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DOE G 450.1-10
10-25-04

SENIOR MANAGERS'
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

FOREWORD
This Guide is one of a series issued to provide suggested approaches for meeting the
requirements of DOE O 450.1, Environmental Protection Program, dated 1-15-03, which
requires Department of Energy (DOE) organizations to establish environmental management
systems (EMSs) that are an integral part of DOE's Integrated Safety Management System
(ISMS), hereinafter referred to as an ISMS/EMS.
This Guide provides a summary description of EMSs for DOE senior managers, including their
responsibilities as they apply to the successful implementation of an ISMS/EMS and the
expected benefits to be derived from such implementation.
This Guide is approved for use by the DOE Office of Environment, Safety and Health and is
available for use by all DOE elements, including the National Nuclear Security Administration,
and their contractors. Suggestions for corrections or improvements to this Guide should be
addressed to—
John (Larry) Stirling
EH-41
U.S. Department of Energy
Office of Air, Water and Radiation Protection Policy and Guidance
Facsimile: 202-586-0955
John.Stirling@eh.doe.gov

DOE Guides are part of the DOE Directives System and are issued to provide supplemental
information regarding the Department's expectations of its requirements as contained in rules,
Orders, Notices, and regulatory standards. Guides also provide acceptable methods for
implementing these requirements; however, Guides do not establish or invoke any new
requirements nor are they substitutes for requirements. Guides do not replace Technical
Standards, which are used to describe established practices and procedures for implementing
requirements.

CONTENTS
1. INTRODUCTION 1
1.1 Purpose 1
1.2 Applicability 1
1.3 Use of Guidance 1

2. ENVIRONMENTAL MANAGEMENT SYSTEMS 1
3. THE BENEFITS OF INTEGRATING AN ENVIRONMENTAL MANAGEMENT
SYSTEM WITH AN INTEGRATED SAFETY MANAGEMENT SYSTEM 2
3.1 Achieving Mission Goals, Reducing Costs, and Improving
Business Practices 2
3.2 Improving Environmental Compliance Performance and
Reducing Pollution 3
3.3 Addressing Stewardship and Legacy Management Challenges
Systematically 3
3.4 Improving Credibility with Regulators and Local Communities 3

4. INTEGRATING ENVIRONMENTAL MANAGEMENT SYSTEMS INTO
INTEGRATED SAFETY MANAGEMENT SYSTEMS 4
5. IMPLEMENTATION OF INTEGRATED SAFETY MANAGEMENT
SYSTEM/ENVIRONMENTAL MANAGEMENT SYSTEM AT CLOSURE
SITES 5
6. SENIOR MANAGER ROLES AND RESPONSIBILITIES IN SUCCESSFUL
INTEGRATED SAFETY MANAGEMENT SYSTEM/ENVIRONMENTAL
MANAGEMENT SYSTEM IMPLEMENTATION 5
6.1 Support the Integrated Safety Management System/Environmental
Management System 6
6.2 Provide Oversight and Guidance 6
6.3 Promote the Use of Environmental Management System Tools
and Training 6
6.4 Engage the Local Community 7

7. CONCLUSIONS 7

1. INTRODUCTION
1.1 PURPOSE
This document provides discretionary guidance for implementing the requirements of DOE
O 450.1, Environmental Protection Program, dated 1-15-03. DOE O 450.1 requires
implementation of sound stewardship practices that are protective of air, water, land, and cultural
and ecological resources impacted by Department of Energy (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) at DOE facilities
as part of existing Integrated Safety Management Systems (ISMSs) established pursuant to DOE
P 450.4, Safety Management System Policy, dated 10-15-96. This Guide provides suggested
approaches for meeting this objective.
1.2 APPLICABILITY
This Guide is for use by all DOE elements including the National Nuclear Security
Administration (NNSA), and DOE/NNSA contractors required to implement DOE O 450.1.
1.3 USE OF GUIDANCE
DOE Guides are not requirements documents and may not be considered as requirements in any
audit or assessment of compliance with the associated Policy, Order, Notice or Manual.
DOE O 450.1 requires DOE elements to establish EMSs that are integrated into DOE site
ISMSs. 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 guidance contained in this document is designed to provide senior managers with an
understanding of DOE O 450.1 roles and responsibilities to ensure successful implementation of
ISMS/EMS and the benefits of implementing ISMS/EMS.
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. Executive Order (E.O.) 13148, Greening
the Government Through Leadership in Environmental Management, requires Federal agencies
to implement EMSs at all appropriate facilities by December 31, 2005. The Department's
progress in implementing the requirements of E.O. 13148 is reported to the White House Office
of the Federal Environmental Executive (OFEE) on an annual basis by the Assistant Secretary of
Environment, Safety and Health, who also serves as the Agency Environmental Executive for the
Department.
The OFEE prepares a scorecard each year to measure progress toward the goal of implementing
EMS. The OFEE has identified several key metrics for Federal agencies to report. The
Department has adopted these metrics to support DOE's reporting requirements. This
information will also assist DOE leadership in assessing how the Department is implementing
their responsibilities to ensure that sites under their purview have successfully implemented EMS
by December 31, 2005.
In furtherance of the goals of E.O. 13148, DOE issued DOE O 450.1 in January 2003. This
Order requires DOE elements to integrate EMSs into site ISMSs (ISMS/EMS).
3. THE BENEFITS OF INTEGRATING AN ENVIRONMENTAL MANAGEMENT
SYSTEM WITH AN INTEGRATED SAFETY MANAGEMENT SYSTEM
The expected benefits of implementing an EMS as part of an ISMS are as follows.
? Achieving mission goals in a timely manner, reducing costs, and improving business
practices.
? Improving environmental compliance performance and reducing the generation of
pollution.
? Addressing stewardship and legacy management issues systematically.
? Improving credibility with regulators and the local community.
3.1 ACHIEVING MISSION GOALS, REDUCING COSTS, AND IMPROVING
BUSINESS PRACTICES
An ISMS/EMS can help ensure that mission goals are achieved in a timely manner by ensuring
that environmental considerations are addressed as part of the strategic planning process and
thereby become part of the critical path to achieving mission goals.
An ISMS/EMS can also help ensure that the management systems used to address these
environmental considerations are built into the existing management system framework, and
thereby become part of the way the organization conducts business. In addition, an ISMS/EMS
can help ensure that an organization's programs and operations minimize the generation of
pollution, which reduces subsequent costs associated attributed to managing waste.
Senior management can underscore to workers their commitment to improved environmental
performance through the implementation of an ISMS/EMS. This can lead to improved employee
awareness of the environmental impacts of their jobs and can help establish an organizational
culture of environmental accountability and performance.
The inherent flexibility provided by management systems allows organizations to implement
ISMS/EMS at facilities and organizations comprised of various sizes, complexities, and missions
(e.g., offices, laboratories, facilities, programs). Moreover, ISMS/EMS will ensure a higher
degree of consistency and reliability in the management processes, assessment activities, and the
continuous improvement of environmental programs and controls.
An ISMS/EMS approach can improve business practices by involving top management.
Increasing employee awareness and participation in the ISMS/EMS approach shifts the culture of
the organization toward the establishment of an environmental protection ethic that strives
toward continual improvement in waste reduction, pollution prevention and environmental
protection by promoting the efficient and compliant accomplishment of mission goals.
3.2 IMPROVING ENVIRONMENTAL COMPLIANCE PERFORMANCE AND
REDUCING POLLUTION
An ISMS/EMS can reveal opportunities for the: continued reduction of waste, pollution
prevention, resource conservation and monetary savings.
Effective implementation of ISMS/EMS involves the entire staff, especially line management.
Ownership of the ISMS/EMS should be placed primarily in the hands of line management, with
the environmental staff providing expertise and assistance as appropriate. Use of EMSs will
allow line managers to predict potential environmental protection problems early enough in the
planning and design phases to minimize or avoid them. A thorough review of the site's/facility's
mission, goals, objectives and activities can minimize redundancies and enhance communication
across business lines, which will result in improved environmental performance and ensure
accountability for achieving the desired environmental results. The ISMS/EMS can also ensure
that continual environmental performance improvements will eventually become the accepted
way of doing business.
3.3 ADDRESSING STEWARDSHIP AND LEGACY MANAGEMENT
CHALLENGES SYSTEMATICALLY
DOE sites are and will continue to be faced with many stewardship and legacy management
challenges. Many sites will close within the next 10 years, making a systematic approach to
reconciling mission goals with acceptable methods, best practices and environmental
requirements and stakeholder concerns necessary. By implementing ISMS/EMS, sites can
proactively identify and address concerns to ensure the Department implements and maintains
sound stewardship practices.
3.4 IMPROVING CREDIBILITY WITH REGULATORS AND LOCAL
COMMUNITIES
Local communities recognize and appreciate a site/facility's open commitment to improved
environmental performance. Regulatory agencies prefer integrated management systems for
similar reasons. A properly functioning ISMS/EMS makes the management systems appear to
be more "transparent" to the regulator, thereby making their job easier. This can result in an
improved, more cooperative relationship with the regulators. Regulators may be able to provide
oversight relief from various administrative requirements if they are convinced there is a sound,
effective EMS in place. Key environmental information that is well organized, comprehensive,
and easy to obtain also helps lessen the chance of a noncompliant situation.
The Environmental Protection Agency (EPA) rewards federal agencies with effective EMS with
the "Performance Track" designation. Performance Track recognizes facilities that consistently
meet the legal requirements and have implemented high-quality EMSs.
4. INTEGRATING ENVIRONMENTAL MANAGEMENT SYSTEMS INTO
INTEGRATED SAFETY MANAGEMENT SYSTEMS
DOE O 450.1 requires DOE elements to ensure that site ISMSs include an EMS. In those
instances where an ISMS is not implemented, DOE elements must develop and implement an
EMS. Otherwise, an EMS is that part of the site's ISMS which addresses the environmental
consequences of an organization's products, services, and activities.
Several recognized EMS frameworks exist. ISO 14001 is the most popular. DOE O 450.1 does
not require DOE organizations to use the ISO 14001 framework, but the Order does identify
specific EMS elements that are required to be included in an ISMS/EMS. DOE elements may
opt to use the ISO 14001 standard or any other model that meets the requirements of the Order.
Senior managers should consult with the DOE Operations/Field/Site Office managers in deciding
upon a particular framework. Regardless of the framework chosen, the EMS elements must still
be compatible with and integrated into the site's ISMS. When a site does not have an ISMS,
DOE elements must still ensure the implementation of an EMS.
The integration of an EMS into an ISMS provides a unified system for the management of
resources; the control and attenuation of environmental risks; and the establishment and
achievement of the organization's environment, safety, and health goals. ISMS/EMS should be
viewed as an ISMS enhancement that adds those EMS elements not previously included in the
ISMS. It is recognized that many sites have already implemented ISMSs and should therefore
have most, if not all, of the elements of an EMS already in place.
Existing environmental programs provide an excellent starting point for developing an
ISMS/EMS because some of the required ISMS/EMS elements may be in place. For example,
existing site environmental information contained in Annual Site Environmental Reports,
National Environmental Policy Act (NEPA) documents, permit applications, monitoring reports,
etc., may be appropriate for inclusion to the ISMS/EMS.
Guidance documents DOE G 450.1-1, Implementation Guide for Use with DOE O 450.1,
Environmental Protection Program, dated 2-18-04, and DOE G 450.1-2, Implementation Guide
for Integrating Environmental Management Systems into Integrated Safety Management
Systems, dated 8-20-04, provide information on the acceptable methods for meeting the
requirements of DOE O 450.1. DOE G 450.1-1 provides an overview of the EMS process, while
DOE G 450.1-2 provides detailed guidance relating to integrating EMSs into a site's ISMS.
Additional documents that provide guidance on meeting the requirements of DOE O 450.1 can
be found at http://www.eh.doe.gov/oepa.
5. IMPLEMENTATION OF INTEGRATED SAFETY MANAGEMENT
SYSTEM/ENVIRONMENTAL MANAGEMENT SYSTEM AT CLOSURE SITES
Closure sites (i.e., sites that have ceased operations or have identified near-term closure activities
and schedules) are required to implement ISMS/EMS. EH encourages using a graded approach
to implementing EMS at closure sites. EMS should be tailored to the nature and magnitude of the
environmental impacts at a site. It is reasonable to expect that a closure site would generally
have fewer environmental impacts than a large, operational site, and the EMS would reflect this.
Closure sites that are conducting cleanup and closure activities pursuant to the regulatory
requirements of the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) or other legal agreements (such as Federal Facilities Compliance Agreements) with
the Environmental Protection Agency (EPA) and/or State environmental agencies may have
most of the elements of ISMS/EMS in place since their primary mission is cleanup. Site
managers may wish to use the various procedures established pursuant to the above-mentioned
laws as the basis for the site's ISMS/EMS. In some cases it may be sufficient to simply
document the existing procedures and show how they cross-walk with the ISMS/EMS
framework.
An ISMS/EMS can also be used as a framework to facilitate the transfer of a closure site from
one organization to another and could address issues such as institutional controls and post-
closure care.
6. SENIOR MANAGER ROLES AND RESPONSIBILITIES IN SUCCESSFUL
INTEGRATED SAFETY MANAGEMENT SYSTEM/ENVIRONMENTAL
MANAGEMENT SYSTEM IMPLEMENTATION
Specific responsibilities for senior managers are found in DOE O 450.1, paragraph 5. Some of
their key responsibilities are:
? Ensure that by December 31, 2005, all sites under their purview have implemented the
management system requirement of DOE O 450.1.
? Request through the annual Departmental budgetary process, the funding and resources
needed for implementing the requirements of DOE O 450.1.
DOE operations/field/site office manager responsibilities are found in DOE O 450.1, paragraph
5d. Some of their key responsibilities are:
? 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.
? Ensure contractors with approved ISMS descriptions update the ISMS descriptions, as
necessary, to include the EMS requirements of DOE O 450.1.
Additional requirements are found in their entirety in paragraph 5 of DOE O 450.1.
6.1 SUPPORT THE INTEGRATED SAFETY MANAGEMENT SYSTEM/
ENVIRONMENTAL MANAGEMENT SYSTEM
For the successful implementation of ISMS/EMS, the entire site should be involved and senior
management must make it clear to everyone that they fully support the implementation of the
ISMS/EMS. Senior manager sets the tone and priority for implementing ISMS/EMS. One way
this can be done is through endorsing and communicating the site's environmental policy.
A strong, clear environmental policy statement emphasizing principles such as regulatory
compliance, pollution prevention, and continual improvement is the first step to ensuring all
employees know what is expected of them as they perform their jobs. Although organizations
usually measure ISMS/EMS performance by assessing progress toward reducing identified
environmental risks, it is the environmental policy that typically provides the ultimate
benchmark of the system's performance.
Everyone at the site or facility should be aware of the policy and understand the senior
manager's commitment to it. ISMS/EMS successful implementation can be enhanced by the
senior manager's clearly communicating the system's benefits and maintaining the
organization's focus during the implementation process.
Commitment of adequate resources, including personnel and funding, is another effective way of
showing senior management commitment, and will also promote buy-in and support from other
leaders and contractors.
6.2 PROVIDE OVERSIGHT AND GUIDANCE
Senior manager oversight, guidance, and encouragement are essential for maintaining
momentum over the course of the implementation process. Periodically, senior managers should
take the time to review how well the ISMS/EMS is being implemented. They should ask is the
EMS working as planned. Is it getting the organization to where they want it to be? Are the
number of environmental violations going down? Is it being cost-effectively implemented? If
not, they should identify and implement corrective actions to put the ISMS/EMS back on track,
and they should continually monitor the performance of the ISMS/EMS
When the senior manager maintains interest, members of the staff also stay focused. The senior
manager must be personally involved in ISMS/EMS management reviews and issue specific
direction as needed.
6.3 PROMOTE THE USE OF ENVIRONMENTAL MANAGEMENT SYSTEM
TOOLS AND TRAINING
Senior management emphasis on continual improvement through the use of guidance documents
and training are keys to successful implementation of ISMS/EMS. They may wish to consider

developing a number of courses which focus on the nature of the work done by different people
at different levels in the organization. For example, ISMS/EMS training for workers on the floor
would be different from training for middle level managers. Some DOE-specific guidance,
training, and implementation tools are available to at http://www.eh.doe.gov/oepa/. EPA also
has EMS information resources available to all Federal agencies at http://www.epa.gov/ems/, and
OFEE has EMS templates and training modules available at
http://www.ofee.gov/ems/resources/templates.html.
6.4 ENGAGE THE LOCAL COMMUNITY
Senior managers frequently interact with citizen advisory boards, local community leaders, and
other stakeholders. Implementation of the ISMS/EMS initiative can provide these groups with a
positive message regarding a site's commitment to environmental protection and stewardship.
Communicating the ISMS/EMS process to the local community will help to enhance the
Department's credibility and promote the visibility of DOE's commitment to the protection of
the environment.
7. CONCLUSIONS
Implementing an ISMS/EMS shifts the environmental protection program focus to a
management system that relies on line management accountability to ensure early detection of
potential environmental problems so they can be avoided and/or mitigated. Managers can embed
this proactive approach into the everyday business processes and mission activities.
Environmental concerns then become part of the critical path to achieving mission goals and
workers know they are held accountable for achieving environmental results.
In addition to accomplishing mission-related work ISMS/EMS is a valuable tool for achieving
and maintaining environmental compliance, and minimizing regulated and non-regulated
environmental impacts, thereby saving money.
Effective ISMS/EMSs also serve to increase environmental awareness and life-cycle
accountability for everyone working at a DOE site and to integrate these values into all aspects
of the Department's work.

The level of management that has the authority to make decisions for the site or facility.
Program Secretarial Officers, the Administrator of the National Nuclear Security Administration, Administrators
for the power administrations.
AVAILABLE ONLINE AT: INITIATED BY:
http://www.directives.doe.gov Office of Environment, Safety
and Health
DOE G 450.1-1 1
DRAFT XX-XX-03

DOE G 450.1-10 i (and ii)
10-25-04

DOE G 450.1-10 iii (and iv)
10-25-04

2 DOE G 450.1-10
10-25-04
DOE G 450.1-10 1
10-25-04

DOE G 450.1-10 7 (and 8)
10-25-04