Requirements for an Environmental Management System

An environmental management system developed in lieu of a toxics use reduction plan shall contain the following elements: (1) A written environmental policy that expresses management for, and makes a commitment to: (a) compliance with environmental legal requirements; (b) pollution prevention through source reduction and toxics use reduction; and (c) continual improvement of the EMS and environmental performance. (2) A process for identifying significant environmental aspects and impacts from current and future activities at the facility. All covered toxics shall be identified as significant environmental aspects. (3) Identification of environmental legal requirements, including a system for tracking compliance and learning about and integrating changes to legal requirements into the EMS. (4) A process for establishing measurable objectives and targets that address significant environmental aspects and other EMS commitments and that emphasize preventing pollution at its source. (5) Environmental management programs designed to make progress toward achieving objectives, targets, and commitments in the EMS, including the means and time-frames for their completion. (6) Established roles and responsibilities of the facility’s staff and management, on-site service providers, and contractors for meeting objectives and targets and complying with legal requirements, including a senior management representative with authority and responsibility for the EMS. (7) Environmental and compliance training for employees and contractors whose jobs and responsibilities involve activities directly related to significant aspects, achieving objectives and targets and compliance with legal requirements, and initiation training for new personnel. (8) Procedures for communicating environmental and EMS information throughout the facility, including EMS awareness programs for all employees. (9) Operational controls to ensure that equipment and other operations comply with legal requirements and address significant environmental aspects. (10) Documentation of key EMS elements and procedures for document control and records management. (11) Emergency preparedness and response procedures. (12) Procedures for monitoring and measuring key operations and activities to assess environmental performance. (13) Procedures for preventing and detecting non-conformance with legal and other require­ ments of the EMS, including an established compliance audit program and an EMS audit program, and procedures for corrective actions to ensure timely compliance and commitment to continual improvement. The EMS audit program shall require independent auditing on at least a two-year cycle and senior management review of audit results. (14) Documented management review of performance against objectives and targets and the effectiveness of the EMS in meeting policy commitments.