Environmental Management Systems and ISO 14001: Federal Facilities Council Report No. 138 (1999)

Mary McKiel

Director

Standards Network

Remember that, although there is an accreditation program associated with ISO 14001, the standard does not require any kind of registration or certification. Its use is completely voluntary. If a federal agency, for example, wishes to follow ISO 14001 as the basis for management of its environmental responsibilities, then it can choose whether to go through the certification process. ISO 14001 and certification are tools for organizations to use whether the organization is a federal agency, a corporation, or an academic institution.

The number of academic institutions across the country that are using ISO 14001 not only as a facilities-based management approach, but also as an approach to developing interdisciplinary curricula, is increasing. If you look to the future and project the direction that the environmental protection paradigm will take, the question arises of how to train people to meet the challenges created by this new kind of integration. It is encouraging that academic institutions are taking on this challenge.

The U.S. Environmental Protection Agency (EPA) has been examining pollution prevention since enactment of the Pollution Prevention Act. The agency has focused on compliance and enforcement as its fundamental mission. EPA exists to enforce regulations and to provide for compliance. At some point the question had to be asked as to how the United States addresses environment-related issues that are not regulated. What about efforts to avoid causing pollution in the first place? EPA has had a strong pollution prevention program that has been growing in strength, especially for the past five years.

Into this debate comes the voluntary ISO 14001 standard. It appears to be compatible with the goals and movement toward pollution prevention, and so, EPA is evaluating its utility. In addition to ISO 14001, EPA is looking at

other industry programs. It recently published an agency policy that essentially says that environmental management systems (EMSs) are good systems for organizations to use. ISO 14001 appears to have a framework for a good EMS. However, at this point, EPA will not be offering additional benefits or incentives to organizations that undertake ISO 14001 registration. EPA needs to understand whether any correlation exists between the use of ISO 14001 and the tendency of organizations to achieve or even exceed compliance or to improve their overall environmental performance. Consequently, EPA is involved in a series of pilot projects and is evaluating the results.

Sarah Walsh

Project Manager

Federal Facilities Enforcement Office

The Code of Environmental Management Principles (CEMP) was developed by the U.S. Environmental Protection Agency (EPA) in response to Executive Order 12856, Federal Compliance with Right-to-Know Laws and Pollution Prevention Requirements which was signed on August 3, 1993. This order contains a requirement to establish a federal environmental challenge program.

Another component of the executive order is to have federal agencies agree to a code of environmental principles, emphasizing pollution prevention, sustainable development, and state-of-the-art environmental management programs. In addition, these agencies would have to agree to submit applications to EPA for individual federal facilities to be recognized as ''model installations.'' Agencies are also to encourage individual employees to demonstrate outstanding leadership in pollution prevention. Upon receiving this directive, EPA formed a task force and, in October 1996, it published the CEMP.

Since then, many federal agencies have endorsed the CENT on an agencywide basis with flexibility on environmental management system (EMS) implementation at the facility level. Agencies endorsing the CENT include the Central Intelligence Agency; the U.S. Postal Service (USPS); the Departments of Commerce, Defense, Treasury, Energy, Health and Human Services, and Transportation; EPA itself, the Tennessee Valley Authority (TVA), and others. Many agencies have begun creating and developing plans that help to improve the EMSs at their facilities. Some of these plans are using the model CEMP whereas others are using ISO 14001. Still others are using a hybrid of the two.

The USPS, for example, has an integrated program in which it incorporates its EMS into its existing business plan called Customer Perfect. TVA has integrated its approach into its existing environmental management responsibilities, and EPA has incorporated many health and safety considerations into its plan. When speaking about CENT, it must be distinguished from ISO 14001. EPA does not advocate one system over the other.

The CEMP has five principles that are also contained in the ISO 14001 standard CENT addresses compliance assurance, and pollution

prevention specifically, a distinguishing difference from ISO 14001. Another difference is that CEMP is a tool and a model, but not a standard.

The first principle of the CEMP is management commitment. Agencies must make a written top-management commitment to improved environmental performance. Policies must be established that emphasize pollution prevention and the need to ensure compliance with environmental requirements.

The second principle deals with compliance assurance and pollution prevention. The agency implements proactive programs that aggressively identify and address potential compliance problem areas and utilize pollution prevention approaches to correct deficiencies and improve environmental performance.

The third principle, enabling systems, calls for the agency to develop and implement the necessary measures to enable personnel to perform their functions in a manner consistent with regulatory requirements, agency environmental policies, and agency mission.

Performance and accountability are the mainstays of the fourth principle. The agency develops measures to address employee environmental performance and ensure full accountability of environmental functions.

The fifth principle focuses on measurement and improvement. The agency develops and implements a program to assess progress toward meeting its environmental goals and uses the results to improve environmental performance.

Table 3-1 shows the correlation between EMR disciplines, the CEMP, and sections of ISO 14001.

The Federal Facilities Enforcement Office of EPA has developed three tools to assist agencies in implementing EMSs. The first is the EMS Primer, available on the internet at http://www.epa.gov/oeca/fedfac/emsprimer.pdf. The second is the implementation guide for the CEMP. A third is the environmental management review (EMR) program.

The EMS Primer, developed jointly by EPA and the Department of Energy (DOE), offers tips to an agency that is creating a plan. These tips are designed primarily to help people who are starting from the lower ranks of the organization. It has specific suggestions for those who want to "sell" the concept to an organization's management. It outlines EMS elements and explains their benefits. The EMS Primer also places EMS in the context of regulations and compliance issues, the Government Performance and Results Act, pollution prevention, and other government activities.

The implementation guide, in contrast, addresses the CEMP, describing each principle and its supporting performance objectives. It provides possible agency actions to achieve each principle, as well as a self-assessment matrix for agencies to follow in implementing the CEMP. The matrix describes stages of CEMP implementation and shows five levels of accomplishment for each performance objective.

The EMR program is an evaluation of federal facilities' environmental programs and management systems. EMRs include consultative technical assistance visits intended to identify root causes of environmental performance problems. EMRs are voluntary and often are initiated by federal agencies that request and receive their reviews. EMRs are a tool to help facility, personnel attain the CEMP and move toward the ISO 14001 standard. EMRs are not compliance-oriented assessments, audits, or inspections, nor are they pollution prevention opportunity assessments.

The EMR was originally piloted in EPA Region One, the New England area. A team comprising EPA employees and contractors would go to a federal agency and provide technical or management assistance to help the agency staff create an EMR. All 10 EPA regions are now capable of providing assistance to perform these reviews.

Many initiatives are under way at EPA for providing guidance. The Cincinnati office has put together a resource directory dealing not only with EPA and other federal agency initiatives, but with state, nonprofit, and international initiatives as well. Another resource available on the Internet gives users access to EPA's Envirosense system (http://www.epa.gov/envirosense). Anyone can access information on EMRs of federal facilities, compliance and enforcement, and technical/research and development information. (See Appendix B for a more complete list of resource documents.)

John L. Stirling

Senior Environmental Protection Specialist

Office of Environmental Policy and Assistance

There has been a gradual shift away from traditional compliance in environmental protection to a more preventive mode that adopts a systems approach and examines ways to make that system effective. Managing costs is an issue of increasing importance for environmentalists. The Department of Energy, (DOE) is now on the verge of addressing the performance of its management systems, including what it costs to implement them.

DOE has been affected by declining resources, as have other agencies, both in terms of staffing and dollars. Its operations have come under increased scrutiny from the public. DOE is expected to achieve more, improve performance, and increase competence. In addition, DOE is expected to demonstrate to the public, Congress, and state regulators that it is accountable for its publicly authorized funds and is effectively executing its mission. As a management system, ISO 14001 can help DOE demonstrate excellence in accomplishing these objectives.

DOE's basic approach to EMSs is quite simple. The department wants effective programs supported by management systems that are cost-effective and continually improving. However, DOE faces a series of challenges in achieving this. Its missions include very different types of activities. For example, DOE fosters energy efficiency; maintains strategic petroleum reserves; and produces, sells, and distributes electric power. It is also responsible for the cleanup of numerous radioactive and hazardous wastes at the nation's nuclear production sites, for on-going stewardship of U.S. nuclear materials, and for leadership in nuclear safeguards and nonproliferation efforts around the world. Supporting each of these functions, DOE also provides major scientific and educational efforts through its National Laboratories.

These missions are conducted in a highly decentralized way in dozens of unique facilities across the country. In some cases, different types of mission activities sit side by side (e.g., a laboratory and cleanup site). In other cases, related mission elements are in widely distributed locations. Further complicating the task, over 90 percent of DOE's budget is spent on competitively awarded contracts rather than salaries for federal employees. Thus DOE's approach to environmental protection must be useful to federal employees making policy and exercising oversight as well as to contractors determining how to carry out these policies. It must be an integral part of the agency's business management practices.

DOE is also responsible for relating environmental protection to protection of workers and the public. In response to a recommendation from the Defense Nuclear Facilities Safety Board, DOE has developed an Integrated

Safety Management System to address all three issues. The system is still being developed and an important challenge is to ensure that environmental protection is a strong component. An EMS, such as ISO 14001 or one based on its tenets, can be that component of the larger integrated management system.

ISO 14001 uses a systems approach, which is critical. It ensures that operations are designed to reduce pollution and continually improve. It is designed to support regulatory compliance although it is not fundamentally a compliance-based approach. It also can help to integrate environmental protection as an activity into the organization's management systems.

At DOE, environmental protection activities tend to be placed in overhead budget categories. Thus, no single entity is accountable for managing them and costs are difficult to control. An EMS approach helps organizations to define more clearly the roles and responsibilities for environmental activities, often identifying gaps and overlaps that prove costly. It also raises awareness at all levels and institutionalizes commitments to preventing pollution. If an organization integrates the EMS into its broader management systems, environmental considerations then can be linked to strategic planning and budgeting processes, and program and project management activities. This makes an EMS more rational and manageable, and links it to other established systems.

Reviews of EMSs at DOE facilities found that most already had many, if not all, elements of ISO 14001 in place. Frequently, they were lacking some elements, such as a policy statement, or maybe roles and responsibilities were not clearly delineated. Sometimes elements needed to be better integrated or strengthened. An EMS can help to improve the effectiveness and efficiency of operations while reducing costs, and helping ensure compliance because of the systems approach to identifying and reducing the impacts of its operations. This includes using performance measures, goals, and targets to reduce the impact of DOE activities, such as levels of environmental pollutants, amounts of water or energy consumed, or increases in the number of "green" products used.

DOE acquisition regulations require clauses devoted to pollution prevention and waste minimization in its contracts. The EMS is then the bridge between a management system and sustainable pollution prevention system. This is one way that pollution prevention is being institutionalized into DOE operations, using an EMS approach. The same management concepts apply to safety. Many private-sector companies are already integrating these because they are cost effective and therefore make good business sense.

DOE facilities managers have expressed a lot of interest in EMS programs. As you would expect, the approaches they have taken reflect the diversity of DOE's operations. For example, Allied Signal, DOE's contractor at the Kansas City site sought and received ISO 14001 third-party certification as part of its environmental protection strategy. At the Savannah River site in South Carolina, federal and contractor staff worked together to secure a single ISO 14001 third-party certification at a site undergoing complex restoration activities for hazardous and radioactive contamination. At the Hanford site in

Washington State, also undergoing restoration, DOE included use of an EMS in its contract documents. This has been extended further, with an EMS being incorporated into an integrated health and safety management system.

Oak Ridge National Laboratory decided to implement an ISO 14001 system within its management office. This office has five geographically noncontiguous sites, some of them in different states. Their rationale for implementing ISO 14001 is that it will set up a common management framework and improve their ability to budget for, oversee operations of, and generally better manage these five sites.

On Long Island, New York, DOE's Brookhaven National Laboratory had released tritium into the groundwater. In addition to regulatory enforcement actions, it created substantial political and public distrust. To address these issues, DOE removed the contractor, brought in a new team, and negotiated a Memorandum of Understanding (MOU) with the Environmental Protection Agency and the State of New York. Two significant elements in the MOU were the requirement for an integrated safety management system and implementation of an EMS based on the tenets of ISO 14001. The new contractor team is now implementing this system.

In sum, DOE is committed to environmental protection and to integrated safety management. However, DOE facilities managers are not required to use ISO 14001 or any other EMS. Use of ISO 14001 is voluntary. An increasing number of facility managers are evaluating — and in many cases, implementing — an EMS or ISO 14001 based on their judgment that it makes good business management sense. This is a key in the evolution of environmental protection in public agencies. DOE is expected to be more than safe, more than compliant — it is expected to be effective. ISO 14001 and environmental management systems are a powerful tool for federal managers in reaching that goal.

Rick Drawbaugh

Representing Office of the Deputy Under

Secretary for Defense-Environmental Security

In the Department of Defense (DOD), a committee has been meeting for more than one year to determine the best approach to addressing EMSs. DOD is pursuing this issue because its analysis indicates that an EMS can pay for itself through cost avoidance. Also, on the international level, DOD operates on the premise that environmental security reinforces economic security, which in turn reinforces national security.

In determining whether to implement ISO 14001, DOD asked, "Will ISO 14001

•  lower net costs?

•  improve environmental stewardship?

•  increase integration of environmental, safety, and health risk reductions into all operations and activities?

•  enhance relations with regulators?

•  change the environmental management culture from being reactive and ad hoc to a performance based focus?

•  fit with existing DOD organization and mission?

After studying the issue, those in DOD's environmental community believe that the adoption of an EMS such as ISO 14001 will improve planning and program processes and facilitate informed decision making on budgeting and resource allocations.

Environmental stewardship is one of DOD's goals. An EMS provides for an integration of activities such that, if DOD plans, implements, checks, and reviews its environmental activities, it will work across the entire organization, not just the environmental, safety, and health community, but the operational community as well. Increasing the integration of environmental, safety, and health issues will mean that the people who are responsible for those activities will work together and advocate for resources together, and thus enhance environmental stewardship.

There have been positive reactions from EPA and from the states to DOD's efforts to enhance relations with regulators. Military installations that have not always been in compliance with environmental regulations will, as a result of developing and implementing an EMS, be given consideration for fewer audits.

One positive outcome of existing EMS programs is a 90 percent reduction in notices of violations in the past six years, which leads to an important point. The DOD has had an EMS in place for more than 15 years. It just has not had the discipline established within the ISO 14001 standard, and that is why facilities have not always been in compliance.

When looking at resource allocation, the culture of DOD is to focus on compliance. One DOD objective in implementing an EMS is to have a good set of requirements and to show what the fiscal impact is going to be on overall operations. Others in the organization must be convinced that resources should be allocated to pollution prevention.

In June 1997, an interim DOD policy was issued that said it would not fund ISO 14001 third-party certification without an economic analysis showing that benefits outweighed the costs. It called for the establishment of a pilot program and stressed the importance of on-going communication on ISO 14001-related activities.

A voluntary pilot study was established in September 1997. Each service was asked to nominate sites for the study. The installations selected will participate in a two-year pilot study (see Appendix C) that will evaluate the installation's answers to a mix of quantitative and self-assessment questions. The quantitative questions focus on funding levels, regulatory findings, number of permits, and energy consumption. The self-assessment questions focus on how the installation's current environmental program works, why the installation wants to implement ISO 14001, the benefits anticipated, and on self-developed environmental metrics and performance indicators.

The pilot study allowed installations to select their own operational or mission performance metrics. Every six months, answers to the baseline questions were updated and the costs of implementation were measured.

The last part of the pilot study was the self-developed matrix and performance standards. Each group had to develop its own objectives and targets because DOD has a variety of installation types, ranging from small installations of perhaps one person to very large installations, and test installations, product centers, depots, and air logistics centers. Each has different objectives and targets. Currently, the greatest challenge they face is deciding on their standards.

There are two issues of which one needs to be wary when dealing with pilot studies. The first is the Hawthorne effect, i.e., the fact that an organization is watching the process will result in changes being noted. The second has to do with making comparisons. There is already a management system in place. Now something new is going to be overlayed. How is the real effect determined? What caused the effect? Was it the ISO 14001-like system or was

it just a matter of doing business, just a natural continuous process improvement?

One anticipated benefit of an EMS will be an improved discipline with planning and programming. Another is the DOD's standardization of environmental activities. The department's intention is to have a standard approach to doing business, not to have everyone the same. Again, DOD, has very different installations with very different activities. From the international perspective, with standardization comes a set of environmental guidelines for the military sector in 44 nations, principally in Eastern, Western and Central Europe; Africa; and North America. DOD will add guidelines for EMSs in the military sector as part of a NATO pilot study.

An EMS should provide improvements in identification and correction of negative environmental impacts, as well as improved integration of environmental activities. Relations with regulators will be enhanced and so will the DOD's compliance with regulations. An EMS also should result in increased awareness and diligence by all personnel regarding the environment. DOD also hopes to see better planning and the fostering of innovation.

Further, DOD anticipates increased competitiveness among its installations. DOD's depots and logistics centers compete for work among the services and outside the military. This is an opportunity for them to improve their competitiveness and includes them in cases in which an ISO 14001 certification is required.

The true cost of implementing an EMS often is underestimated. Not only must the cost include the outside contracting fee, but also the salaries for in-house staff devoted to the project. The total costs will vary depending upon how advanced the existing EMS is. However, an EMS should result in reduced costs in the long run.

An EMS on its own should be able to convince people that it makes good business sense, even for the DOD and national defense. DOD owns the largest amount of property in the United States of any public institution. It is critical that DOD show the public that it is a good environmental steward.

In summary, DOD believes that an EMS makes good sense. It is fully supportive of an ISO 14001-like structure, but, until the results of the pilot study are seen, it is not certain to what level DOD will encourage ISO 14001 to be taken up by the services.

ISO 14001 has many potential benefits and can improve DOD's already strong environmental program. The pilot study will help to determine whether the added benefit is worth the associated cost. If indeed the benefits are worth the cost, the pilot study will help DOD make the decision whether to mandate ISO 14001, encourage it, or leave it as an option.

Robert Stephens

Deputy Director

Science, Pollution Prevention &

Technology Program

Why are state agencies involved in implementing environmental management systems? One principal factor is to have an outcome-based system, one aimed at achieving better outcomes more efficiently and effectively. In many ways, public agencies at the state level are trying to redefine success to regulatory agencies, moving away from "bean counting" and a focus on compliance toward some measure of environmental performance. State environmental protection agencies have interpreted "environmental protection" over the past 20 years as counting compliance. More and more of these agencies are realizing that there are potentially much better ways to define environmental protection. They are exploring ways to measure what their missions are supposed to be in the first place, that is, environmental protection.

"Compliance" means compliance with the federal laws, a set of standards that were point-in-time concepts relating to environmental performance and protection. In some cases, they are fairly good measures and in others they are not. Those issues need to be revisited because, in fact, the mission of these agencies is environmental protection, environmental stewardship.

Another principal driver for state activities is credibility of the system. As EMSs, ISO 14000, and others are evaluated, along with their ability to achieve better outcomes more efficiently and effectively, credibility of the systems becomes extremely important, because state agencies are public agents. That credibility comes from open information that is valid and believable. This is not unique to public agencies, but applies to everyone who is interested in better outcomes.

In the past 10 years, there has been a growing devolution of authority to the states from the federal level. New initiatives will further this trend in the environmental arena. Stakeholders, the public, and industry are demanding a better standard of performance and resource use from the states. There has to be a better way of doing business, or many state agencies will be out of business.

Foundation policy guides on which states operate include one from the National Governors' Association and another from the Environmental Council of the States. These guides basically reaffirm the notion that states are the laboratories of democracies, that they must be innovative, exploring new ways

of working in partnership with the federal government and with the private sector.

Fifteen states are involved in the MSWG ¹, a rather informal network of professionals who have a common interest in exploring the policy implications, particularly the public policy implications, related to EMSs and ISO 14000. The working group also has other stakeholders, including two federal agencies, a growing contingent of nongovernmental organizations (NGOs), and environmental representatives. A recent addition is an NGO consortium, comprising many national NGOs and the Sierra Club. An increasing number of academic institutions and companies in the private sector also are involved. These include a coalition for the implementation of ISO 14000 made up of chemical manufacturers, the American Automobile Association, American Forest Products, and a group of 15 other associations.

The initiative is clearly a federal/state partnership, with states implementing most of the federal statutes in this country. The states view themselves as innovators, and that is why they believe that it is appropriate to look at new paradigms.

The mission and objectives of the MSWG are fairly focused. It is interested in developing information about the implementation of ISO 14001, EMSs, and other related systems in order to make responsible decisions about public policy. The first step, though, is to identify the key public policy, questions that need to be addressed. The next is to identify the information necessary to address these particular policy questions and then create a national database where this information could be deposited and accessed.

The MSWG will try to develop a system or a data quality structure such that the information that flows to the national database is credible and useful for answering the key policy questions. This is a principal focus of the MSWG. The source of the data is a series of pilot projects in the 12 to 15 states that are members of MSWG. These pilot projects are being conducted under a variety of models, depending upon the state; the main differences involve the roles that the public regulatory agencies play in partnerships with organizations implementing ISO 14000. In some cases, public agencies play a very passive role, approaching organizations for certain kinds of information about ISO 14000 implementation in key areas that could be placed in the national database for evaluation with other projects around the country. In other cases,

state and local agencies are involved in not only the design of EMSs at facilities but work with companies and other organizations to define targets and objectives, perform inventories, and make significance determinations. In these cases, the system is being built in a partnership and is generating information about the performance of EMSs.

MSWG spent its first year measuring the results of implementing ISO 14001 EMSs and the types of information generated in order to identify, the key categories of information to be tracked in support of long-term public policy questions. The result was a document called the ''Environmental Management Systems Voluntary Project Evaluation Guidance,'' published in February 1998 by the National Institute of Standards and Technology in Gaithersburg, Maryland. It contains guidance about the generation of results information in six categories: environmental performance indicators, environmental condition indicators, compliance indicators, costs and benefits, pollution prevention indicators and measures, and stakeholder preferences and confidence.

These are the six areas in which MSWG is interested in generating core information for the national database. The database has been established at the University of North Carolina and is receiving baseline data from some of the North Carolina pilot projects. A companion protocol document will translate guidance in the measurement areas into suggested protocols that show how to generate the information most useful to the national database. MSWG wants to collect and evaluate sufficient information, test performance-based multimedia strategies, and demonstrate streamlining options for multimedia permitting.

A critical element of these pilot projects is the interest in projects that are truly multimedia rather than single media. It is hoped that EMSs will attract not only organizations that are managing their facilities, but regulatory agencies that are designed around single media. Compliance assurance is essential to all of the pilot projects and is a given for participation in the group projects. It is important to show that high levels of compliance are achieved through implementation of EMSs.

MSWG is concerned about cost analysis. It also is interested in public disclosure and stakeholder participation, which can be controversial. To date, this has not been a problem in most projects. In fact, many of the organizations dealing with MSWG have good ideas about how stakeholder participation is supposed to function.

One of the issues that will be addressed as the group explores the interface of existing regulatory regimes to EMS is that of audit functions. Audits are designed to generate a certain kind of information. One topic to be explored in a number of states is whether there are different and more effective ways to generate that information, using some mix of internal audits, third-part audits, and government inspections.

Another issue is electronic reporting of information. When discussions are held about the ways in which regulatory agencies have generated and transmitted information for purposes of decision making, it is clear that those agencies are in the previous century, technologically. Huge amounts of money are spent on generating large volumes of data that often are of little use, winding up in archive boxes, on tables, or in file storage rooms somewhere. An organized management system can lead to much more efficient ways to generate better quality information that can be transmitted electronically.

Another issue being investigated is the area of permitting activities. Can an integrated system created around EMSs be used to change the way in which permits are issued, by whom they are issued, their lifetimes, and how they are monitored?

MSWG anticipates that there are over 100 pilot projects that are going to be conducted over the next one to two years to generate data on performance and results that will go to the national database.

Why would organizations want to participate and partner with a regulatory agency? Recognition. California, Pennsylvania, North Carolina, and other states want to recognize environmental leadership companies and organizations within the state that are willing to step forward and say there is a better way to achieve environmental protection. MSWG is talking about potentially major changes in public policy in the way the regulatory systems work. Those who partner with regulatory agencies have the opportunity to help frame the debate. They can sit at the table and influence how activities will be carried out in the future, such as how audits are conducted or how to permits are issued.

John Bridges

Area Environmental Compliance Coordinator

Capital/Metro Operations

For the U.S. Postal Service (USPS), the key to success in moving beyond simply complying with environmental regulations has been to develop and implement an environmental management system (EMS) by using the standard methods approach. The system is built on three stakeholders and their interests: the voice of the employee, the voice of business and the voice of the customer. This provides an opportunity to gauge the impact of how the USPS does business and for letting the customer know exactly what the USPS is trying to accomplish.

After many years of evaluation, the USPS concluded that there are more than 160 environmental aspects of postal operations. These were divided into 11 target areas, including leadership and compliance.

The issues affecting postal operations that target management and compliance requirements are consistently changing and often unpredictable. Opportunities for improvement through EMS components are fostering continual improvement of environmental performance in management.

The USPS delivers about 180 billion pieces of mail each year and employs 760,000 to 800,000 people. It manages about 40,000 facilities, ranging from small trailers in rural areas to one-million-square-foot facilities in urban areas. With 208,000 vehicles, the USPS has one of the largest fleets in the country, which also includes the largest fleet of alternative fuel vehicles.

The USPS workforce has an impact on how the EMS is implemented. An educational outreach program is being used for the line personnel to show them how a collaboration between the EMS and occupational safety and health practices could be used to improve the organization. Each of the USPS's 11 areas and 85 districts now has an area environmental compliance coordinator.

Because the environmental regulatory structure is so broad in scope, it is confusing at times. The USPS firmly believes that its environmental activities should not be driven by compliance with the law and regulations, but rather by doing the right thing for the environment. The USPS is using an EMS approach to improve environmental protection, to enhance employee commitment, and to serve its customers.

The Postmaster General signed the environmental policy, statement, which is a requirement in the EMS structure; this has given the USPS

flexibility in how it handles environmental management. The opportunities for improvement are based on its Customer Perfect program, which has direct correlation to the EMS structure.

The current USPS environmental programs are viewed as a separate entity and are not integrated into USPS business decision-making processes. In addition, the system is compliance driven. The new programs are built around operations. Everything the service does has an operational impact, and operations has been subdivided into four phases. The operations element establishes a program, deploys it, implements it, and, finally, subjects it to review. This is a continuous improvement process.

The EMS is a standardized approach to environmental management that enhances operational efficiency and effectiveness. It integrates environmental issues into the USPS business decision-making process. The goal is to go beyond compliance to achieve sustainability. The USPS uses the same definition for sustainability that the President's Council on Sustainable Development has — to meet the needs of the present without compromising the ability of future generations to meet their own needs.

The EMS helps to improve the ways that the organization works, provides and improves program management, and enhances environmental performance. The EMS is integrated into business strategies and also impacts on regulatory interests and future liabilities. The goal is to be practicing environmentally sound business management in a systematic manner.

How will the USPS achieve that goal? First, through commitment. The EMS contains the policy letters and directions that define the voices of the customer, the employee, and the business. It also has national environmental performance indicators and leadership and compliance targets. All of the systems are process and results oriented, so that USPS business processes can be improved through changes in the operational delivery process by considering the environmental aspects of these processes.

The USPS has formulated a strategic plan that outlines where the organization is and how it is going to achieve success. Some processes for environmental health and safety have already been carefully evaluated. There are district and state programs and management plans. The USPS knows what is being done at each facility in terms of roles and responsibilities, operation and maintenance plans, support tools to facilitate compliance and leadership, and progress tracking.

Education and training in compliance and skills are keys to this program. The measurement and improvement system permits the USPS to reevaluate how activities are being implemented. Quality assurance reviews and baseline audits are conducted by contractors. The environmental office conducts an internal review every third year. This EMS strategy team is based on

maximizing USPS strengths and eliminating weaknesses from environmental management.

Recognizing that economic, environmental, and social goals play an important role is one way to plan for the future. The USPS management believes that it provides a service to the communities it serves, and is very proactive in environmental stewardship. Some of its vehicles, for example, represent maximized efforts to address environmental concerns. The USPS is recycling waste oil and antifreeze and is recapping many used tires. Each plays an important part in how business is being done.

Similarly, the USPS is very concerned about its properties. Before a property is purchased, the service conducts a complete site assessment It has a very strong commitment to ensuring that the properties be in comparable or better condition when they are sold. Again, the goal is to go beyond compliance to achieve sustainability.

Implementation of the EMS program is showing positive results. The customers' interests are addressed through enhanced corporate image, which translates to improved market share when someone purchases stamps or other USPS products. The employees' interests are satisfied in how the USPS looks out for their welfare, especially regarding safety, health, and quality of life, that is, morale and work environment. The USPS doesn't simply tell employees what they have to do; it provides tools, whether they be personal protective equipment or information, to do the job safely.

The business interests of USPS are addressed economic gains achieved through the incorporation of programs that will enhance operational efficiency, reduce labor hours, and reduce the potential for liability.

The USPS has such an aggressive program — strategic plans and operations and management plans — that it will exceed requirements for meeting the 1998 deadlines for removing underground storage tanks, of which the USPS had thousands. It is improving customer satisfaction by developing environmental plans around operational issues. It is strengthening Postal Service effectiveness by increasing environmental awareness and education programs for employees. It is improving financial performance for environmental programs through best management practices and cost avoidance, which will better serve USPS business interests.

The bottom-line benefit of the EMS program is the economic value added to the business section of the service. Employees have a clear and powerful process to improve the bottom-line economic performance of the USPS through the implementation of an environmental management system. If the USPS looks at and deploys its plans properly, there should be a good return on investment, not only in financial gains, but also in terms of community stewardship and sustainability.

Rick Drawbaugh Deputy for Environment, Safety, and Occupational Health Technology Office of the Deputy Assistant Secretary of the Air Force for Environment, Safety & Occupational Health

When it comes to environmental management systems (EMSs), the Air Force is looking at environment, safety, and health (ESH) together. It is implementing the first policy directive within the Department of Defense (DOD) that will incorporate ESH into a single policy.

The Air Force intends to use ESH systems to improve productivity by incorporating them into core business practices. The Air Force has a business and that is national defense. Within the Air Force, business is defined as maintaining readiness, being a good neighbor, and leveraging resources. An ESH system is necessary for process-driven improvement.

What are the obstacles to establishing a quality-based environmental management system? The Air Force problem is very simple. Since 1985, budgets have been cut in half. Military staff has been cut from 602,000 to 372,000. However, the mission has not changed. The Environment, Safety, and Occupational Health Technology Office needs to better leverage resources because budgets and manpower levels will continue to go down.

Another issue is outsourcing and privatization. What impact will they have?

At present the Air Force has separate management systems or "stovepipes." There is a logistics and material support management system with its own data center, an EMS with a data center under development, and an operational readiness management system. There are separate inspections for environment, health, safety, and fire. This creates duplication of effort when the same facilities are being inspected many times. The results of having these separate systems are:

•  Critical activities are not performed.

•  Redundant and unnecessary activities are performed.

•  Decisions are made early in the value chain without considering implications later in a process.

•  People are not focused on internal and external customers.

•  There is an inability to accurately cost services or products.

A single management system, at least within ESH, would reduce the overhead costs of conducting inspections, and would allow people in the field to do their jobs, which are to fly, fight, and win.

One task in putting together an EMS system is to go to the people in the field and ask them to describe their jobs. What they say and what their position descriptions say are two different things. It is difficult then to sit down and determine how to improve the situation and how to incorporate that information into a management system based on goals, objectives, targets, and, ultimately, performance measures. Performance measures are needed that relate to what those staff people actually do, not what the Air Force thinks they do.

A management system is a methodology, whether it be activity-based management or an ESH management system. To have a sound management system, tools such as performance measures, activity-based costing, and a decision support system, are needed.

The Air Force is aiming for a 30 percent increase in productivity by the year 2005. The problem is not so much the amount of money being allocated, but how the money is being spent. Productivity is cost and performance. If existing performance can be maintained at a reduced cost, productivity can be improved just on cost alone.

To improve performance and reduce costs, customer requirements have to be defined. In the past, requirements were not identified, solutions were The individual office asked for a specific budget to solve a specific problem. This is very different from asking people what they need to do their jobs. The Air Force has made a significant effort to put in a requirements process. From there, resources must be leveraged to find the best, most cost-effective answer, and if possible, to acquire in batch rather than through single acquisitions.

The Air Force has a well-educated, experienced ESH community, with skills that can help across the Air Force. Its facilitators, enablers, processes, technology, constraints, and resources are all aimed at improving, or at least not degrading, performance at a reduced cost.

One example is a dental clinic for which an engineer identified a piece of instrumentation, a dental radiographic device that takes x rays using a digital camera. The Air Force was able to save $136,000 per year and effect a payback time of nine months. The reduced environmental costs accounted for half the savings and the other half was personnel costs. Half of a technician's time now can be used elsewhere in the laboratory. Further, for the technicians, there is a 95 percent reduction in exposures to the radiological equipment, and for patients, a 70 percent reduction. That is in only one dental clinic. The Air Force has 138 installations, so that there is the potential for significant paybacks. This type of experience needs to be duplicated.

The Air Force secretariat's job is to identify goals and performance measures for ESH issues. They have to be tied together, but the key is the performance measure. If it is done properly, and if there is a sound information management system, a review, in essence, is never needed. The information available should help managers determine whether the job is being done properly or not. That is the beauty of the system. It reduces overhead costs. It reduces air staff, the military side of the Pentagon, and allows the people in the field the time to do their Jobs.

The organization's culture has to change from thinking simply about compliance. How can that be achieved if there are no performance measures to facilitate the change in the culture? Performance indicators can be separated into measures and standards. Examples of measures include effectiveness of training, no adverse press, EHS factors in financial decisions, and performance evaluations. Examples of standards are numbers of spills and releases, environmental penalties paid, number of audits, and injury frequency rate. Goals are changing but it is amazing how many managers do not know how performance measures relate back to the goal. The goal has to be there first.

One of the biggest problems that government agencies face is that they work by budget management, in which money is allocated and the agency spends it. The faster it is spent, the better chance that the agency, will get more. The difficulty with that is that it is counterintuitive to good business sense.

ESH activities, whether in business or government, generally are paid for from the overhead account. Taking these activities out of the overhead account to develop a cost center is a difficult and expensive task. How then, can one identify the costs of ESH systems?

The tools to do so exist. The Air Force is seeking to identify the old cost drivers and use them to determine the true costs to the ESH. These include the cost of materials, such as plastics, energy, electrical energy, nonproduct output and unused materials. How much of that material is purchased but never used? What is the cost of permitting and of pollutant releases? One goal is to change the way people think in terms of the amount and the kinds of materials and energy they use.

The best ESH system in the world needs to be incorporated into the organization's overall management system. Then, attention must be focused on cost accounting practices. The Air Force needs to build business cases for its ESH dollars, but to do so, the costs of doing business must be known. The Air Force is moving forward with an integrated ESH policy, acknowledging that

having separate policies in each of those areas is counterproductive. Last, a set of "tools" to do the job is needed.

Presently there is a "disconnect" between the polluter and the cost of pollution. If the system owners paid the bill for pollution, they would be more accountable for their actions and would improve their business practices.

Another area for improvement is to standardize accounting practices. The Air Force is looking at how industry works and is seeking a system it could adopt because it does not have the money to build a new accounting system.

The Air Force believes that it can achieve its goal to increase productivity by 30% by 2005 if it has a management system that is fully integrated into core business practices. This is not just about the ESH community, either. It includes financial, logistics, information management, and acquisition reform. All need to play a role in attaining that goal. Shifting the environmental protection paradigm from compliance to performance and cost is the ESH goal. A sound, integrated, ESH management system will provide for this paradigm shift.