Implementing an environmental management system, EMS

The main steps in implementation of an environmental management system, EMS, are:

1. Commitment by top management to developing the EMS
2. Planning the EMS project
3. Planning the EMS
4. Implementing the EMS
5. Internal checking of the EMS
6. Certification of the completed EMS

Step 1. Commitment by top management to developing the EMS

Management commitment is crucial since they has to allocate resources, and have to have an understanding of the scope, expected deliverables. A project have to be set up and the need for external support have to be evaluated. The project must be clearly announced throughout the organization and driving project leader have to be appointed 

Step 2. Planning the EMS project 

The project now starts. The implementation of an environmental management system is not a one-man show; identification, assessment and documentation of environmental aspects involves all functions of the organization whose activities could interact with the environment. It is also important to train the key persons early in the project, since the lead-time can be significantly shortened if the key members of the teams have been provided with specific training on the basic requirements of an environmental management system.

The project leader and the project team also have to establish an action plan where milestones and responsibilities should be identified. The team have to define the physical and organizational scope carefully, paying particular attention to organizational boundaries, management systems for health and safety and quality, suppliers, customers use of products, off-site work and new projects. It is e.g. of special importance to identify overlaps with ISO 9001 (quality control) and other management system since many of the modules used by an EMS can be found in ISO 9001 and other systems. If the quality system is efficient and effective, it will probably be appropriate to re-use those modules.

Step 3. Planning the EMS 

The EMS project team should first identify the organization's environmental performance. An initial review will provide much useful information about the company's current status in terms of environmental compliance, potential liabilities and environmental opportunities. The initial review should also identify and rank the environmental requirements and aspects of the organization's work to identify the most significant ones and those that need to be controlled and monitored. 

The team together with top management have to agree on objectives and targets for site environmental performance and the team have to design a EMS program to achieve these objectives.

To help the planning one could ask for other companies' experience, since lots of useful information can be obtained from companies already having implemented an EMS. 

Step 4. Implementing the EMS 

The next step is to design and produce the documentation. In particular, the environmental manual and procedures and work instructions necessary to implement the program. For example, working instructions relating to waste management, chemical handling, transports or other significant environmental aspects.

EMS project team and relevant parts of the organization have to identify, needed to  establish and ensure a proper functioning of the EMS. the management of significant aspects and the monitoring program needed to track the site's progress towards meeting its objectives.

The team also have to ensure that all employees are provided with general training and if needed, specific training, on environmental matters.

Step 5. Internal checking of the EMS 

When the EMS is in place the team has to check the completed documentation against the standard to ensure all requirements have been. 

Step 6. Certification of the completed EMS

In a initial visit the certifiers review the processes on site and the various operations of the EMS. There is a possibility to close-out any non-conformances found by the certifiers.

At the audit visit, the certifiers conduct a detailed audit of the functioning EMS.  When everything is OK the organization can be certified! 

There will be follow-up audits where the certifiers will visit the site. The sequence for the surveillance visits is however negotiable. The most common period between the visits is currently 6 months, but, based on experience, the time between the visits tends to become longer

Suggested milestones in a generic approach to achieve a certified EMS

Below are suggestions for generic milestones in the project plan to achieve a certified EMS. The milestones do not have to be achieved exactly in this order. The milestone is reached when:

1. management support has been obtained and resources agreed. 
2. the legal requirements have been identified. 
3. an initial review of the business has been completed and when the company's environmental aspects have been identified. 
4. a milestone plan for the EMS project has been agreed. 
5. policy, objectives, targets have been agreed. 
6. the environmental program has been agreed. 
7. system procedures, work instructions, and controls have been designed and issued. 
8. metrics / feedback on environmental performance are in place. 
9. key staff has been trained and all staff are aware of the company's program 
10. the audit program is running.
11. the first management review has taken place.
12. the EMS has been checked against the standard.
13. the EMS has been checked against significant aspects.
14. the EMS has been checked for loop-closure.
15. the initial visit by the certifier has taken place.
16. the audit visit has taken place.
17. certification has been obtained.

The above approach is not strictly sequential. Some of the actions may take place over a period. Others may be addressed in a slightly different order.

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