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EFCOG Best Practice #12

Defining and Implementing an Environmental Management System at a Large Complex Facility using Activity Based Compliance

Facility: Idaho National Engineering and Environmental Laboratory, (INEEL) Idaho Falls, Idaho

Point of contact:

  • John S. Irving, BBWI/INEEL Phone: 208-524-4594 E-mail: jsi4@inel.gov

Brief description of the Best Practice

The INEEL uses an activity-based compliance concept in association with a work control approach to help satisfy the environmental requirements of Integrated Safety Management (ISM) and an Environmental Management System (EMS). As a result, activity-based compliance became part of INEEL’s work control process.

Integral with developing and using an activity-based compliance concept is designing a ‘change control’ process to accommodate change in work activities and requirements. To address this, we use an environmental review process (referred to as the Environmental Checklist [EC] Process), to integrate regulatory review into the activity-based concept. In addition, we use a strict requirements mapping process to track change.

Initially used to trigger an environmental review under the National Environmental Policy Act (NEPA), we modified the EC Process to serve as the notification mechanism to company environmental personnel of all new or modified facilities, equipment, processes or activities. Upon completion of review, the EC identifies (1) new work activities (2) applicable environmental requirements and  implementing instructions, and (3) the impact significance and level of environmental review under NEPA, such as a categorical exclusion, an environmental assessment, or an environmental impact statement.

We document INEEL’s environmental programs and responsibilities in a single program document to clarify roles and responsibility, set accountability for work and identify the accepted systems to perform environmental work. The Process integrates the ISO 14001 EMS structure with INEEL’s other infrastructure such as activity management systems, document control, records management, environmental monitoring programs, performance measurement, and training, all part of the overall Integrated Safety Management System (ISMS). The result is an effective, well integrated environmental, safety and health work and operations control process.

We believe INEEL’s EMS meets the challenge to integrate new and existing systems into a cohesive EMS. The elements leading to the success of INEEL’s EMS include (1) converting from an expert-based system to an activity-based system, (2) developing an activity-based approach to requirements management that include change control, (3) relating environmental aspects and specific hazards with work activities, (4) using existing systems and integrating them to meet ISO 14001 requirements, and (5) integrating environmental, safety, and health instructions into the work control process.

Why the best practice was used:

The EMS integrates environmental protection, pollution prevention, and regulatory compliance into work planning and execution throughout all work areas as a function of the ISMS. We developed the EMS program elements to integrate with the five core functions of ISM and the elements of the ISO 14001 standard. The EMS provides effective protection to workers, the surrounding communities and the environment through implementation of the ISMS, at the same time meeting operating objectives and compliance with regulations.

What are the benefits of the best practice

Integrating worker involvement through the Voluntary Protection Program (VPP), and environmental management through an effective EMS, into a broad work control system such as the ISMS strengthened INEEL’s work control process, and environmental management system.

What problems/issues were associated with the Best Practice

Although met with significant implementation challenges, the INEEL completed the ISMS and first evolution of the EMS in the fall of 1999 and the Department of Energy (DOE) verified ISMS as complete at the INEEL in the first half of 2000. As part of the ISM process, DOE required the INEEL to obtain ISO 14001 Certification. To meet this challenge, the INEEL took new steps to align its processes with the ISO 14001 requirements. Those included:

  • Identifying required ISO 14001 elements from existing infrastructure, and modifying these, where required
  • Identifying environmental aspects of work activities
  • Developing criteria to identify significant impacts
  • Identifying work activities with significant environmental impacts and aspects
  • Identifying operational controls for work activities that had the potential to significant impact the environment
  • Integrating existing performance evaluations processes with the significant environmental aspects process
  • Developing and implementing training.

Management and workers found it difficult to change from a discipline oriented (or media-based) approach to a work activity approach. However, the most resistance came from environmental professionals who thought that their jobs were in jeopardy.

ISMS bore much of the cost of developing a robust EMS by developing or improving supporting systems such as those associated with training, records, and document control. Others just beginning to develop an EMS may need to fund creation or improvement of similar systems.

How the success of the Best Practice was measured

We measure success of the EMS in two ways: First, since 1999, Federal & State regulators have issued fewer ‘Notices of violation.’ Before 1999, an annual fine in the hundreds of thousand dollars was typical. Since implementing the ISM and EMS, fines have dropped to below $20,000. Second, ISO 14001 certification (June 2002) shows the success of the EMS and supporting systems. In addition, the INEEL has successfully undergone three subsequent surveillance audits.

In time, we believe the EMS will help workers become more aware of their potential impacts on the environment and what they can do to control those impacts, thus resulting in fewer impacts to the environment.

Description of process experience using the Best Practice:

We developed the Environmental Management System (EMS) programs and processes over several years. This effort included developing new management systems, integrating and modifying infrastructure, and integrating other process improvements and initiatives. Today, INEEL’s environmental policy is the basis for the EMS; the proper identification and understanding of the work activities, their environmental aspects and environmental

impacts; and structured implementation of controls to mitigate impacts and comply with applicable requirements: important elements of an EMS under the ISO 14001 EMS standard.

In 1998, the paradigm in implementing work processes at the INEEL began shifting from a subject matter expert-based compliance system that focused on compliance with regulatory disciples, to a system that focused on the work activity itself. Two independent forces: 1) the DOE ISMS initiative and 2) a fresh look at how environmental activities could be performed triggered this shift. We coined the concept of "activity-based compliance" and a new requirements management and implementation process began at the INEEL. This involved the identification of work activities associated with environmental regulations, identification of requirements for each activity, and development of easily understood implementing instructions. We developed a seven-step process, and subsequently deployed at the INEEL.

At the INEEL, ISM combines all the elements of environment, safety and health (ES&H) into one system focused on accomplishing work safely. ISM uses five basic core functions to integrate processes to plan work, work safe, and work within proscribe environmental regulations:

  • Define the Scope of work
  • Identify the hazards
  • Mitigate the hazards
  • Perform work within their controls, and
  • Lessons learned, feedback, and continuous improvement.

The INEEL successfully completed ISMS verification in the fall of 2000. The "safety" in Integrated Safety Management also includes protection of the public and the environment. In fact, ISMS integrates ES&H values to protect employees, the public, and the environment from adverse consequences.

Through the VPP, a program that brings worker safety involvement into the ISMS, the INEEL incorporates the highest safety standards in the DOE Complex and the following elements:

  • Management Leadership
  • Employee involvement
  • Worksite analysis
  • Hazard prevention and control
  • Safety & health training.

INEEL received VPP Gold Star status in the summer of 2001, and was the first national laboratory in the DOE program to achieve Star status.

Like the VPP, we designed the EMS to successfully integrate environmental protection and compliance into the company ISM culture. It is important to recognize that we have integrated the functions, processes, and responsibilities found in INEEL’s EMS and ISO 14001 Core Elements with the VPP Elements and ISM Core Functions.

At the INEEL, we perform activities following the principles of the plan-do-check-act cycle, which also fits nicely within ISO 14001. Through the process, the INEEL plans company activities using daily work planning and project, program, and long-range work planning. Each of these planning functions requires properly defining work scope, identifying environmental aspects, specific hazards, compliance risks, impacts, and applicable environmental requirements, and developing procedure, plans, and other work instructions and controls.