core functions and guiding principles of ISMS do not address
the development of a policy statement. However, it is not
inconsistent with the principles of ISMS to develop an
environment, safety and health (ES&H) policy statement. As part
of the integration of EMS into ISMS, senior management should
issue a policy statement for a site or facility addressing
environment, safety and health. Further guidance on what a policy
statement should contain and how it may be developed is provided
in section 7.5.
6.2 Summary of ISMS/EMS Integration
Section 4.a. of DOE O 450.1 requires that all DOE elements must
ensure that a site’s ISMS/EMS does the following:
(1) Provides for the systematic planning, integrated
execution, and evaluation of programs for:
· Public health and environmental protection
· Pollution prevention (P2)
· Compliance with applicable environmental protection
requirements
(2) Includes policies, procedures, and training to identify
activities with significant environmental impacts , to manage,
control, and mitigate the potential impacts of these
activities, and to assess performance and implement corrective
actions where needed.
(3) Includes measurable environmental goals, objectives, and
targets that are reviewed annually and updated when
appropriate.
A complete list of all EMS elements required by the Order to be
included in a site's ISMS/EMS are contained in attachment 3 of
this Guide.
To comply with the requirements of DOE O 450.1, the ISMS/EMS team
(see section 7.2 for information on establishing an ISMS/EMS
team) should progress through a typical EMS implementation
schedule, integrating EMS elements into the existing ISMS where
needed. The four major phases of this process are:
1. Planning
2. Implementation and Operation
3. Checking and Corrective Action
4. Management Review
Each of these four phases consists of steps that integrate EMS
elements into a site's existing ISMS. This process should be
carried out step-by-step for implementation to be efficient and
for the ISMS/EMS to operate as expected. There are ten steps that
comprise the four phases of implementation (see Figure 3). This
section of the guide discusses the similarities between the four
phases of EMS implementation and the guiding principles and core
functions of ISMS (see Figure 4 for a description of the major
parallels between ISMS and EMS). This section also provides a
brief summary of the steps in each phase as an overview of the
entire integration process. Detailed guidance on the steps in
each phase will be issued in the near future. For definitions
see Attachment 4 of this Guide.
Figure 3. ISMS/EMS Integration Road Map
6.2.1 Phase I --Planning
Section 4.a. (1) of DOE O 450.1 requires that DOE site ISMSs
include an EMS that provides for systematic planning, integrated
execution, and evaluation of programs for public health and
environmental protection, pollution prevention (P2), and
compliance with applicable environmental protection requirements.
The planning function of EMS can be addressed in the first three
core functions of ISMS: define the scope of work, analyze the
hazards, and develop and implement hazard controls.
Part of the planning process under section 4.a.(3) of DOE O 450.1
is the identification of measurable environmental goals,
objectives, and targets. This requirement parallels the process
of developing and implementing hazard controls under ISMS where
certain hazards (or impacts) are identified for special focus and
management in order to achieve continual improvement. These
hazards and impacts are monitored to establish whether objectives
and targets are being achieved as planned.
Step 1––Identifying Environmental Aspects
Identify how the activities, products, and services of the
organization may interact with the environment. For example,
some activities can cause ground water contamination as a result
of spills; others may create habitats for flora and fauna. These
potential interactions (e.g., spills, habitat creation) are
environmental aspects (ground water contamination and increased
diversity of flora and fauna are the impacts).
Step 2––Determining Significant Aspects
For each environmental aspect, determine the consequence of its
occurrence and the likelihood that it will occur. Combined,
these two characteristics describe the potential impact of an
environmental aspect. Next, an organization should determine
whether the environmental aspect is significant. Significant
environmental aspects are those aspects that have or could have a
significant impact on the environment, the organization, or to
the organization's mission.
Step 3––Setting Measurable Environmental Goals, Objectives and
Targets
Set measurable goals, objectives and targets which address all
significant environmental aspects and achieve the commitments
made in the ES&H policy (e.g., pollution prevention goals, such
as reductions in waste generation and releases to the
environment).
6.2.2 Phase II--Implementation and Operation
In an EMS, implementation and operation includes developing and
maintaining programs and procedures, conducting training,
establishing operational controls, and other elements. This EMS
element is addressed in ISMS core functions three and four:
develop and implement hazard controls, and perform work within
controls. Training is also addressed in ISMS guiding principle
three: competence commensurate with responsibilities. The
results of an EMS gap analysis should assist a site in
determining the extent to which existing ISMS elements satisfy
the requirements of DOE O 450.1 or whether they will need
additions or amendments (see section 7.3 for a discussion on
conducting a gap analysis).
Step 4––Documenting the ISMS/EMS
The ISMS description should be modified to make reference to
additional documents and procedures developed in order to ensure
that the elements of an EMS are integrated into the site's ISMS.
Step 5––Developing Environmental Management Programs (EMPs)
As needed, develop or revise existing programs to include plans
for the achievement of measurable goals, objectives and targets.
These programs should specify the resources (human and financial)
designated for specific activities, controls, and procedures
needed to achieve the goals, objectives and targets.
Step 6––Developing Operational Controls
As needed, develop or revise existing operational controls.
Operational controls can be either administrative or engineering
controls and are used to control potential environmental impacts.
For example, operational controls could be applied to
transporting waste drums to reduce the opportunity for spills.
Adherence to these controls will support the achievement of
goals, objectives and targets.
Step 7––Developing ISMS/EMS Procedures
In many cases, DOE sites will not need to develop new procedures,
but can use existing ISMS procedures or revise them to include
missing EMS elements. For example, a site may need to develop
procedures on how to identify environmental aspects.
6.2.3 Phase III--Checking and Corrective Action
In an EMS, checking and corrective action includes maintaining
procedures to monitor and measure the characteristics and
progress of the EMS on a regular basis. This element is
addressed in the fifth ISMS core function, provide feedback and
continuous improvement. The ISMS description (DEAR 970.5223-1)
requires the contractor to provide feedback on the adequacy of
operational controls, on continuing to improve ES&H management,
and on measuring system effectiveness. Again, the results of a
gap analysis should assist sites in determining whether any
revisions need to be made to existing feedback and corrective
action processes.
Step 8– Establishing the ISMS/EMS Assessment Program
The site's existing ISMS assessment program should be modified to
include a structured, formal self assessment of all elements of
the ISMS/EMS, including the level of implementation and
operational effectiveness of procedures, programs, and controls,
in addition to the level of progress made toward objectives and
targets. Assessments should identify non-conformity, root
causes, trends, and corrective actions. Assessments should also
be consistent with DOE P 450.5, Line Environmental, Safety and
Health Oversight.
6.2.4 Phase IV Management Review
An EMS management review is a periodic assessment (at a pre-
determined frequency) by senior management of how well the
management system is functioning, and whether the established
environmental goals, objectives and targets are being achieved.
This EMS element is covered in the fifth ISMS core function:
provide feedback and continuous improvement. The adequacy,
suitability and effectiveness of the management system processes
should be reviewed for opportunities to improve the system’s
effectiveness. DEAR clause 970.5223-1 requires an annual review
of the ISMS by the contractor and by DOE; this review should
assess the adequacy, suitability and effectiveness of the
ISMS/EMS. The gap analysis will ascertain whether other
provisions for this element are needed.
Step 9––Developing the Management Review Process
Develop a process whereby management can assess ISMS/EMS
performance based on available evidence and make decisions that
drive continual improvement of the system. Present management
with findings and analysis that fully describes ISMS/EMS
performance elements, such as the effectiveness of the ISMS/EMS,
overall improvement of environmental performance, successful and
unsuccessful programs, non-conformity with procedures and
operational controls and the level of achievement of objectives
and targets. This process should be integrated with the annual
ISMS review.
Step 10 - Developing a Plan to Keep the ISMS/EMS Updated
Develop a plan including a schedule to review and update, as
needed, all elements of the ISMS/EMS. In addition, develop
approaches to maintaining the momentum of the ISMS/EMS including
management involvement and employee participation and interest
(See also DOE G 450.4-1B, Chapter IV).
Figure 4. Major parallels between ISMS and EMS
Integrated Safety Management Environmental Management
System System
Ø Policy
PLAN Analyze Hazards Planning
Ø Identification of Safety Ø Environmental Aspects
Hazards and Requirements § Determine Significant
§ Analyze Hazards Aspects
Ø Safety Standards and Ø Legal and other
Requirements Requirements
Ø Balanced Priorities Ø Measurable
Ø Line Management Environmental Goals,
Responsibility Objectives and Targets
Ø Clear Roles and Ø Environmental
Responsibilities Management Programs
DO Develop & Implement Hazard Implementation & Operation
Controls
Ø Hazard Controls Tailored Ø Structure and
to Work Responsibility
Ø Perform Work Within Ø Training, Awareness
Controls and Competence
Ø Clear Roles and Ø Communication
Responsibilities Ø Document EMS
Ø Competence Commensurate Ø Document Control
with Responsibilities Ø Operational Control
Ø Emergency Preparedness
and Response
CHECK Provide Feedback & Continuous Checking & Corrective
Improvement Action
Ø Provide Feedback on Ø Monitoring and
Adequacy of Controls Measurement
Ø Continuous Improvement Ø Nonconformance
in Defining and Planning Work Corrective./Preventive.
Action
Ø Records
Ø EMS Audit/Self
assessment
Ø Management Review
Ø Continuous Improvement
ACT Annual ISMS Review Management Review
Ø Continuous Improvement Ø Continuous Improvement
7. PREPARING TO INTEGRATE AN ENVIRONMENTAL MANAGEMENT SYSTEM
INTO AN INTEGRATED SAFETY MANAGEMENT SYSTEM
Integrating EMS elements into ISMS will lead organizations to
follow much the same process they would if implementing a
freestanding EMS.
There are some important preparatory tasks that an organization
should carry out initially to facilitate the ten steps to full
integration, including:
Preparatory tasks
Task 1 - Selecting the ISMS/EMS team leader
Task 2 - Establishing the ISMS/EMS team
Task 3 - Conducting the ISMS/EMS Gap Analysis
Task 4 - Defining the Scope of the ISMS/EMS
Task 5 - Writing the ES&H policy statement
These tasks can have a substantial impact on the efficiency of
implementation and the value provided by the ISMS/EMS.
Therefore, it is critical that they be carefully considered and
completed.
7.1 Task 1––Selecting the ISMS/EMS Team Leader
DOE Operations/Field/Site Office Managers and cognizant
contractor management should select the team leader for their
organization or site. These managers should also choose the
remainder of the ISMS/EMS integration team.
The team leader should be selected for his or her knowledge of
site operations, EMS, ISMS, and existing ES&H controls. He or
she should preferably be someone with leadership skills necessary
to promote an initiative that requires cooperation, coordination,
and change management across the many entities, functions and
interests at a DOE site. Some of the characteristics of a
suitable ISMS/EMS team leader include:
C Employee trust
The team leader should be someone the employees trust,
relate to, and feel comfortable with.
C Management trust
The team leader should be someone that senior management
trusts to make wise decisions and wise, pragmatic use of
resources including employee time.
C Energy and creativity
The team leader should be energetic and creative in leading
the team and ultimately the entire organization in
investigating the environmental consequences of the
organization’s activities, products and services, and
implementing procedures and programs as part of a system
that establishes the environmental ethic and works
continuously to address the environmental impacts of the
organization.
C Confidence and organizational skills
The team leader should be someone who has confidence and
organizational skills to lead and direct the ISMS/EMS team.
7.2 Task 2––Establishing an ISMS/EMS Team
Senior management will need to establish site ISMS/EMS teams
drawn from a cross-section of internal functions, to take on the
responsibility for developing the ISMS/EMS. The team size and
makeup will vary by individual sites and should include those
individuals that have knowledge of site operations, those with
extensive understanding of EMS and ISMS, and those with
experience of environmental programs and issues. The team can
include representatives from the appropriate program offices,
environmental, health and safety, quality, personnel, legal,
documents and records management, communications, facilities, and
design functions among others.
7.2.1 ISMS/EMS Team Training
Once the team is established, team members should review
available information on the elements of EMS, ISMS, and the
requirements and approaches for integration. Many commercial, as
well as government training organizations offer training on EMSs.
7.3 Task 3––Conducting the ISMS/EMS Gap Analysis
As a first step, the ISMS/EMS team should conduct a gap analysis
to establish the existing site EMS baseline. This is achieved by
comparing the requirements set out in DOE O 450.1 against
existing site management system descriptions, policies and
procedures. The gap analysis will determine what EMS elements are
already in place, and to what degree EMS requirements are
addressed by existing ISMS procedures. For example, the gap
analysis will determine whether there is a documented procedure
for providing training, and whether programs and procedures are
effectively integrated and operating as parts of a comprehensive,
coordinated system. Having done this comparison, the ISMS/EMS
team can determine which elements must be expanded, supplemented
or established to fully conform to DOE O 450.1. (Note that this
gap analysis does not identify the organization’s environmental
aspects; this is done later, in the early stages of planning .)
In general the gap analysis should:
C Assess whether existing programs, procedures and controls
fully address the EMS elements required by DOE O 450.1.
C Identify any need for new or revised programs and
procedures.
C Establish whether the significant environmental aspects
(operational influences on the environment) of site/organization
activities, products or services have been identified.
C Identify whether measurable goals, objectives and targets
have been established to address the significant environmental
aspects of the site’s activities products and services.
Attachment 1 provides an example of a gap analysis questionnaire
that is based on the ISMS/EMS integration process discussed in
Section 6 and which also includes requirements from DOE O 450.1.
The gap analysis may include more detailed questions to assess
the operational status of system components and other
arrangements for regulatory compliance or for control of
environmental exposures. DOE sites have the option of conducting
a gap analysis as part of their annual ISMS review.
7.4 Task 4––Defining the Scope of the ISMS/EMS
7.4.1 Organizational Scope
Organizational scope refers to the set of facilities or
activities covered by an ISMS/EMS. DOE O 450.1 does not
prescribe the organizational scope of an EMS that is integrated
into a site’s ISMS. An ISMS/EMS may include one or more
geographic sites within one management organization. For
example, Western Area Power Administration has implemented an EMS
for its entire system across 15 states, the Strategic Petroleum
Reserve’s ISMS/EMS covers sites in Louisiana and Texas, and the
Kansas City Plant's EMS covers one single large building. On the
other hand, separate major contractors at Hanford each have a
separate ISMS/EMS. The organizational scope of the ISMS/EMS
should usually parallel the scope of the existing ISMS.
The ISMS/EMS should include all activities that occur within that
scope, including DOE field offices, contractors (with appropriate
flow-down to subcontractors), and other tenant organizations. The
ISMS/EMS at the Savannah River Site includes the DOE field
office, all DOE facilities on site, the Savannah River Ecology
Laboratory, the U.S. Forest Service activities on site, and the
General Services Administration activities on the site.
Implementation of an ISMS/EMS at a large site with multiple, semi-
autonomous divisions may best be approached by taking advantage
of the divisional structure on the site. This approach was
successfully employed at Brookhaven National Laboratory. The
ISMS/EMS was developed centrally for the entire laboratory and
many of the functions of the ISMS/EMS, such as document control
and records management were executed through a centralized, on-
line management system. However, each division was given
responsibility to analyze its own separate activities, products
and services, to identify the environmental aspects that were
present in those activities, products and services, to select
those aspects that were significant, and importantly to define
their environmental management programs (EMPs) and all the detail
that go into them such as operational controls, objectives and
targets, performance indicators, roles, authorities and
responsibilities, and training needs. These divisional sub-
systems were tested and approved individually (primarily through
third-party audits) and were later integrated into a site-wide
ISMS/EMS, although each division still retains responsibility for
its own environmental aspects and the EMPs that address those
aspects.
Where separate ISMS/EMS systems exist for different entities on
one site, the ISMS/EMS documentation should clearly identify the
organizational and geographic boundaries to indicate that which
is included and that which is not included in the ISMS/EMS. The
ISMS/EMS team should review this documentation to ensure that all
site-wide issues and cumulative impacts are addressed and that no
activities or impacts are overlooked.
7.4.2 Subject Matter Scope
The ISMS/EMS should address all of the subject matter areas
covered in section 4.b.(1) of DOE O 450.1, (e.g. cultural
resource protection, watershed management) unless they are not
applicable to the site. If they are not applicable, a site is
expected to make an affirmative declaration that certain subject
matter areas are not applicable. The subject matter areas
identified in DOE O 450.1 constitute the minimum scope of
“environment” for the purposes of an ISMS/EMS. For example, if
site activities have the potential to affect cultural resources,
then cultural resources should be included within the policies,
programs and procedures of the ISMS/EMS. Potential impacts to
cultural resources should be identified, appropriate programs and
controls should be established, and monitoring and feedback on
the accomplishment of objectives and targets should be provided.
If the site’s operations do not affect any cultural resources,
the ISMS/EMS should note that the issue was considered but found
unnecessary to include. Additional guidance will be provided in
the near future on subject areas covered by DOE O 450.1.
7.4.3 Closure Sites
A graded approach may be the best process to implement the
ISMS/EMS at a closure site. For example, the Fernald
Environmental Management Project (FEMP) shut down production
activities in 1989. The clean up is being conducted under
CERCLA, and in accordance with approved Records of Decision
(RODs), workplans and legal agreements with EPA and the State of
Ohio. Completion of clean up is scheduled for 2006. Much of the
systematic approach of an EMS is realized through the CERCLA
investigation, planning, stakeholder review, implementation and
monitoring process.
The major elements of an ISMS/EMS are: planning, implementation
and operation, checking and corrective action, and management
review and are discussed in Section 6 of this Guide. For
example, identifying environmental aspects and impacts, which is
part of your planning element, may have been accomplished during
the RI/FS process. The site’s objectives and targets, which are
also part of the planning element, may have been determined
through pathway analysis and establishment of clean up levels and
programs/activities approved in RODs and workplans. Elements of
implementation and operation and checking and corrective action
would be part of the site’s CERCLA clean up program. Closure
sites may be further along in the implementation of many elements
of an ISMS/EMS than many operating sites. They have conducted
extensive planning and analysis activities that can be
incorporated into their ISMS/EMS.
7.5 Task 5––Writing the Environment, Safety and Health (ES&H)
Policy Statement
Each site implementing an ISMS/EMS should develop an ES&H Policy
Statement. The policy statement should reflect the nature and
scale of the organization’s activities, products and services and
embody the organization’s commitment to:
C Compliance with laws and applicable requirements
C Pollution Prevention
C Continual improvement of the management system and of ES&H
performance
C Integration of environmental accountability into decision
making processes
The understanding gained in the training, in conducting the gap
analysis, and in developing the ISMS/EMS scope will assist the
ISMS/EMS team in its development of the ES&H Policy Statement.
Sites may also base their ES&H Policy Statement on any existing
ISMS policy statements or other policy statements at the site.
The site ES&H Policy Statement should express management’s
commitment to identifying and addressing potential environmental,
safety and health risks from site activities. The site’s ES&H
Policy Statement should serve as a framework for setting and
reviewing a facility’s environmental goals, objectives and
targets. The ISMS/EMS team should review and reference as
appropriate, DOE policies, listed below and implemented through
DOE Orders (particularly DOE O 450.1, Environmental Protection
Program) to develop the site's ES&H Policy Statement.
C DOE P 450.1, Environment, Safety and Health Policy for the
Department of Energy Complex
C DOE P 450.2A, Identifying, Implementing and Complying with
Environment, Safety and Health Requirements
C DOE P 450.4, Safety Management System Policy
C DOE P 450.5, Line Environment, Safety and Health Oversight
C DOE P 450.6, Secretarial Policy Statement: Environment,
Safety and Health
C DOE P 141.2, Public Participation and Community Relations
The following are examples of language that can be used in policy
statements to address various environmental areas applicable to
DOE sites:
C Regulatory Compliance
We will identify and comply with all applicable
environmental laws and regulations at each location where we
conduct business.
C Pollution Prevention
We will seek, first, to cost effectively avoid the
generation of pollution and waste from our processes and
services, and, second, to manage remaining waste through
safe and responsible methods and vendors. We will also seek
to avoid the release of hazardous substances into the
environment by using environmentally preferable products in
our processes and services whenever costeffectively
feasible.
C Conservation
We will strive to diminish our consumption of natural
resources through cost-effective reuse of materials and use
of recycled-content materials and conservation of energy and
water.
C Emissions and Effluents
We will work to reduce our emissions and effluents by
employing cost-effective operational controls, by diligently
monitoring operational indicators to determine when
corrective actions are needed, and by implementing
corrective and preventive actions whenever necessary.
C Design for Environment
We will develop or procure products that have been designed
to prevent pollution and that are safe for their intended
use, efficient in their use of energy, protective of the
environment, and that can be recycled or disposed of safely.
X Responsible Neighbor
We will be an environmentally responsible neighbor in the
communities where we operate and act quickly and responsibly
to correct incidents or conditions that endanger health,
safety, or the environment, report them to authorities
promptly, and inform everyone who may be affected by them.
C Cultural Resources
We will be attentive in our operations and activities to
avoid unnecessary harm to cultural resources (e.g., an
action that threatens, disturbs, damages, or destroys
historic properties, cultural landscapes, cultural items,
archeological resources, Indian sacred sites, cemeteries)
C Organizational Planning
We will incorporate environmental considerations into our
organizational planning processes.
C Responsible Partnerships
We will work with stakeholders to address mutual
environmental concerns and will encourage suppliers,
vendors, and contractors to comply with similar
environmental protection goals.
C Ecology, Habitats, Endangered Species
We will be attentive in our operations and activities to
avoid unnecessary harm to endangered species, natural
habitats and ecologically sensitive areas.
C Communication
We will communicate this policy to all employees and make it
available to the public and our stakeholders, and consider
public input, and incorporate or otherwise respond to
stakeholder views when making decisions. We will also alert
potentially affected individuals and authorities of any
environmental incident in a timely manner in order to
empower participation at appropriate stages of the decision
making process.
It may be appropriate for the Program Secretarial office, the
head of a DOE field office, and the head of a DOE contractor
organization to each issue a policy statement, with appropriate
scope. Alternatively, the DOE field office and contractor can
jointly issue a policy statement. Once senior management has
endorsed the policy statement, it should be communicated to all
staff and made available to the public. DOE sites should use
existing mechanisms to communicate the policy statement to its
staff and the public.
8. ISMS/EMS FRAMEWORKS
DOE O 450.1 does not require DOE elements to implement any
specific EMS model or standard. The Order does include the EMS
elements (see attachment 3 of this Guide) that are required to be
included in an ISMS/EMS. DOE elements implementing the
requirements of the Order may opt to use the ISO 14001 standard
or any other model that meets the requirements of the Order. To
ensure a high-level commitment to the establishment of the EMS
portion of ISMS, Program Secretarial Officers, the Administrator
for the National Nuclear Security Administration, and
Administrators for the Power Administrations, in consultation
with DOE Operations/Field/Site Office managers should make the
decision regarding whether a DOE site's EMS will follow the ISO
14001 standard or another EMS framework. Regardless of which
model is chosen, the EMS elements must still be compatible with,
and integrated into, the site ISMS.
Section 3.a. (2) of DOE O 450.1 provides for those instances
where requirements for ISMSs are not applicable. In those cases
DOE elements must ensure the implementation of EMSs. These DOE
sites have the choice of using one of the implementation
frameworks discussed below, but do not have to integrate their
EMS with ISMS.
8.1 Framework 1: Self-Declaration
A DOE site can implement the elements of an EMS, within the
context of its existing ISMS, which meets all the requirements of
DOE O 450.1. The site can then self-declare conformity of its
ISMS/EMS to the requirements of the Order (see section 9.1 for
details on self-declaration). When selecting framework 1 or 2,
DOE sites should clearly define the elements of the EMS as part
of their ISMS.
8.2 Framework 2: Third-Party Registration to ISO 14001
A DOE site can implement the elements of an ISO 14001 EMS, within
the context of its existing ISMS, which meets all the
requirements of DOE O 450.1. The site may then seek third-party
registration (see section 9.2 for details on third-party
registration). Several DOE sites have already chosen this
course, although it is not required by DOE O 450.1.
9. ASSESSING AND REPORTING IMPLEMENTATION OF THE MANAGEMENT
SYSTEM REQUIREMENTS OF DOE O 450.1
DOE O 450.1 requires Program Secretarial Officers, the
Administrator for the National Nuclear Security Administration,
and Administrators for the Power Administrations to ensure that
by December 31, 2005, all sites under their purview have
implemented the management system requirements of the Order
(section 5.c.(1)). Managers of DOE Operations, Field, or Site
Offices are required by the Order to report by December 31,
2005, to the Cognizant Secretarial Officer the status regarding
whether the EMS requirements of DOE O 450.1 have been integrated
into ISMSs by site contractors (section 5.d.(1)). This section
provides guidance regarding how a DOE site can demonstrate that
it has an ISMS/EMS that meets the requirements of the Order.
9.1 Self-Declaration
As discussed in Section 8, DOE sites may choose between two
frameworks for declaring conformity to the Order. Under framework
1, DOE sites can self-declare conformity with the requirements of
DOE O 450.1 and under framework 2, DOE sites obtain third-party
registration to ISO 14001.
Self-declaration means that a site has determined that it fully
conforms to the requirements of DOE O 450.1 and publicly asserts
that it conforms to the Order. To be credible, the
self-declaration process should be based upon a conclusion of
conformity reached after the organization has completed an
internal environmental management system evaluation, and
determined that its ISMS/EMS conforms to the requirements of the
Order.
DOE sites should use a self-declaration procedure which provides
for effective and objective assessment of the ISMS/EMS in a
manner that not only ensures the system meets the requirements of
DOE O 450.1, but that is also designed for ongoing evaluation and
continual improvement. The process must also be transparent and
provide credibility to interested parties. The evaluation should
be thorough and systematic.
The Office of Environment, Safety and Health (EH) has developed a
self-declaration procedure that DOE sites may use (attachment 2
of this Guide). This procedure was developed pursuant to the
Agency Self-Declaration Protocols for Appropriate Federal
Facilities, September 10, 2003, which was developed by the E.O.
13148 Interagency Working Group. This procedure should be used
in conjunction with attachment 3, Elements of an ISMS/EMS-DOE O
450.1, which contains the EMS elements required by DOE O 450.1 to
be included in a site's ISMS/EMS. Attachment 3 can also be used
to develop an evaluation checklist or lines of inquiry that can
be used during the evaluation.
Alternatively, sites may use other self-declaration procedures
that credibly establish and document that they have an EMS that
conforms to the requirements of DOE O 450.1. For example, sites
may use existing review/evaluation/audit processes already
established under ISMS. However, sites using this option must
comply with the reporting requirements of sections 5(d)(1) of DOE
O 450.1 and should prepare a report letter pursuant to section
9.3.1 of this guide. Sites using this option should also prepare
a self-declaration statement that can be publicly issued on its
site web site (see attachment 2 for a sample statement).
9.2 Third-Party Registration of ISMS/EMS
Third-party registration of a site’s ISMS/EMS is an option that
DOE sites may choose. A DOE entity may choose to include several
related sites under one registration. Third-party registration is
not a requirement of DOE O 450.1. An ISMS/EMS that conforms to
all the requirements of the ISO 14001 Standard may be registered
by an independent third-party registrar. However, this ISMS/EMS
must still meet all the requirements of the Order.
Registration is based on an audit by an independent, third party
registrar, and lasts for three years. During this period, the
registrar will conduct periodic verification audits. Renewal
after three years is based on the assessment of the registrar
that may or may not include another full audit.
9.3 DOE O 450.1 Report Letter Requirement
This section outlines the information that should be included in
the Report Letter from the Operations, Field, or Site Office
Manager to the Cognizant Secretarial Officer by December 31,
2005, (pursuant to section 5.d. (1)) reporting whether the EMS
requirements of DOE O 450.1 have been implemented and integrated
into the site’s ISMS.
9.3.1 Report Letter––Framework 1
If the site ISMS/EMS is not third-party registered, the report
letter should include an affirmation by the
Operations/Site/Field Office Manager that the site has
implemented an ISMS/EMS, which meets the requirements of DOE O
450.1 and that the following has been reviewed:
a. ES& H (or environmental) policy statement
b. Current approved ISMS description (including ISMS/EMS)
c. Current list of significant aspects
d. Current list of measurable environmental goals,
objectives, and targets
Supporting documentation must be available on request by the PSO
or EH or the Office of Independent Oversight and Performance
Assurance, but need not be attached to the letter.
9.3.2 Report Letter––Framework 2
If the site ISMS/EMS is third-party registered to the ISO 14001
Standard, the report letter from the Operations/Site/Field Office
Manager should include the following:
1. The name and address of the third-party registrar, the date
of registration audit, and the date of the most recent
verification audit.
2. An affirmation by the Operations/Site/Field Office Manager
that the site has implemented an ISMS/EMS, which meets the
requirements of DOE O 450.1.
GAP ANALYSIS WORKSHEET
Instructions: The left column of this worksheet includes all the
requirements needed to conform to the elements of an EMS and DOE
O 450.1. The right column has been left blank so that a DOE site
can describe how each EMS element is covered under the site's
ISMS or other relevant management system (including an existing
EMS). All identified gaps should be identified in the right
column.
EMS ELEMENTS Gaps Remaining after
(Based on Elements of an EMS and Comparison to ISMS
DOE O 450.1)
Environmental Policy
An environmental policy has been
developed by senior management
that includes the following:
C It is appropriate for the
nature, scale, and environmental
impacts of the site’s activities,
products, and services.
C It includes a commitment to
continual improvement in the
prevention of pollution.
C It includes a commitment to
comply with relevant environmental
legislation, regulations, and
requirements.
C It includes a commitment to
promote long-term stewardship of
the site’s natural and cultural
resources.
C It provides a framework for
setting and reviewing
environmental objectives and
targets.
C It is documented,
implemented, and maintained.
C It has been communicated to
all employees.
C It is available to the public
Planning (Phase I)
The EMS does the following:
§ Provides for the systematic
planning of programs for pollution
prevention.
§ Provides for the systematic
planning of programs for public
health and environmental
protection.
Environmental Aspects
C A procedure exists to
identify environmental aspects and
determine which have significant
impacts on the environment.
C Procedure includes
consideration of existing NEPA
documentation to identify impacts.
C Procedure promotes use of a
comprehensive analysis that (1)
accounts for all sources of
release and contamination, (2)
assesses composite impacts (e.g.
impacts to al1 media from
radiation) of operations and
activities and their implications
for near- and long-term
environmental management of the
site with regard to legal
requirements and environmental
performance objectives; (3)
integrates with other relevant
site-wide natural and cultural
resource processes (e.g., existing
land use planning processes) to
ensure consistent management
criteria are used throughout the
site.
C Significant aspects are
considered when setting
environmental objectives.
C This information is kept up-
to-date.
Legal and Other Requirements
C A procedure exists to
identify and have access to legal
and other requirements pertaining
to environmental aspects.
C EMS includes systematic
planning of programs for
compliance with applicable
requirements.
C Consider the following (if
applicable) when identifying legal
requirements and other
requirements: requirements
relating to Clean Air Act General
Conformity; implementation of a
watershed approach for surface
water protection; implementation
of a site-wide approach for ground
water protection; protection of
natural resources, including
biota; protection of site
resources from wildland and
operational fires; protection of
cultural resources.
C Provides for reduction or
elimination of waste generation,
the release of pollutants to the
environment, and the use of Class
I ODS through source reduction,
reuse, segregation, and recycling
and by procuring recycled-content
materials and environmentally
preferable products and services.
C Promotes the long-term
stewardship of a site's natural
and cultural resources throughout
its operational, closure, and post-
closure life cycle.
Objectives and Targets
C Objectives and targets have
been established at each relevant
function and level.
C Establish measurable goals,
objectives and targets.
C Develop site-specific goals
that contribute to the
accomplishment of the DOE
pollution prevention and energy
efficiency goals.
C Contractor ES&H performance
objectives, performance measures,
and commitments include
appropriate environmental elements
based on the environmental risks,
impacts of activities at the site
and established Departmental
pollution prevention/energy
efficiency goals.
C Legal and other requirements
were considered in establishing
them.
C Significant environmental
impacts were considered in
establishing them.
C Technological options were
considered in establishing them.
C Financial, operational, and
business requirements were
considered in establishing them.
C The views of interested
parties were considered in
establishing them.
C They are consistent with the
environmental policy.
Environmental Management Program
An environmental management
program for achieving objectives
and targets has been established
and includes:
C Designation of responsibility
for achieving objectives and
targets at each relevant function
and level of the company.
C The means and time frame for
accomplishment.
C The program applies to new
developments, new or modified
activities, products, and
services.
C Includes policies and
procedures to manage, control, and
mitigate the potential impacts of
site activities with significant
impacts.
C Includes (if applicable) the
following: requirements relating
to Clean Air Act General
Conformity; implementation of a
watershed approach for surface
water protection; implementation
of a site-wide approach for ground
water protection; protection of
natural resources, including
biota; protection of site
resources from wildland and
operational fires; protection of
cultural resources; and reduction
and elimination of waste
generation, the release of
pollutants to the environment and
use of Class I ODS through source
reduction, reuse, segregation, and
recycling and by procuring
recycled-content materials and
environmentally preferable
products and services.
C Includes development and
implementation of cost-effective
pollution prevention programs that
use life-cycle assessment concepts
and practices in determining
program return-on investment.
C Promotes long-term
stewardship of a site’s natural
and cultural resources throughout
its operational, closure, and post-
closure life cycle.
Implementation and Operation
(Phase II)
C Provides for the integrated
execution of programs for public
health and environmental
protection, pollution prevention,
and compliance with applicable
requirements.
Structure and Responsibility
C Roles, responsibilities, and
authorities are defined,
documented, and communicated.
C Resources are provided that
are essential to the
implementation and operation of
the environmental management
system.
C A specific management
representative (one or more) has
been appointed by senior
management with defined roles,
responsibility, and authority for
establishing, implementing and
maintaining an EMS; and reporting
on the performance of the EMS to
senior management.
Training, Awareness, and
Competence
C Training needs are identified
and all personnel whose work may
create a significant impact upon
the environment have received
appropriate training.
C Procedures are established
and maintained to make appropriate
employees aware.
C Personnel performing tasks
that can cause significant
environmental impacts are
competent.
C Includes training to identify
activities with significant
environmental impacts.
C Includes training to manage,
control, and mitigate the
potential impacts of site
activities with significant
environmental impacts.
C Includes training to assess
performance and implement
corrective actions where needed.
Communication
The site has established and
maintains procedures for—
C Communicating internally
communications among levels and
functions.
C Receiving, documenting and
responding to relevant
communication from external
interested parties.
C Communicating externally on
its significant environmental
aspects and recordinged its
decision.
C Obtaining as appropriate,
community advice relevant to
aspects of “Greening the
Government” Executive Orders,
through new or existing outreach
programs.
EMS Documentation
C Information describing the
core elements of the EMS and their
interaction has been established
and maintained.
C Information providing
directions to related
documentation has been established
and maintained.
C Update approved ISMS
descriptions to include EMS
requirements.
Document Control
A procedure has been established
and maintained for controlling
documents to ensure that
C They can be located.
C They are periodically
reviewed, revised, and approved by
authorized personnel.
C Current versions are
available at all appropriate
locations.
C Obsolete documents are
promptly removed.
C Obsolete documents retained
for preservation are identified as
such.
C Documents are legible,
readily identifiable, maintained,
retained, and includes most recent
revision date.
C Procedures exist and are
maintained for creation and
modification of documents.
Operational Control
C Includes procedures to
manage, control, and mitigate the
potential impacts of site
activities with significant
impacts.
Emergency Preparedness and
Response
C There are procedures for
identifying the potential for and
response to accidents and
emergency situations.
C There are procedures for
preventing and mitigating the
environmental impacts that may be
associated with emergencies.
C Procedures are reviewed and
revised as necessary.
C Procedures are periodically
tested where practicable.
Checking and Corrective Action
(Phase III)
C Provides for evaluation of
programs for compliance with
applicable requirements.
C Provides for evaluation of
programs for public health and
environmental protection.
C Provides for evaluation of
programs for pollution prevention.
C Implementation is assessed as
a component of the implementation
of DOE P 450.5, Line Environment,
Safety and Health Oversight
Monitoring and Measurement
C Procedures exist and are
documented to regularly monitor
and measure the key
characteristics of operations
having a significant impact on the
environment.
C Includes recording
information to track performance,
relevant operations controls, and
conformity with objectives and
targets.
C Monitoring equipment is
calibrated and maintained and
records of the process retained.
C A procedure exists for
periodically evaluating compliance
with legislation and regulations.
C Includes policies, procedures
to assess performance
C Contractor ES&H self-
assessment programs within the
framework of DOE P 450.5 are
established and continue to be
effective.
C Ensures the early
identification of, and appropriate
response to, potential adverse
environmental impacts associated
with DOE operations, including, as
appropriate, preoperational
characterization and assessment
and effluent and surveillance
monitoring.
C Provides for the conduct of
environmental monitoring, as
appropriate, to support the site's
ISMS, to detect, characterize, and
respond to releases from DOE
activities.
C Provides for the conduct of
environmental monitoring, as
appropriate, to assess impacts.
C Provides for the conduct of
environmental monitoring, as
appropriate, to estimate dispersal
patterns in the environment.
C Provides for the conduct of
environmental monitoring, as
appropriate, to characterize the
pathways of exposure to members of
the public; and to characterize
the exposures and doses to
individuals, and to the
population.
C Provides for the conduct of
environmental monitoring, as
appropriate, to evaluate the
potential impacts to the biota in
the vicinity of the DOE activity.
C Provides for the
implementation of the analytical
work supporting environmental
monitoring using a consistent
system for collecting, assessing,
and documenting environmental data
of known and documented quality.
C Provides for the
implementation of the analytical
work supporting environmental
monitoring using a validated and
consistent approach for sampling
and analysis of radionuclide
samples to ensure laboratory data
meets program-specific needs and
requirements within the framework
of a performance-based approach
for analytical laboratory work.
C Provides for the
implementation of the analytical
work supporting environmental
monitoring using an integrated
sampling approach to avoid
duplicative data collection.
Nonconformity and
Corrective/Preventive Action
C Procedures exist and are
maintained for defining
responsibility and authority for
handling and investigating
nonconformity and taking
appropriate action.
C Corrective or preventive
actions are appropriate.
C Changes in procedures
resulting from corrective and
prevention action are documented.
C Includes policies, procedures
to implement corrective actions
where needed.
Record
C Procedures are established
and maintained for the
identification, maintenance, and
disposition of environmental
records. These include training
and audit results.
C Records are legible,
identifiable, and traceable to the
activity, product, or service
involved.
C Records are easily
retrievable and protected from
damage, deterioration, or loss.
C Retention times are
established and recorded.
C Records demonstrate
conformity to the standard.
EMS Audit/Self Assessment
C A program and procedure for
periodic EMS audits is established
and maintained.
C The audits determine whether
the EMS conforms to DOE O 450.1.
C Whether it has been properly
implemented and maintained.
C The program provides
information on the results of
audits to management.
C Procedures cover the audit
scope, frequency, and methods, and
responsibilities and requirements
for conducting audits and
reporting results.
C Provides for the evaluation
of programs for public health and
environmental protection,
pollution prevention, and
compliance with applicable
requirements.
C Contractor ES&H self-
assessment programs within the
framework of DOE P 450.5 are
established and continue to be
effective.
Management Review (Phase IV)
C Senior management regularly
reviews the EMS to ensure its
suitability, adequacy, and
effectiveness. The review is
documented.
C Information necessary for
management to perform the review
is collected.
C The review shall consider the
need for changes to policy,
objectives, and other elements of
the EMS resulting from audit
results, changing conditions, and
the commitment to continual
improvement.
C Provides for the evaluation
of programs for public health and
environmental protection,
pollution prevention, and
compliance with applicable
requirements.
C Includes policies, procedures
to assess performance.
C Reviews are conducted
annually, and the site’s
measurable environmental goals,
objectives, and targets are
updated (when appropriate)
C Implementation is assessed as
a component of the implementation
of DOE P 450.5, Line Environment,
Safety and Health Oversight.
C Contractor ES&H performance
objectives, performance measures,
and commitments are reviewed
through the annual ISM review
process [established pursuant to
DEAR 970.5223-1(e)].
DOE ISMS/EMS SELF-DECLARATION PROCEDURE
Introduction and Purpose
The Executive Order 13148, Greening the Government through
Leadership in Environmental Management Working Group (hereinafter
Working Group) developed self-declaration protocols entitled,
"Agency Self-Declaration Protocols for Appropriate Federal
Facilities," September 10, 2003. The protocols provide that the
self-declaration process to be used by facilities should be a
credible, effective and objective evaluation of the site's EMS.
Furthermore, the process should ensure that the system is not
only conformant, but also designed for ongoing evaluation and
continual improvement. The process should also include the
degree of transparency and objectivity necessary to make the self-
declaration credible.
The protocols developed by the Working Group directed agencies to
develop a procedure that addresses the following areas:
§ Direction on the use of an evaluation guide
§ Makeup of the independent review team (e.g. headquarters,
other facility, other agency or contractor)
§ Qualification of independent reviewers
§ Documenting and using the results of management system
evaluations
§ Development of a site self-declaration statement
§ Direction on the frequency of the self-declaration internal
evaluations
§ Frequency of agency independent reviews
§ Schedule for reviewing the self-declaration procedures that
considers changes in mission and organization (this review should
consider changes in agency programs and missions when
appropriate, but on a schedule that does not exceed five years)
The procedures set forth below address the areas that should be
covered pursuant to the protocols. However, these procedures
represent only one example of a site self-declaration procedure.
DOE sites may develop other self-declaration procedures so long
as the procedures address the areas listed above.
PROCEDURES
1. Use of Evaluation Guide
Attachment 3 contains the EMS elements required by DOE O 450.1
to be integrated into an ISMS/EMS. This attachment should be
used to develop an evaluation checklist or lines of inquiry
that can be used during an evaluation of the site's ISMS/EMS.
2. Makeup of Independent Review Team
After a site has completed its ISMS/EMS, but before conducting
an evaluation to determine conformity of the ISMS/EMS, an
independent review team (e.g. Headquarters, other facility,
other agency) should be established. Issues regarding whether
the team should be made up of internal and/or external
reviewers, the size of the review team, and the qualification
of the team members are key considerations.
To ensure team credibility, the members should be independent,
free of bias and conflict, and competent to carry out their
responsibilities. Using external reviewers to conduct the
evaluation can help ensure independence.
The size of the review team should be appropriate to the
complexity of the ISMS/EMS and should include a team leader.
The team leader should be designated by the site or facility
senior management and have applied experience and training
with management systems. The team leader should also have
strong project management experience.
3. Qualification of Team Members
It is highly recommended that the team be composed of members
who have technical and compliance experience, auditing, and
HAZWOPER training (if it is necessary to have physical access
to hazardous areas). An administrative professional is a key
team member to provide a central point of contact for the
evaluation team. Team members should also have appropriate
clearances to access all documents and areas, as appropriate.
4. Pre-visit Activities
Once the site/facility senior management identifies the team
leader, and the team leader has identified team members, a
list of resources and a budget should be developed. The team
should consider the following items: laptop computer, digital
or video camera, and personal protective equipment, such as
safety glasses, safety shoes, respirators, and hard hats.
The team leader should send formal notification to the
site/facility senior management indicating the start date of
the evaluation and a kickoff meeting with critical site
personnel who will be involved in the evaluation. A sample
memorandum is shown below. A copy of the appropriate
evaluation checklist or lines of inquiry should be shared with
the participants at the kickoff meeting so that an opportunity
will exist to clarify and answer questions.
Sample Notification Memorandum
DATE:
REPLY TO
ATTN OF:
SUBJECT: ISMS/EMS Self-Declaration Evaluation
TO:
On _______, the ISMS/EMS self-declaration evaluation
team will begin a review of your ISMS/EMS. This
evaluation will determine whether your
site’s/facility’s ISMS/EMS conforms to DOE O 450.1.
Before the team begins its review, we would like to
schedule a kickoff meeting with key site personnel who
will be involved in the evaluation. If it is
convenient, we would like to schedule the kickoff
meeting from 8:30 a.m. until noon on __________. Please
contact _________of my team if you have questions.
Thank you for your cooperation.
The team leader should assemble the team and begin reviewing
documentation, such as the following:
· Past reviews/assessments (such as ISMS reviews)
·
· Audits (preferably from the past 2 years)
· Policy, guidance, and procedure documents
· National Environmental Policy Act of 1969 (NEPA)
documentation
· Organization chart for Environmental group
· List of key individuals for each evaluated area
The team leader should make arrangements for dedicated office
and meeting space for the duration of the evaluation with
telephone, fax, printer and copier, and computer capabilities.
In addition, the team leader should also make an assignment
list with deadlines and distribute the list to all team
members.
5. Onsite Evaluation
The team leader should make arrangements to conduct a briefing
with managers, team members, and key personnel in the area to
be evaluated. This briefing may review the scope of the
evaluation, expected products, and outcomes. The schedule and
activities, along with any resource needs or issues, should be
discussed at this briefing.
a. Daily Evaluation Activities
Evaluation team members should conduct interviews and
observe media-specific operations with personnel to
assess various program components with respect to the
checklist. These personnel may include the following:
· Senior environmental official/manager in the area being
evaluated
· Environmental personnel (federal and contractor)
· Managers and operations personnel in areas of environmental
significance
· Site/facility environmental manager
Evaluation team members may review relevant documents,
as necessary, to assess the ISMS/EMS. The evaluation
team should document in notes, any findings or
observations and send them to a central repository
managed by the team’s administrative staff.
The team should have a daily end-of-day briefing with
the team leader. Managers and other personnel (at the
team leader’s discretion) may also attend the briefing
to discuss findings and observations and the next
day’s schedule and activities.
6. Documenting and Using the Results of Management System
Evaluations
The evaluation team should develop steps to document the
results of the management system evaluation, including steps
for acknowledging adequate management systems, followup
actions to address inadequacies in the site management
systems, and reporting results of the evaluation for inclusion
in the DOE annual ISMS reviews.
To rate the conformity of the management systems, the
following criteria may be used:
C=Conformity
SC=Sufficiently in Conformity (nonconformities are minor)
NC=Nonconformity.
Findings of nonconformity may be classified further in the
following categories:
· Significant—May result in a direct and immediate threat to
human health, safety, the environment, or the site
mission—requires immediate attention
· Regulatory—Noncompliance with a federal or state regulation
or permit
· Policy—Noncompliance with DOE directive, or policy
7. Out-Briefing
The team leader should conduct the out-briefing with the
assistance of other team members. Attendees should include
site senior managers, environmental managers, and contractor
managers. A sample agenda is outlined below:
SAMPLE AGENDA
Purpose and Scope of Evaluation
Management Review
- Positive Observations
- Findings
- Performance Indicators
Future Actions
8. Post-Visit Activities
The Evaluation Report may be structured based on the format
outlined below. The report should be completed within 4 to 6
weeks after completion of the evaluation. The draft report
should be circulated to the team members and senior federal
and contractor managers for review and comment. A period of at
least 2 weeks should be factored in for resolving any
comments. The final report will include an action plan for
resolution of any findings, including estimated completion
dates and notification of final closure for each finding.
After completion and resolution of the findings, site/facility
senior management will prepare and submit a self-declaration
memorandum to the appropriate CSO no later than December 31,
2005, with a copy to the Office of Environment, Safety and
Health. (Section 9.3.1 of DOE G 450.1-1 lists information that
should be included in this memorandum.)
Site/facility senior management should publicly issue a self-
declaration statement that it has a management system that
conforms to DOE O 450.1. This statement should be communicated
on the site's web page. A sample statement is shown below.
Sample Evaluation Report Format
I. Introduction (includes description of facility,
evaluation method, overall content of report)
II. Results (overall discussion of results of
evaluation)
III. Conclusions (overall discussion of effectiveness of
management system)
Appendix A—Acronyms
Appendix B—Team Membership
Appendix C—Findings (detailed discussion of the findings
based on criteria)
Appendix D—Action Plan for Resolution of Findings
Sample Self-Declaration Statement
{Insert name of Operations/Field/Site office manager here}
declares that {Insert name of site or facility}has an
environmental management system that is fully integrated
with its integrated safety management system and meets the
requirements of DOE O 450.1, Environmental Protection
Program. This integrated management system provides {insert
name of site or facility here} with the means to cost
effectively meet or exceed compliance with applicable
environmental, public health and safety and resource
protection laws, regulations, and DOE requirements. In
making this declaration, I have relied on the following:
{insert a brief description of the findings from the
evaluation that supports the declaration}
9. Frequency of Facility Independent Reviews and Self-
Declaration Evaluations
Although the self-declaration evaluation is a one-time
occurrence, subsequent independent reviews and evaluations to
ensure that the management system continues to conform should be
conducted at least every 3 years or sooner if
evaluations/audits/self-assessments indicate that the management
system is no longer conforming. These subsequent independent
reviews and evaluations should be integrated into a site’s
existing audit/assessment program.
10. Schedule for Reviewing Self-Declaration Procedures
Site self-declaration procedures should be periodically reviewed
on a schedule that does not exceed five years. This review
should consider changes in DOE programs and mission and revisions
to the procedures should be made when appropriate.
Elements of an ISMS/EMS – DOE O 450.1
The environmental management system is a continuing cycle of
planning, implementing, evaluating, and improving processes and
actions undertaken to achieve environmental goals (DOE O 450.1
§1.).
The environmental management system is part of the Integrated
Safety Management System established pursuant to DOE P 450.4
Safety Management System Policy (DOE O 450.1 §1.).
Planning
The ISMS/EMS provides for the systematic planning of
programs for public health and environmental protection (DOE
O 450.1 §4.a.(1)(a)).
The ISMS/EMS provides for the systematic planning of
programs for pollution prevention (DOE O 450.1
§4.a.(1)(b)).
Environmental aspects.
The ISMS/EMS includes policies [and] procedures to identify
activities with significant environmental impacts (DOE O
450.1 §4.a.(2)).
Legal and other requirements.
The ISMS/EMS provides for the systematic planning of
programs for compliance with applicable requirements (DOE O
450.1 §4.a.(1)).
The ISMS/EMS includes (if applicable) conformity of DOE
proposed actions with State Implementation Plans to attain
and maintain national ambient air quality standards (DOE O
450.1 §4.b.(1)(a)).
The ISMS/EMS includes (if applicable) implementation of a
watershed approach for surface water protection (DOE O 450.1
§4.b.(1)(b)).
The ISMS/EMS includes (if applicable) protection of other
natural resources, including biota (DOE O 450.1
§4.b.(1)(d)).
The ISMS/EMS includes (if applicable) protection of cultural
resources (DOE O 450.1 §4.b.(1)(f)).
The ISMS/EMS includes (if applicable) implementation of a
site-wide approach for groundwater protection (DOE O 450.1
§4.b.(1)(c)).
The ISMS/EMS includes (if applicable) protection of site
resources from
wildland and operational fires (DOE O 450.1 §4.b.(1)(e)).
The ISMS/EMS provides for reduction or elimination of: the
generation of waste, the release of pollutants to the
environment, and the use of Class I ozone-depleting
substances (ODS), through source reduction, re-use,
segregation, and recycling and by procuring recycled-content
materials and environmentally preferable products and
services (DOE O 450.1 §4.b.(3)).
The ISMS/EMS promotes the long-term stewardship of a site's
natural and cultural resources throughout its operational,
closure, and post-closure life cycle (DOE O 450.1
§4.b.(2)).
Objectives and targets.
The ISMS/EMS includes measurable environmental goals,
objectives, and targets (DOE O 450.1 §4.a.(3)).
The ISMS/EMS includes site-specific goals that contribute to
the accomplishment of DOE pollution prevention and energy
efficiency goals (DOE O 450.1 §5.c.(3)).
Contractor ES&H performance objectives, performance
measures, and commitments include appropriate environmental
elements based on the environmental risks, impacts of
activities at the site and established Departmental
pollution prevention/energy efficiency goals (DOE O 450.1
§5.d.(17)).
Environmental management program(s).
The ISMS/EMS includes policies [and] procedures to manage,
control, and mitigate the potential impacts of site
activities with significant environmental impacts (DOE O
450.1 §4.a.(2)).
The ISMS/EMS includes (if applicable) conformity of DOE
proposed actions with State Implementation Plans to attain
and maintain national ambient air quality standards (DOE O
450.1 §4.b.(1)(a)).
The ISMS/EMS includes (if applicable) implementation of a
watershed approach for surface water protection (DOE O 450.1
§4.b.(1)(b)).
The ISMS/EMS includes (if applicable) implementation of a
site-wide approach for ground water protection(DOE O 450.1
§4.b.(1)(c)).
The ISMS/EMS includes (if applicable) protection of other
natural resources, including biota (DOE O 450.1
§4.b.(1)(d)).
The ISMS/EMS includes development and implementation of cost-
effective pollution prevention programs that use life-cycle
assessment concepts and practices in determining program
return-on-investment (DOE O 450.1 §5.c.(4)).
The ISMS/EMS includes (if applicable) protection of cultural
resources (DOE O 450.1 §4.b.(1)(f)).
The ISMS/EMS includes (if applicable) protection of site
resources from wildland and operational fires (DOE O 450.1
§4.b.(1)(e)).
The ISMS/EMS provides for reduction or elimination of: the
generation of waste, the release of pollutants to the
environment, and the use of Class I ozone-depleting
substances (ODS), through source reduction, re-use,
segregation, and recycling and by procuring recycled-content
materials and environmentally preferable products and
services (DOE O 450.1 §4.b.(3)).
The ISMS/EMS promotes the long-term stewardship of a site's
natural and cultural resources throughout its operational,
closure, and post-closure life cycle (DOE O 450.1
§4.b.(2)).
Implementation and operation
The ISMS/EMS provides for the integrated execution of
programs for public health and environmental protection,
pollution prevention, and compliance with applicable
requirements (DOE O 450.1 §4.a.(1)).
Structure and responsibility.
[Structure and responsibility is addressed in DOE P 450.4
Safety Management System Policy, DOE P 411.1 Safety
Management Functions Responsibilities and Authorities
Policy, DOE M 411.1C Safety Management Functions,
Responsibilities and Authorities, and other DOE policies,
procedures and requirements.]
Training, awareness, and competence.
The ISMS/EMS includes training to identify activities with
significant environmental impacts (DOE O 450.1 §4.a.(2)).
The ISMS/EMS includes training to manage, control, and
mitigate the potential impacts of site activities with
significant environmental impacts (DOE O 450.1 §4.a.(2)).
The ISMS/EMS includes training to assess performance and
implement corrective actions where needed (DOE O 450.1
§4.a.(2).
Communication.
The ISMS/EMS provides for obtaining, as appropriate,
community advice relevant to aspects of “Greening the
Government” Executive Orders, through new or existing
outreach programs (DOE O 450.1 §5.d.(3)).
Environmental management system documentation.
Approved ISMS descriptions have been updated, as necessary,
to include EMS requirements (DOE O 450.1 §5.d.(2)).
Document control.
[Document control is addressed in other DOE policies,
procedures and requirements.]
Operational control.
The ISMS/EMS includes procedures to manage, control, and
mitigate the potential impacts of site activities with
significant environmental impacts (DOE O 450.1 §4.a.(2)).
Emergency preparedness and response.
[Emergency preparedness and response is addressed in other
DOE policies, procedures and requirements.]
Checking and corrective action
The ISMS/EMS provides for the evaluation of programs for
compliance with applicable requirements (DOE O 450.1
§4.a.(1)(c)).
The ISMS/EMS provides for the evaluation of programs for
public health and environmental protection (DOE O 450.1
§4.a.(1)(a)).
The ISMS/EMS provides for the evaluation of programs for
pollution prevention (DOE O 450.1 §4.a.(1)(b)).
ISMS/EMS implementation is assessed as a component of the
implementation of DOE P 450.5, Line Environment, Safety and
Health Oversight (DOE O 450.1 §5.b.).
Monitoring and measurement.
The ISMS/EMS includes policies, procedures to assess
performance (DOE O 450.1 §4.a.(2)).
Contractor ES&H self-assessment programs within the
framework of DOE P 450.5 are established and continue to be
effective (DOE O 450.1 §5.d.(16)).
The ISMS/EMS ensures the early identification of, and
appropriate response to, potential adverse environmental
impacts associated with DOE operations, including, as
appropriate, preoperational characterization and assessment
and effluent and surveillance monitoring (DOE O 450.1
§4.b.(4)).
The ISMS/EMS provides for the conduct of environmental
monitoring, as appropriate, to support the site's ISMS, to
detect, characterize, and respond to releases from DOE
activities (DOE O 450.1 §5.d.(14)).
The ISMS/EMS provides for the conduct of environmental
monitoring, as appropriate, to assess impacts (DOE O 450.1
§5.d.(14)).
The ISMS/EMS provides for the conduct of environmental
monitoring, as appropriate, to estimate dispersal patterns
in the environment (DOE O 450.1 §5.d.(14)).
The ISMS/EMS provides for the conduct of environmental
monitoring, as appropriate, to characterize the pathways of
exposure to members of the public; and to characterize the
exposures and doses to individuals, and to the population
(DOE O 450.1 §5.d.(14)).
The ISMS/EMS provides for the conduct of environmental
monitoring, as appropriate, to evaluate the potential
impacts to the biota in the vicinity of the DOE activity
(DOE O 450.1 §5.d.(14)).
The ISMS/EMS provides for the implementation of the
analytical work supporting environmental monitoring
using a consistent system for collecting, assessing,
and documenting environmental data of known and
documented quality (DOE O 450.1 §5.d.(15)(a)).
The ISMS/EMS provides for the implementation of the
analytical work supporting environmental monitoring using a
validated and consistent approach for sampling and analysis
of radionuclide samples to ensure laboratory data meets
program-specific needs and requirements within the framework
of a performance-based approach for analytical laboratory
work (DOE O 450.1 §5.d.(15)(b)).
The ISMS/EMS provides for the implementation of the
analytical work supporting environmental monitoring using an
integrated sampling approach to avoid duplicative data
collection (DOE O 450.1 §5.d.(15)(c)).
Non conformance and corrective and preventive action.
The ISMS/EMS includes policies, procedures to implement
corrective actions where needed (DOE O 450.1 §4.a.(2)).
Records.
[This is addressed in other DOE policies, procedures and
requirements.]
Environmental management system audit/Self Assessment
The ISMS/EMS provides for the evaluation of programs for
public health and environmental protection, pollution
prevention, and compliance with applicable requirements (DOE
O 450.1 §4.a.(1)).
Contractor ES&H self-assessment programs within the
framework of DOE P 450.5 are established and continue to be
effective (DOE O 450.1 §5.d.(16)).
Management review
The ISMS/EMS provides for the evaluation of programs for
public health and environmental protection, pollution
prevention, and compliance with applicable requirements (DOE
O 450.1 §4.a.(1)).
The ISMS/EMS includes policies, procedures to assess
performance (DOE O 450.1 §4.a.(2)).
The ISMS/EMS reviews annually, and updates (when
appropriate) the site’s measurable environmental goals,
objectives, and targets (DOE O 450.1 §4.a.(3)).
ISMS/EMS implementation is assessed as a component of the
implementation of DOE P 450.5, Line Environment, Safety and
Health Oversight (DOE O 450.1 §5.b.).
Contractor ES&H performance objectives, performance
measures, and commitments are reviewed through the annual
ISM review process [established pursuant to DEAR 970.5223-1
(e)] (DOE O 450.1 §5.d.(17)).
GLOSSARY
Activities, Products, and Services—A catchall phrase that was
developed by Technical Committee 207 of ISO to capture all of
the elements at a facility or organization that can interact with
the environment.
Assessment—An analysis, appraisal, or evaluation of a DOE program
or contractors performance to ensure conformance to regulatory
and DOE internal requirements and confirm safe and
environmentally protective performance of work.
Audit—A systematic and documented verification process of
objectively obtaining and evaluating evidence to determine the
adequacy of a program or system within an organization.
Cognizant Secretarial Officer (CSO)—A DOE official at the
Assistant Secretary level who is responsible for the assignment
of work, the institutional overview of any type of facility, or
both, and the management oversight of a laboratory.
Composite Impacts—The sum of real or potential significant
impacts to human health and the environment that may result from
DOE site operations or activities.
Continuous Improvement—The process of enhancing the environmental
management system to achieve improvements in overall
environmental performance in line with the organization's
environmental policy. This process need not take place in all
areas of activity simultaneously.
Corrective Action—An action taken to eliminate the causes of an
existing noncompliance, nonconformity, defect, or other
undesirable situation in order to prevent recurrence.
Cultural Resources—Historic properties as defined in the National
Historic Preservation Act, archaeological resource as defined in
the Archaeological Resources Protection Act, and cultural items
as defined in the Native American Graves Protection and
Repatriation Act. Includes artifacts and sites dating to the
prehistoric, historic, and ethnohistoric periods that are
currently located on the ground or buried beneath it; standing
structures that are more than 50 years of age or are important
because they represent a major historical theme or era; cultural
and natural places, select natural resources, and sacred objects
that have importance for Native Americans and other ethnic
groups; and American folklife traditions and arts.
EMS Audit—A systematic and documented verification process of
objectively obtaining and evaluating evidence to determine
whether an organization’s environmental management system
conforms to the environmental management system audit criteria
set by the organization, and for communication of the results of
this process to management.
Environment—Surroundings in which an organization operates,
including air, water, land, natural resources, flora, fauna,
humans, and their interrelation. (ISO-14001, 1996).
Environmental Aspect—Elements of an organization’s activities,
products, or services that can interact with the environment.
(ISO-14001, 1996) (The environmental aspect of an activity is
that part of it that creates a possibility for an environmental
impact. As such, it is equivalent to the concept of “hazard” in
safety, which is also defined as the mere possibility of a
negative event.)
Environmental Impact—A change to the environment, whether adverse
or beneficial, wholly or partially resulting from an
organization’s activities, products, or services. (ISO-14001,
1996).
Environmental Management System (EMS)—The part of the overall
management system that includes organizational structure,
planning activities, responsibilities, practices, procedures,
processes, and resources for developing, integrating, achieving,
reviewing, and maintaining environmental policy; a continuing
cycle of planning, implementing, evaluating, and improving
processes and actions undertaken to achieve environmental goals.
Environmental Objective—An overall environmental goal, arising
from the environmental policy, that an organization sets itself
to achieve, and which is quantified where practicable. (ISO-
14001, 1996).
Environmental Performance—Measurable results of the environmental
management system, related to an organization’s control of its
environmental aspects, based on its environmental policy,
objectives, and targets. (ISO-14001, 1996).
Environmental Policy—A statement by the organization of its
intentions and principles in relation to its overall
environmental performance, which provides a framework for action
and for the setting of its environmental objectives and targets.
(ISO 14001, 1996)
Environmental Target—A detailed performance requirement,
quantified where practicable, and applicable to the organization
or parts thereof, which arises from the environmental objectives
and needs to be set and met to achieve those objectives. (ISO-
14001, 1996).
Gap Analysis—An assessment of EMS requirements against existing
management system descriptions, policies and procedures.
Integrated Safety Management System (ISMS)—A DOE management
system that provides a formal, organized process whereby people
plan, perform, assess, and improve the safe conduct of work
efficiently and in a manner that ensures protection of workers,
the public, and the environment. This management system shall be
used to systematically integrate safety into management and work
practices at all levels so that missions are accomplished while
protecting the public, the worker, and the environment.
ISMS/EMS Assessment—A formal self-assessment (see self-
assessment) that is normally conducted by an organization with an
appropriate degree of independence.
ISO 14001 Standard—Internationally recognized voluntary
environmental management system standard that provides
organizations with the elements of an effective environmental
management system that can be integrated with other management
requirements to help organizations to achieve environmental and
economic goals.
Likelihood—A measure of how often an aspect can be expected to
occur within an activity given the probability of its occurrence
for each repetition of the activity and the frequency of the
activity over time.
Operational Controls—Procedures that help a site in implementing
its environmental policy, objectives, and targets.
Organization—A company, corporation, firm, enterprise, authority,
or institution, or part or combination thereof, whether
incorporated or not, public or private, that has its own
functions and administration. (ISO-14001, 1996).
Pollution Prevention—A source reduction as defined in the
Pollution Prevention Act, and other practices that reduce or
eliminate the creation of pollutants through 1) increased
efficiency in the use of raw materials, energy, water, or other
natural resources; or 2) protection of natural resources by
conservation. The DOE has expanded this definition to include
recycling.
Potential Environmental Impact—An aspect defined by its
likelihood of occurrence and likely consequences. It is
equivalent to the concept of “risk” in Safety, which assigns a
probability and consequence to the possible negative event that
may result from a “hazard.”
Recycling—1) The use or reuse of a material as an effective
substitute for a commercial product and as an ingredient or
feedstock in an industrial or energy-producing process, and 2)
the reclamation of useful constituents within a waste, or removal
of contaminants from a waste to allow it to be reused.
Root Cause—The origin of an environmental deficiency.
Self-Assessment—An analysis or evaluation of a DOE program or
contractors management system by that program or contractor to
ensure conformance to regulatory and DOE internal requirements
and to confirm the safe and environmentally protective
performance of work.
Self-Declaration—An organization determines that it is in full
conformance with the requirements of a recognized standard and
publicly asserts that it conforms to the specifications of the
standard.
Significant Environmental Aspect—An environmental aspect that has
or could have a significant impact on the environment, the
organization, or to the organization’s mission. (ISO-14001,
1996).
Third-Party Registration—The process by which an organization
applies for placement on a publicly available list of entities
that conforms to a specified set of requirements.
Senior Management—The level of management that has authority to
make decisions for the site/facility.
REFERENCES
The following references were used in compiling this document.
American National Standards Institute. 2001. ANSI Auditing Policy
and Procedures. National Issues Committee, September 2000.
Block, M., and Marash, I. R. 2001. Integrating ISO-14001 in to a
Quality Management System. Milwaukee: ASQ Quality Press.
Block, M. 1999. Identifying Environment Aspects and Impacts.
Milwaukee: ASQ Quality Press.
Canadian Standards Association. 1995. Competing Leaner, Keener
and Greener A Small Business Guide to ISO 14000.
Cascio, Joseph, et al. ISO 14000 Guide, McGraw-Hill, 1996.
Cascio, Joseph, Editor, The ISO 14000 Handbook. ASQ,,1996.
Deaver, T. 1998. Integrating facilities planning and ISO 14000.
IIE Solutions, Sept v30 n9 p1(4).
Diamond, Craig P. 1995. “Voluntary Environmental Management
System Standards: Case
Studies in Implementation.” Total Quality Environmental
Management. Winter 1995/1996, pp. 9-23.
Department of Energy and Environmental Protection Agency. 1998.
Environmental Management Systems Primer for Federal Facilities.
Department of Energy, Office of Environmental Policy and
Assistance; and EPA, Federal Facilities Enforcement Office,
DOE/EH-0573
(
http://www.epa.gov/Compliance/resources/publications/incentives/e
ms/emsprimer.pdf ).
EMAS. 1993. Eco-management Audit Scheme. Brussels: European
Council. Text of Council Regulation 1836/93-EMAS.
Fryxell, G. E. and Vryza, M. 1998. “Managing environmental issues
across multiple function: and empirical study of corporate
environmental departments and functional co-ordination.” Journal
of Environmental Management, v55, p. 39(56).
GETF. 2000. The USEPA Environmental Management System Pilot
Program for Local Government Entities. January 2000.
Hamilton, E. 1997. “The top eleven pitfalls of environmental
audits and how to avoid them.” Journal of Environmental Law and
Practice, Mar/Apr v4 n5 p. 29(6).
Hillary, Ruth. 1999. Evaluation of Study Reports on the
Barriers, Opportunities and Drivers for Small and Medium Sized
Enterprises in the Adoption of Environmental Management
Systems. October 1999.
Institute of Quality Assurance. 1995. Quality Systems in the
Small Firm: a Guide to the Use of the ISO 9000 Series. March
1995.
International Organization for Standardization. 1996. ISO 14004-
Environmental Management
System—General Guidelines on Principles, Systems, and Supporting
Techniques.
International Standards Organization. 1996. ISO-
14001.Environmental Management Systems Specification with
Guidance for Use, ISO-14001; 1(996(E)).
McDonough, William and Michael Braungart. Cradle to Cradle, 2002.
Metcalf, K. R., Williams, P. L., Minter, R. J. and Hobson, C. M.
1995. “An assessment of corporate environmental programs and
their performance measurement systems.” Journal of Environmental
Health, Sept v58 n2 p. 9(9).
Michigan Department of Commerce and Natural Resources. 1996.
Business Waste Reduction: Creating an Action Plan. Michigan
Department of Commerce and Natural Resources, Environmental
Services Division, November 1994.
Northern Environmental. 2000. ISO-14001 Guide for Small to Medium-
Sized Companies. Northern Environmental.
NSF-ISR. 1998. Environmental Management Systems: A Guide for
Metal Finishers. NSF-ISR.
NSF-ISR. 1998. Implementing Environmental Management Systems in
Community-Based
Organizations. NSF-ISR.
Raymond, Martin, Dr. 1998. ISO-14001 Guidance Manual. National
Center of Environmental Decision-Making Research (NCEDR).
Technical Report NCEDR/98-06.
Rikhardsson. P. M. 1998. Information systems for corporate
environmental management accounting and performance measurement.
Greener Management International, Spring, p. 51.
Sisk, Steven. 1997. Compliance-Focused Environmental Management
System – Enforcement Agreement Guidance. EPA, Office of Criminal
Enforcement, Forensics and Training, EPA330/9-97-002R. Revised
December 2001.
(http://www.epa.gov/compliance/resources/publications/incentives/
ems/ems12elemr.pdf).
Stapleton, P., and Glover, M. 2001. Environmental Management
Systems: An Implementation Guide for Small and Medium-Sized
Organizations. NSF International.
(http://www.epa.gov/OW-OWM.html/iso14001/wm046200.htm).
Tibor, T., and Feldman, I. 1996. ISO 14000 A Guide to the New
Environmental Management Standards. Irwin Professional
Publishing.
United Nations Environment Programme (UNEP). 1995. Environmental
Management System Training Resource Kit. Version 1.0, UNEP, the
International Chamber of Commerce (ICC), and the International
Federation of Consulting Engineers (FIDIC). December 1995.
United States Department of Energy. Environmental Management
System Implementer’s Guide (Draft), March 2003.
United States Environmental Protection Agency. 2001. Compliance-
Focused Environmental Management System-Enforcement Agreement
Guidance. EPA330/9-97-002R, Revised December 2001.
(http://www.epa.gov/Compliance/resources/publications/incentives/
ems/ems12elemr.pdf ).
United States Environmental Protection Agency. 2001. Draft
College and University Environmental Management System Guide.
EPA, New England.
(http://www.epa.gov/ne/assistance/univ/emsguide.html).
United States Environmental Protection Agency. 2003. EMS
Implementation Training Course. Office of Administration; Safety,
Health and Environmental Management Division. (Produced by Booz
Allen Hamilton, EMS Team, to be completed March 2003).
United States Environmental Protection Agency. 1998.
Environmental Audit Program Design Guidelines for Federal
Agencies. Office of Enforcement and Compliance Assurance, EPA300-
B-96-011
United States Environmental Protection Agency. 1986.
Environmental Auditing Policy Statement. EPA, Office of
Administration. 51 FR 25004.
United States Environmental Protection Agency. 1996. Generic
Protocol for Conducting Environmental Audits of Federal
Facilities. Office of Enforcement and Compliance Assurance,
EPA300-B-96-012B.
United States Environmental Protection Agency. 1997.
Implementation Guide For The Code of Environmental Management
Principles for Federal Agencies (CEMP). Federal Facilities
Enforcement Office, EPA 315-B-97-001.
(http://www.epa.gov/compliance/resources/publications/incentives/
ems/cempmaster.pdf).
United States Environmental Protection Agency. 2000. Incentives
for Self-Policing: Discovery, Disclosure, Correction and
Prevention of Violations. [FRL 6576-3].
United States Environmental Protection Agency. 2000. Integrated
Environmental Management Systems Company Manual for Small
Business. Office of Pollution Prevention and Toxics, EPA744-R-00-
012.
(http://www.epa.gov/dfe/pubs/iems/iems_template/template.pdf).
United States Environmental Protection Agency. 2000. Integrated
Environmental Management Systems (IEMS) Implementation Guide.
Office of Pollution Prevention and Toxics, EPA744-R-00-011.
(http://www.epa.gov/opptintr/dfe/tools/iemsguide.htm)
United States Environmental Protection Agency. 2002. Practical
Guide to Environmental Management for Small Business. Small
Business Division, EPA233-K-02-001. (http://www.smallbiz-
enviroweb.org/html/pdf/EM_Guide0902.pdf).
United States Postal Service. 1995. Environmental Resources
Handbook. United States Postal Service.
Internet sites
Environmental Management Systems Home Page.
(http://www.p2pays.org/iso). Accessed January 2003.
EPA’s Action Plan for Promoting the Use of Environmental
Management Systems (EMS).
(http://www.epa.gov/ems/policy/goals.htm). Accessed January 2003.
EPA’s EMS Web site.
(http://www.epa.gov/ems/index.htm). Accessed January 2003.
EPA’s EMS Web site: EMS Publications.
(http://www.epa.gov/ems/assist/guide/general.htm). Accessed
January 2003.
EPA’s National Compliance Assistance Clearinghouse: EMS Page.
(http://cfpub.epa.gov/clearinghouse/index.cfm?Tab=Tools&TopicID=C
:10:300:EMS). Accessed January 2003.
EPA’s National Compliance Assistance Clearinghouse.
(http://cfpub.epa.gov/clearinghouse/). Accessed January 2003.
EPA’s National Environmental Performance Track.
(http://www.epa.gov/performancetrack/).
Accessed: August 2001.
Global Reporting Initiative (GRI).
(http://www.globalreporting.org).
Accessed: August 2001.
Iowa Waste Reduction Center: EMS Service Center.
(http://www.iwrc.org/programs/ems.cfm). Accessed January 2003.
Northeast Business Environmental Network (NBEN) (2002).
(http://www.nben.org).
Accessed: January 2003.
P2 Regional Information Center: Environmental Management Systems.
(http://p2ric.org/TopicHubs/toc.cfm?hub=9&subsec=7&nav=7).
Accessed January 2003.