Plan - Initial Development of an EMS

The first phase of the PDCA cycle is "Plan." During this phase, an organization identifies and establishes various parts of its EMS. For example, the organization identifies the ways that its operations may impact the environment (e.g., environmental aspects) and establishes detailed environmental goals (or environmental objectives).

the four phases of the Plan-Do-Check-Act cycle, beginning with Plan

The information below illustrates the first 12 steps in the multi-step EMS planning process. 

Step 1: Explore Context of the Organization

The first thing an organization must do is decide why it is pursuing the development of an EMS. Understanding the motives will allow the organization to develop an EMS that is tailored to meet its needs, interests and goals. This exercise requires the organization to explore a variety of questions, such as:

  • Do we need to improve environmental performance?
  • Are we in full compliance with laws and regulations?
  • Do we want to prevent pollution and reduce environmental hazards (e.g., toxic waste and hazardous chemicals)?
  • Do we want to improve our organization's reputation?
  • What are the internal and external issues that are most relevant to our organization?
    • Air quality, climate change, water quality, land use change and contamination?
    • Other issues: cultural, social, political, economic, financial and/or regulatory?
    • The organization’s activities, products, services, culture, capabilities, and strategic direction?

As part of the process, the organization will need to:

  • Identify All Interested Parties (Internal and External). Focusing on stakeholders, the organization must determine who is interested in or affected by its decisions or activities related to environmental management and what these interested parties need or expect from the organization. Examples are provided here.
 
Interested Party Need/Expectation
Local or Federal Government Compliance with environmental regulations 
Neighbors Disclosure about local environmental impacts 
Employees or Contractors Safe and healthy workplace
Customers/Public Sustainability reporting, disclosure about impacts, environmentally friendly supply chain
Shareholders Environmentally friendly image
  • Develop the Scope of the EMS. The organization must define the scope - the physical and organizational boundaries - of its EMS. For example, it must decide if the EMS will cover the whole organization or only certain parts. The scope should include the activities, products, services, and facilities that the organization can control and influence either through direct ownership, its purchasing power, or its authority or jurisdiction.

Step 2: Secure Leadership Commitment

A critical step in the planning process is securing top management's commitment and support for EMS development and implementation. Management needs to assess the strengths and limitations of the organization's existing approach to environmental management, examine the impacts of noncompliance and negative media attention from poor environmental performance, learn about the benefits of having an EMS, and be informed of the resources required to establish and maintain the system. To ensure success, top management should make sure that the EMS goals are consistent with other organizational goals and that they are clearly and frequently communicated across the entire organization.

Step 3: Establish an Environmental Policy

Each organization should establish an environmental policy that is consistent with its goals and values. The policy, which should be established by the highest levels of management, will become the organization’s formal commitment to reducing environmental impacts and achieving continual improvement. It should be available to the organization’s interested parties.

Step 4: Determine Roles and Responsibilities of the EMS Team

The EMS team bears responsibility for ensuring that the organization's EMS is implemented and maintained properly. Organizations should clearly define team members' roles and responsibilities up front, so they understand expectations. Key activities that must be completed during this step include:

  • Select an EMS Champion:  The organization should select an "EMS champion" to spearhead EMS development and continued implementation, and to advocate for the EMS during meetings with top management. The champion should have the necessary authority, an understanding of the organization, and project management skills. The champion should be a "systems thinker" (ISO 14001 experience is a plus but is not necessary). They should have support from other managers, as well as the time to commit to the EMS-building process. 
  • Build an EMS Team:  The EMS team should include representatives from key organizational functions (e.g., engineering, acquisitions, finance, human resources, laboratory and field operations, production and/or service, distribution).  The EMS team should be able to identify all existing activities within the organization. If possible, organizations should include external parties, such as contractors and suppliers, as part of the EMS team, where appropriate. Having a cross-functional team led by an effective EMS champion helps ensure balanced and diverse input on environmental performance and effective communication with all programs and employees within the organization. These conditions - diverse input and effective communication - increase the likelihood that the EMS team will identify environmental concerns in all areas and aspects of the workplace.

Step 5: Hold Kick-off Meeting

Once the EMS team is established, it should hold a kick-off meeting with top management to ensure that everyone is motivated to implement the EMS and supports the organization's environmental policy (discussed under Step 3). During the meeting, it is critical to make sure that everyone understands their roles and agrees on the initial steps that need to be taken to support the EMS. Next, the team should follow up with a communication to all employees, informing them of the plan to implement an EMS and explaining what they should expect going forward. The communication should also identify ways for employees to ask questions and share suggestions about environmental goals with the EMS champion.

Step 6: Determine Environmental Aspects and Impacts

The EMS team should identify all of the organization’s environmental aspects and impacts. An environmental aspect is the part of an activity, product, or service that interacts with the environment; it is the cause of an environmental impact or change to the environment. When generating a list of environmental aspects and impacts, the EMS team should think about whether the organization’s activities (during regular operations or during a foreseeable emergency) could involve:

  • Emissions to air
  • Releases to water
  • Releases to land
  • Use of natural resources
  • Use of energy
  • Generation of waste

Some of the organization’s environmental aspects may have more significant environmental impacts than others; these are called significant environmental aspects. The organization will need to establish criteria to determine which of its aspects are significant. For example, your criteria may include the frequency of the activity (how often it occurs), the potential consequence (ranging from minimal/negligible effects to longer-term damage or severe effects), whether there are legal requirements or compliance obligations associated with the aspect, and the level of stakeholder interest.

Identifying significant environmental aspects helps organizations determine how they should prioritize and leverage resources to ensure that they are making the most impactful changes. Once identified, significant environmental aspects should be:

  • Controlled to reduce their environmental impact;
  • Considered when setting environmental goals;
  • Handled by trained and competent individuals; and,
  • Monitored and/or measured.

Step 7: Identify Compliance Obligations

The organization must identify the compliance obligations that apply to its activities, products, and services. For example, does it perform operations that require an air quality permit, or does it create a product that generates regulated wastes? Compliance obligations may include mandatory requirements, such as laws and regulations, or voluntary commitments, such as industry standards, agreements with community groups, or contractual relationships. Reviewing the expectations of interested parties (addressed in Step 1) may reveal relevant compliance obligations. The EMS should include processes to ensure that the organization acts in conformance with all compliance obligations.

Step 8: Prepare Budget and Secure Resources

The EMS team should prepare an initial project plan and budget that describes what key actions must be completed to support the EMS, who is responsible, what resources are necessary and when work will be completed. In developing the project plan and budget, the team should consider the needs associated with initial EMS implementation as well as continued maintenance. The initial plan and budget will become more detailed as the EMS implementation process progresses and the organization's environmental goals become better understood. Top management should review and approve the initial plan and budget.

Step 9: Set Environmental Objectives and Action Plan

Goal setting is a critical step: organizations need to establish environmental objectives to establish a clear vision of what they hope to accomplish. The objectives should be consistent with the organization’s environmental policy, compliance obligations, and environmental aspects and impacts, as well as the views of interested parties. Ideally, the objectives should be “SMART.”

  • Specific
  • Measurable
  • Achievable
  • Relevant
  • Time-bound

The following are examples of smart objectives:

  • By end of the year, reduce water consumption at all facilities by 5% as compared to the previous year’s consumption.
  • By end of the year, reduce the disposal expired chemicals by 15%.
  • By end of fourth quarter, achieve a waste diversion rate of 50%.

After the environmental objectives are set, the EMS team should create an action plan that outlines a strategy for achieving the objectives and identifies who is responsible for ensuring success.

Step 10: Identify Operational Controls, and Monitoring and Measurement Needs

Next, the EMS team should identify operational controls that can be implemented to control environmental aspects and minimize environmental impacts. Operational Controls can take many forms, such as policies, procedures, plans, or other actions; see Step 16 for examples. The organization must also determine what monitoring and measurement activities should be conducted based on its environmental aspects, impacts and objectives. To start, it may be helpful to ask the following questions for certain operations or activities:

  • Are we currently able to control the environmental aspects associated with this operation or activity?
  • Are the existing controls adequate to meet our objectives and to ensure compliance?
  • What type of monitoring/measurement is needed to track progress in achieving objectives?
  • How can we determine whether operational controls are working as designed?

Step 11: Define Roles and Responsibilities for Specific Environmental Tasks

Step 4 spoke about the EMS team, but many other people within the organization must step forward as environmental stewards to achieve meaningful and sustained environmental improvement. The EMS team should communicate clearly with those who have a key role in implementing specific environmental objectives and ensure that they understand their responsibilities. For example, the EMS team may need to rely on fleet managers to reduce petroleum use, facility managers to shut off unneeded lights, acquisitions staff to purchase environmentally friendly products, and custodial staff to select less toxic cleaning agents. It’s best to document these responsibilities to ensure that relevant competency training is in place.

Step 12: Establish Other System-Level Procedures

A variety of procedures should be developed up-front to ensure that the EMS runs smoothly. For example, the organization should make sure it has an adequate Emergency Action Plan that addresses onsite hazards (e.g., flammable liquids, storage tanks, compressed gasses, potentially dangerous chemicals) and establishes a procedure to prepare for potential emergencies. The EMS team may also need to lead the development of system-level procedures to address the following questions:

  • Which employees needs to be trained, how often, and what topics need to be covered (especially related to significant environmental aspects)?
  • Who will handle internal and external environmental communications, and how?
  • How will the organization control documents and manage records?
  • What process will be used to audit the EMS (internal and/or external)?
  • What process will be used to implement corrective actions when nonconformances are identified?
  • Who will deliver EMS status reports to top management, how often, and in what format?

The next phase of the PDCA cycle is "Do - Implementing an EMS."

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Last updated on March 27, 2024