December 2005 USIBWC EMS Implementation Report.pdf

Final

International Boundary and Water Commission, United States Section

Environmental Management System Implementation Report December 2005

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USIBWC-EMS Implementation Report-December 1, 2005

Contents

Executive Summary ................................................................................................................... iii

Introduction

1.1 About this Report .....................................................................................................1-1

1.2 What is an Environmental Management System? ...............................................1-1

1.3 Environmental Management System Drivers and Requirements .....................1-2

1.3.1 Executive Order 13148 ..............................................................................1-2

1.3.2 ISO 14001:2004 ...........................................................................................1-3

1.4 USIBWC Environmental Management System Development Approach ........1-3

1.4.1 Organizational Structure ..........................................................................1-4

1.4.2 Processes .....................................................................................................1-5

1.4.3 Tools ............................................................................................................1-6

Environmental Policy

2.1 Environmental Policy Element ...............................................................................2-1

2.2 USIBWC Environmental Policy..............................................................................2-1

2.3 Action Items ..............................................................................................................2-2

Planning

3.1 Planning Element......................................................................................................3-1

3.2 Environmental Aspects............................................................................................3-1

3.2.1 Significant Environmental Aspects.........................................................3-3

3.3 Legal Requirements..................................................................................................3-5

3.4 Objectives and Targets.............................................................................................3-5

3.5 Environmental Management Programs ................................................................3-6

3.6 Action Items ..............................................................................................................3-8

Implementation

4.1 Implementation Element .........................................................................................4-1

4.2 Roles and Responsibilities .......................................................................................4-1

4.3 Training and Awareness..........................................................................................4-3

4.4 Communication ........................................................................................................4-4

4.5 Documentation..........................................................................................................4-5

4.5.1 Control of Documentation .......................................................................4-5

4.6 Operational Controls................................................................................................4-6

4.7 Emergency Preparedness and Response...............................................................4-6

4.8 Action Items ..............................................................................................................4-7

Checking

5.1 Checking Element.....................................................................................................5-1

Table of Contents USIBWC EMS Implementation Report

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USIBWC-EMS Implementation Report-December 1, 2005

5.2 Monitoring and Measurement................................................................................5-1

5.3 Evaluation of Compliance .......................................................................................5-1

5.4 Nonconformity, Corrective Action and Preventive Action................................5-2

5.5 Control of Records....................................................................................................5-2

5.6 Internal Audit............................................................................................................5-3

5.7 Action Items ..............................................................................................................5-3

Management Review

6.1 Management Review Element ................................................................................6-1

6.2 Management Review................................................................................................6-1

6.3 Action Items ..............................................................................................................6-2

Resources and Schedule

7.1 Resource Allocation..................................................................................................7-1

7.2 Implementation Schedule........................................................................................7-2

7.3 Action Items ..............................................................................................................7-4

7.4 Graphical Implementation Schedule .....................................................................7-5

Appendices Appendix A EMR Response Matrix Appendix B Environmental Policy Appendix C Significant Environmental Aspects Appendix D Objectives and Targets Appendix E Environmental Management Programs Appendix F List of References

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Executive Summary

Background and Purpose The United States Section of the International Boundary and Water Commission (USIBWC) is committed to minimizing its operational impact on the environment by complying with all applicable environmental laws and Presidential Executive Orders.

The USIBWC is establishing an environmental management system (EMS) to satisfy the requirements of Executive Order (EO) 13148 “Greening the Government Through Leadership in Environmental Management” (Federal Register, 2000), and that conforms to the International Organization for Standardization EMS standard ISO 14001:2004 (American Society for Quality, 2005).

As a means to understand the USIBWC EMS status, an environmental management review (EMR) was conducted by the United States Environmental Protection Agency (USEPA) Regions 6 and 9 in July 2005 (USEPA, 2005). The USEPA evaluated the USIBWC existing management system for its environmental program and provided key observations and recommendation for improvement.

Based upon the EMR findings and results from an initial environmental assessment (IEA) conducted by CDM in October 2005 (CDM, 2005), the USIBWC has taken action in moving forward with the EMS development. The USIBWC established an initial EMS fence line encompassing the El Paso, Texas headquarters office, the American Dam field office in El Paso and the Nogales International Wastewater Treatment Plant (NIWTP) in Nogales, Arizona. After the USIBWC completes implementation of these EMS pilot programs, it will roll out the same or a similar EMS at its other facilities to comply with EO 13148 and conform to the ISO 14001 standard.

About this Implementation Report CDM developed this EMS Implementation Report to serve as a starting point for the USIBWC to develop its EMS and an EMS Manual. The USIBWC plans to complete the development of the EMS Manual by December 2005. The EMS Manual will describe the elements included in the EMS and how they fit together, and provide guidance to the USIBWC for meeting the requirements of Executive Order 13148 and ISO 14001 with the goal of minimizing its operational impact on the environment.

This EMS Implementation Report describes specific activities to be undertaken by the USIBWC in continuing to develop and sustain its EMS. The report presents the progress of the USIBWC beginning phases of its EMS development and identifies ISO 14001 elements to be developed. Recommended resource allocation and a schedule for implementation are also included. The results of the initial EMS development activities are attached as appendices.

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Section 1 Introduction

1.1 About this Report

This introduction presents an overview of EMS development and implementation activities, and the requirements of the Executive Order and ISO 14001 standard.

Subsequent sections include descriptions of each EMS element and summarize the components and processes already undertaken. The sections then include a description of action items that will be addressed for further development and implementation. The final section offers recommendations for resource allocation and proposes a schedule for implementation.

It is expected that the USIBWC will continue with the development of the EMS and addresses the action items for further development and implementation using the implementation schedule and resource recommendations as guides. The EMS pilot programs at Headquarters, American Dam and NIWTP will serve as models for roll out of the EMS to the remaining nine USIBWC facilities. This Implementation Report is also to be used to facilitate and support the EMS development and implementation at these facilities and sustain the USIBWC EMS throughout the organization.

1.2 What is an Environmental Management System?

An environmental management system (EMS) is part of an organization’s management system used to develop and implement its environmental policy and manage its environmental aspects (American Society for Quality, 2005). An EMS includes organizational structure, planning activities, responsibilities, practices, procedures, processes and resources.

An EMS integrates environmental considerations into day-to-day decision making and other practices through systematic assembly of organizational elements, business processes, and technology tools, and does so in a way that promotes their use by all employees in sustaining the continual improvement of the organization’s environmental performance.

CDM’s support to client organizations in developing EMS’ is guided by the following principles:

Build on existing management system elements;

Use a recognized EMS framework; and

Engage the organization in the EMS development and implementation process.

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1.3 Environmental Management System Drivers and

Requirements Organizations have different reasons for developing and implementing an EMS, yet similar benefits such as operational improvements, cost savings, organizational alignment, and competitive advantage may result. Specific drivers for EMS implementation may include:

Regulatory compliance;

Liability and risk management;

Environmental performance improvement; and

Business performance improvement.

A common driver for implementation is a response to a consent decree or regulatory requirement, or in the case of the USIBWC, a Presidential Executive Order.

1.3.1 Executive Order 13148

In April of 2000, Executive Order (EO) 13148 was promulgated to drive federal agencies to be responsible for and take actions necessary to integrate environmental accountability into every day decision making and long-term planning.

As stated in EO 13148, federal agencies (like the USIBWC) are required to develop and implement an EMS to:

“ensure that strategies are established to support environmental leadership programs, policies, and procedures and that agency senior level managers explicitly and actively endorse those strategies.”

EO 13148 requires federal agencies to:

Conduct an agency-level EMS self assessment;

Implement an EMS at all appropriate federal agency facilities;

Include, and review and update annually, measurable environmental goals, objectives and targets; and

Incorporate EMS performance measures into the facilities audit protocols.

The USIBWC has already met the EMS self assessment requirement by inviting the USEPA to conduct an environmental management review (EMR) which was completed in July 2005. The USEPA Regions 6 and 9 EMR team evaluated the existing management system for the environmental program at the USIBWC and provided a

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A 1-3 matrix of key observations and “areas for improvement.” The USIBWC response to those observations and areas for improvement is included in Appendix A.

1.3.2 ISO 14001:2004

The most commonly used framework for developing and implementing an EMS is ISO 14001. Published by the International Organization for Standardization (ISO) in 1996 and updated in 2004, ISO 14001 is the voluntary EMS standard which establishes a framework for pollution prevention and continual improvement of environmental performance.

The ISO 14001 standard is based on the Plan-Do-Check-Act (PDCA) continual improvement process framework. Planning involves an organization establishing objectives and processes to meet an environmental policy, while doing actually implements those processes. Checking requires monitoring and measuring of those processes and reporting results. Acting confirms an organization in taking action to continually improve its environmental performance.

The five major elements of the ISO 14001 standard are:

Environmental Policy;

Planning (environmental aspects, legal and other requirements, objectives, targets and programs);

Implementation and Operation (resources, roles, responsibility and authority, competence, training and awareness, communications, documentation, control of documents, operational control, emergency preparedness and response);

Checking (monitoring and measurement, evaluation of compliance, nonconformity, corrective action and preventive action, control of records, internal audit); and

Management Review.

1.4 USIBWC Environmental Management System

Development Approach The USIBWC is establishing an EMS to satisfy the requirements of EO 13148 and the ISO 14001 standard. The continual improvement process framework for environmental performance used by the USIBWC follows the PDCA cycle and includes the ISO 14001 elements. Figure 1-1 presents the USIBWC EMS framework.

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The USIBWC established an initial EMS fence line encompassing the El Paso, Texas headquarters office, the American Dam field office in El Paso and the Nogales International Wastewater Treatment Plant (NIWTP) in Nogales, Arizona. The fence line describes the limit of the organization (physical and/or organization) in which the EMS will be developed initially. These initial efforts are referred to as EMS pilot programs. These EMS pilot programs will be undertaken to provide a foundation on which the USIBWC can build out and roll out the comprehensive EMS beyond the fence line.

1.4.1 Organizational Structure

An organizational structure for the development and implementation of the EMS has been identified and the USIBWC is working to engage management personnel and staff in the EMS development efforts. The following roles and responsibilities have been identified for the EMS development process efforts. More information on the specific roles and responsibilities can be found in Section 4.2, Roles and Responsibilities.

EMS Coordinator: The EMS Coordinator, also known as the Management Representative, is the Environmental Management Division (EMD) Engineer for the Engineering Department. The EMS Coordinator is responsible for all elements of the EMS development project including development, implementation, training, oversight and assessment. The EMS Coordinator identifies the USIBWC management

Continual Improvement

Environmental Policy

Planning

Implementation Checking

Management Review

Continual Improvement

Environmental Policy

Planning

Implementation Checking

Management Review

Figure 1-1 USIBWC EMS Framework

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A 1-5 personnel and staff representatives to serve on the oversight Steering Committee and Core EMS Team. The EMS Coordinator reports to the Steering Committee every quarter and presents updates on the EMS at the annual meeting in November.

EMS Steering Committee: The Steering Committee comprises the Commissioner, the Chief Administrative Officer, the Engineering Department Principal Engineer, and the Operations Department Principal Engineer. The Steering Committee is responsible for implementing the Environmental Policy and integrating the EMS into the USIBWC policy, procedures and operations. The Steering Committee offers support and necessary resources for effective development and implementation of the EMS. The Steering Committee reports to the State Department on progress made with EMS implementation. Through a management review, the Steering Committee may also review inspection and audit reports and recommend revisions to SOPs and corrective actions if necessary.

Core EMS Team: The Core EMS Team members include the EMD Engineer, the Engineering Services Division Engineer, the Operations and Maintenance Division Engineer, and at least one representative from each USIBWC facility within the EMS fence line. The Core EMS Team is responsible for the identification of the USIBWC significant environmental aspects and for development of objectives and targets and environmental management programs. Representatives from each facility are responsible for recommending staff members to participate on the facility specific EMS Implementation Teams. The Core EMS Team works with the EMS Implementation Teams at each facility and makes sure the EMS implementation is ongoing and progressively improving the USIBWC environmental performance.

EMS Implementation Team: The EMS Implementation Team is comprised of staff members from each facility that are responsible for the daily implementation of the EMS at its respective facility. The EMS Implementation Team members report to the Core EMS Team on the status of the EMS at least monthly through existing communication channels with the Project Managers at each facility.

1.4.2 Processes

The USIBWC uses processes in every day work activities, however, often these processes are not standardized, documented or maintained across facilities. The development and implementation of an EMS requires the review and update of existing processes and may call for the establishment of new processes. The USIBWC will need to use existing processes wherever possible and develop new ones on an as needed basis. Typical processes included in an EMS are:

Environmental aspects identification;

Objective and targets development;

Legal requirements identification;

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Training and awareness;

Communication;

Document and records control;

Corrective action; and

Management review.

It will be important for the organization to continually review and update those processes and track them across the facilities in order to standardize and control practices which may impact the environment.

1.3.3 Tools

Effective tools useful for developing and implementing an EMS include technology tools and process tools. The USIBWC currently uses a variety of tools throughout its operations and is also investing in new tools.

During the initial environmental assessment, tools that the USIBWC plans to obtain or develop were identified. This includes a Geographical Information System (GIS) and a Supervisory Control And Data Acquisition (SCADA) system for monitoring and measuring the effectiveness of operations at the NITWP. The NIWTP is also planning to upgrade the plant, which will include new equipment. The USIBWC should consider opportunities for building environmental considerations in the planning process as part of this work.

Additional tools that may be helpful for the USIBWC will be a formal tracking system for documenting and recording training activities and regulatory compliance.

Communication tools, like standard announcements to staff via email and postings to an intranet site, may help provide EMS awareness and coordinate EMS activities.

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Section 2 Environmental Policy

2.1 Environmental Policy Element

The Environmental Policy drives the EMS development and implementation for improving an organization’s environmental performance. The policy provides top management commitment to comply with applicable legal requirements and any other voluntary standards or requirements, to prevent pollution and to continually improve its environmental performance. As a key step in the development of an EMS, the policy forms the basis for the other EMS elements and provides the framework for setting and reviewing environmental goals, objectives and targets.

It is very important that the environmental policy is communicated to persons who work for, or on behalf of the USIBWC, including contractors, vendors and suppliers.

The policy should also be understood by internal and external stakeholders. The policy should be reviewed and revised to accommodate any necessary changing conditions and/or information.

2.2 USIBWC Environmental Policy

The USIBWC Environmental Policy was signed in May 2005 and commits the organization to:

“the protection of natural, cultural and historical resources, pollution prevention and meeting applicable legal, regulatory, and other pertinent requirements . . . by establishing goals, measuring progress, and reporting performance through a comprehensive environmental management system.”

Some key highlights of the environmental policy include:

Protection of natural, cultural, historical resources;

Pollution prevention;

Meet applicable legal, regulatory and other pertinent requirements;

Continually improve environmental performance; and

Factor environmental considerations into decisions.

The USIBWC should review and update the environmental policy annually to accommodate any necessary changes. Copies of the policy should be posted in the USIBWC headquarters and each field office. An environmental awareness program for communicating the policy to new and existing staff members and training employees on their environmental responsibilities should occur at least annually. The

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USIBWC should work with its consultants, contractors, suppliers, and partners in understanding its environmental priorities.

The complete Environmental Policy is attached in Appendix B.

2.3 Action Items

In order to complete development and implementation of the Environmental Policy element, the USIBWC should:

Authorize policy continuance under the Acting Commissioner;

Review and authorize when permanent Commissioner is named;

Include policy in document control system;

Distribute policy to staff and make available to contractors; and

Post copies of policy in prominent places in each facility.

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Section 3 Planning

3.1 Planning Element

The Planning element articulates top management’s objectives for environmental protection and pollution prevention. It includes processes, procedures, plans, projects and programs to achieve the environmental policy. Planning activities are undertaken to develop EMS initiatives for implementation across the USIBWC departments.

The major planning components involve determining significant environmental aspects (SEAs), identifying applicable legal requirements or other voluntary standards or requirements, establishing objectives and targets (O&Ts), and developing environmental management programs (EMPs). Much of the EMS development takes place during this phase of the continual improvement framework process.

3.2 Environmental Aspects

Environmental aspects are an element of an organization’s activities, products or services that can interact with the environment. Aspects can have an actual or potential environmental impact, like oil spills or leaks.

The USIBWC has developed a standard operating procedure (SOP# EMS-4.3.1-SEA) for identifying environmental aspects and impacts and determining SEAs. The USIBWC reviews and, if necessary, updates this SOP on an annual basis.

The environmental aspects identified by the USIBWC are those which the organization has direct control or influence over. A list of potential environmental impacts, positive and negative, associated with these aspects has also been developed.

The following environmental aspects were identified at Headquarters, American Dam and NIWTP:

Hazardous Waste Generation;

Air Emissions;

Chemical/Handling and Storage;

Combined Sewer Overflows Release;

Contract Specifications Affecting Natural Resources on Project Sites (also includes disposal of American Dam soils, handling of hazardous materials);

Damage to Natural Resources (also includes damage to property, destruction of habitat, loss/depletion of natural resources);

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Disposal of Sediments;

Fuel Use;

Materials Use;

Solid Waste Generation (also includes storage of solid waste on the island);

Effluent;

Odors;

Storage of Obsolete Equipment;

Vectors;

Debris Management;

Energy Use;

Erosion;

Greenhouse Gas Emissions;

Natural Resource Use;

Release to Ground;

Release to Water;

Spills/Leaks;

Storage of Engine Fluids (also includes storage/disposal of hydraulic fluids);

Sand Disposal from Filters;

Releases to Ground/Water;

Sludge Management;

Water Use;

Stormwater Discharge; and

Grit Storage.

These environmental aspects have the potential to result in the following positive and negative environmental impacts:

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Air quality degradation;

Water quality degradation or improvement;

Water consumption or conservation;

Soil and water contamination;

Natural resource depletion/damage;

Cultural, historical or archaeological items or sites damage;

Nuisance to public;

Energy consumption or conservation;

Contribution to global warming;

Materials consumption or conservation;

Solid waste disposal or recycling;

Hazardous waste disposal or recycling; and

Natural resource enhancement.

3.2.1 Significant Environmental Aspects

Significant environmental aspects (SEAs) are those elements of an organization’s activities, products or services that have or can have a significant environmental impact, and thus should be addressed as a priority. The USIBWC follows SOP# EMS- 4.3.1-SEA for determining SEAs. The USIBWC should review and, if necessary, annually update this SOP.

The following criteria are included in the SEA SOP for determining significance of each aspect:

Frequency;

Severity;

Regulatory Requirement;

Environmental Risk; and

Human Health and Safety Risk.

Each criterion was rated as either: High, Medium-High, Medium, Medium-Low, or Low. After tallying the ratings in aggregate, the USIBWC formed a final list of SEAs

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Facility Significant Environmental Aspects

Headquarters, American Dam, NIWTP Hazardous Waste Generation

Headquarters, American Dam, NIWTP Solid Waste Generation

Headquarters, American Dam, NIWTP Contract Specifications addressing Environmental Management

American Dam, NIWTP Damage to Natural Resources

American Dam, NIWTP Disposal of Sediments

NIWTP Air Emissions

American Dam, NIWTP Chemical Handling/Storage

NIWTP Combined Sewer Overflows Release

NIWTP Effluent

Headquarters, American Dam, NIWTP Fuel Use

Headquarters, American Dam, NIWTP Materials Use

NIWTP Odors

NIWTP Obsolete Equipment

NIWTP Storage and Dispensing of Chlorine Tablets

NIWTP Vectors

The USIBWC will consider setting environmental objectives and targets based on the list of SEAs. This list, with criteria for rating significance, should be reviewed and updated at least annually.

Table 3-1 USIBWC SEAs

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3.3 Legal Requirements

Based on the organization’s commitment to complying with all applicable environmental laws and Presidential EOs, the USIBWC will identify applicable legal requirements and other voluntary standards or requirements that are related to its environmental aspects. At this time, the USIBWC has begun identifying these legal requirements, however, there is no formal procedure for identifying and tracking them.

The EMS Coordinator, with the Core EMS Team, should establish, implement and maintain a procedure to identify and have access to the applicable legal requirements and other voluntary standards or requirements to which the organization subscribes.

The procedure should also include when and how the list will be updated so that current regulations and requirements are addressed. The EMS Coordinator should review and update this list at least annually.

These legal requirements should be taken into account when establishing, implementing and maintaining the organization’s EMS.

3.4 Objectives and Targets

The SEAs, along with the Environmental Policy and regulatory requirements, serve as a basis for establishing objectives and targets for improving environmental performance. Developing objectives and targets involves setting an environmental goal or objective and then setting a performance requirement or target for meeting that goal. They are the driving force in facilitating the move from reactive to proactive environmental performance improvement. They provide the USIBWC management personnel with ways to measure environmental performance and progress similar to other areas of the organization’s business.

The USIBWC has developed a procedure defining the steps to be taken to establish objectives and targets (SOP#-4.3.3-OT). The EMS Coordinator and Core EMS Team have followed the SOP and established objectives and targets for headquarters, American Dam and NIWTP by considering SEAs and at least the following criteria:

Environmental Policy;

Significant environmental aspects;

Significant environmental impacts;

Regulatory and other legal requirements;

Technological tools;

Financial resources;

Operational Requirements; and

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Stakeholder interests.

The USIBWC also has identified performance indicators to quantify and measure environmental performance improvement. A performance indicator is a unit of measure used to standardize and quantify performance measurements of objectives and targets. Some examples of performance indicators include the following:

Percentage of employees completing training per year;

Permit exceedences per year;

Odor complaints per year;

Chemical usage per quantity of water treated;

Percentage of solid waste recycled or reused per year;

Percentage of materials purchased, which are classified as “green,” per year;

Quantity of alternative fuel purchased and used per year; and

Quantity of energy consumed per square foot of office space.

The EMS Coordinator, with the help of the Core EMS Team and EMS Implementation Teams, should establish baseline data for the objectives and targets and then collect data relative to the objectives within their operations. Collecting baseline data is important for assessing current conditions and integrating efforts with existing practices. Once data is collected quarterly, the EMS Coordinator will compile the data for presentation to the EMS Steering Committee. The EMS Steering Committee will review and update the objectives and targets at least annually.

The objectives and targets list is attached in Appendix D. These objectives and targets will also serve as a model for building out the EMS to additional facilities.

3.5 Environmental Management Programs

The objectives and targets give rise to the development of environmental management programs (EMPs). EMPs are short-term plans that describe actions required to achieve those set objectives and targets. They contain specific actions, defined schedules, allocation of staff and financial resources, identification of individual and group responsibilities, and process for review and reporting.

The USIBWC has developed EMPs that apply to headquarters, American Dam and NIWTP. The template for developing EMPs requires the following information:

Objective (what is the environmental goal; how can the USIBWC improve elements of its environmental performance);

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Target (what are the performance requirements to measure, how can the USIBWC measure success);

Background/Purpose (what significant environmental aspect or other criterion is this EMP based on, why did the organization choose this EMP);

Scope (what facilities or field offices apply to this EMP);

Tasks/Activities (what actions are required to meet the objective and target, how will effectiveness or progress be measured);

Timeline/Milestones (when should monitoring and measuring be conducted, when are reviews scheduled, are there short-term or long-term milestones for meeting this objective and target);

Deliverables (what operational controls, SOPs or best management practices are required, must there be a report generated);

Responsible Parties and Roles (who is responsible for achieving the objective and target, what appropriate personnel should be involved at each designated level);

Resources Needed (what training is required, what human, technological and/or financial resources are needed, what are the sources for this funding); and

Issues (what is the actual progress toward achieving the objective and target, what are the problems, what are the lessons learned or success stories).

Table 3-2 presents the five objectives and targets the EMS Coordinator chose for developing EMPs. The EMPs are key EMS implementation activities. The complete EMPs for these five objectives and targets are attached in Appendix E.

Objective Target

Develop EMS Awareness Training Program for all the USIBWC staff and general public

Post policy in all facilities by November

Awareness training of staff:

> 70% by February 2006

> 90% by June 2006

100% by October 2006

Table 3-2 USIBWC OTs

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Objective Target

Document and review existing emergency preparedness and response practices and communicate those to employees and contractors

Develop emergency preparedness response program and communication program by February 2006

Establish a training program and tracking system to include environmental knowledge and responsibilities for both existing employees and new hires

Develop training plan by January 2006

All staff complete overview training by April 2006

Develop training records system by May

Formalize procedures to identify and comply with regulatory requirements and other programs or standards

Develop procedures by December 2006

Optimize existing recycling program in headquarters and field offices

Expand recycling program to include toner cartridges, aluminum cans, cardboard, and plastics

Establish baseline and performance metrics

Promote recycling in the field offices

The EMS Coordinator should be responsible for amending EMPs, where relevant, to reflect any necessary changes if a project relates to new developments within the USIBWC and/or new or modified activities.

3.6 Action Items

To complete development and implementation of the Planning element, the USIBWC should:

Develop procedure for identifying and tracking legal requirements;

Identify applicable legal requirements and other standards or requirements;

Implement five EMPs and collect necessary baseline data relative to performance indicators; and

Choose at least two more objectives and targets to develop EMPs.

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Section 4 Implementation

4.1 Implementation Element

Implementing an EMS can only be successful with clear roles and responsibilities, efficient communication channels, proper training, useful documentation and operational emergency preparedness and response procedures. It is important for an EMS to address these components so that environmental considerations are addressed in every day decision making, planning and work activities.

4.2 Roles and Responsibilities

The following definitions for roles and responsibilities should be documented and communicated to appropriate personnel to facilitate EMS development and implementation. This section only describes the roles and responsibilities as they apply to the EMS. More information regarding specific roles and responsibilities for operational activities should be elaborated on in the EMS Manual.

Designation of the EMS Coordinator is crucial as part of an EMS project. The EMS Coordinator is the Environmental Management Division (EMD) Engineer and is responsible for managing and overseeing the development and implementation effort of the EMS. Specific responsibilities include:

Planning and managing EMS development and implementation;

Coordinating with nearby federal facilities or other entities on EMS efforts and pooling resources;

Providing EMS awareness, training and assistance to the USIBWC staff;

Communicating and promoting the environmental policy and EMS to the USIBWC staff;

Helping to form the EMS organizational structure and Core EMS Team and EMS Steering Committee; and

Reporting to the EMS Steering Committee and top management personnel on EMS activities.

The EMS Coordinator should formalize and chair the Core EMS Team to assist in the development and implementation of the EMS across facilities. The Core EMS Team will comprise the EMS Coordinator, Division Engineers for the Engineering and Operations Departments and one representative from each field office. Specific responsibilities of the Core EMS Team include, but are not limited to:

Conducting appropriate competency-based training for staff;

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Disseminating information and delegating EMS tasks to EMS Implementation Teams;

Developing EMS Manual and associated documentation;

Implementing EMPs and developing procedures for EMS implementation;

Reporting quarterly to the EMS Coordinator on EMS results and activities; and

Facilitating EMS implementation at each field office.

The EMS Steering Committee comprises the Commissioner, the Chief Administrative Officer, and the Principal Engineers for the Engineering and Operations Departments.

Specific responsibilities for this committee include, but are not limited to:

Providing available resources (i.e. human, specialized skills, organizational infrastructure, financial, and technology resources) for development and implementation, and eventual sustainability, of the EMS;

Appointing an EMS Coordinator;

Implementing the Environmental Policy and integrating the EMS into existing procedures and operations;

Reporting to the State Department on EMS progress; and

Conducting at least annual EMS management reviews and recommending revisions or corrective actions if necessary.

The EMS Implementation Teams are individual teams located at each field office to conduct the activities necessary for effective implementation. Each team comprises of staff members from their respective facilities and is responsible for the every day activities associated with the EMS. Specific responsibilities include, but are not limited to:

Collecting baseline data for EMPs;

Monitoring and measuring EMPs; and

Reporting to the Core EMS Team at least monthly on the status of the EMS and reporting quarterly to the EMS Coordinator on EMS activities.

Contractors, suppliers and vendors also have roles and responsibilities in implementing the EMS. It is important that they understand the USIBWC commitment to the environmental policy and objectives and targets, as needed, as well as emergency preparedness and response procedures and any applicable legal requirements.

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4.3 Competence, Training and Awareness

EMS awareness and training, both general EMS training and competency-based training, are important to prepare and educate USIBWC management personnel and staff representatives on activities related to the development and implementation of an EMS. Two types of training are identified as important; the first type of training is for general EMS awareness and the second for employee competency related to job-specific activities.

General awareness of the EMS and the environmental policy is essential early in the implementation process for obtaining top management buy-in and garnering support and commitment from staff. The USIBWC should promote the environmental policy and EMS through the following media:

Publicize the policy on the USIBWC website;

Display the policy in one or more prominent location at each facility;

Publish stories related to environmental management and updates on the EMS in The Boundary Marker;

Promote the policy and environmental management activities through displays in the USIBWC trailer; and

Include a copy of the policy and a description of employees’ roles in environmental management and the EMS during new hire orientation.

The USIBWC should consider developing a procedure for identifying training needs related to environmental performance for employees and reviewing that at least annually by the EMS Coordinator and project managers. Communication with nearby federal facilities will be beneficial for coordinating and sharing training opportunities as appropriate. The USIBWC should provide general EMS training to new and existing employees so that each has a basic understanding of and/or commitment to the following:

EMS overview;

Environmental Policy;

Environmental aspects related to respective work activities;

Objectives, targets and performance indicators;

Environmental management programs;

Performance measurements and record keeping;

Emergency preparedness and response; and

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Respective roles and responsibilities related to the EMS.

The USIBWC should also provide competency-based training to those employees whose tasks have the potential to cause a significant environmental impact. The training program should also retain records for all training activities conducted, including names of employees attended, dates of delivery, contact time (in hours), subject matter, and method of delivery (lecture, classroom, hands-on, field location, on-line module).

The EMS Coordinator and Core EMS Team may choose to coordinate through Human Resources to collect and retain training records. Collection and retention of training records should also be coordinated with staff working in positions where certification or licensing requirements include continuing education (i.e. NIWTP plant operators).

4.4 Communication

Internal communication is important for effective implementation of the EMS throughout each field office. The objectives and requirements of the EMS should be communicated to USIBWC staff in order to align current work practices with improving environmental performance. The primary tool for internal communication is the use of Groupwise for email announcement, updates and document sharing.

Other appropriate methods for internal communication may include, but are not limited to:

Weekly, monthly and/or annual staff meetings;

Newsletters;

Bulletin boards in employee break rooms; and

Postings to intranet sites or the website.

The EMS Implementation Teams and Project Managers in the field offices should be assigned responsibilities for communicating environmental roles and responsibilities through operational control plans, which staff must follow for conducting their work activities.

External communication about the EMS is also important in educating stakeholders and the USIBWC counterparts in Mexico about the Environmental Policy and environmental management activities. It is important to communicate emergency preparedness and response procedures with local authorities, neighboring facilties and contractors, suppliers and vendors. The means for external communication may include, but are not limited to:

Citizen Forum meetings;

Meetings with counterparts in Mexico;

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Promotional tours with the trailer;

Annual reports;

Newsletters or other mailings; and

Postings to the website.

4.5 Documentation

EMS documentation is necessary to provide a written description of the EMS and specific elements as well detailed information for managing and evaluating its development and implementation. Developing documentation is an ongoing process and should be integrated with current USIBWC documentation systems when possible. Existing documentation will need to be reviewed and kept current, whereas developing documentation will require more time and organization.

Specific EMS documentation includes the EMS Manual and SOPs. The EMS Manual documents the overall framework for improved performance in environmental management, environmental compliance and public right-to-know. SOPs specify the work process in the field offices and include guidance related to environmental considerations of appropriate work practices.

Documented processes and procedures should be developed as appropriate.

Situations which require documented procedures may include, but are not limited to:

Lack of that documentation may cause work contrary to the environmental policy and regulatory requirements;

When the need to demonstrate compliance with legal requirements or other voluntary requirements or standards; and

When benefits result in easier communication and training, maintenance and revision, and less risk of non-compliance or non-conformance.

4.5.1 Control of Documentation

The USIBC should develop and implement a document control system to establish and maintain EMS information, to describe the core elements of the EMS and their interaction, and to provide direction to related documentation. Documents may be stored and maintained in either paper or electronic formats, and should be made available to USIBWC staff as needed.

The EMS Coordinator should control the following documents:

Environmental Policy;

EMS Manual;

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Standard Operating Procedures (SOPs) referenced by the EMS Manual including determining significant environmental aspects and establishing objectives and targets;

Spill Prevention, Control and Countermeasure Plans (SPCC) and Emergency Response Plans and associated SOP for operations. and

Regulatory permits and permit applications.

Controlled documents should be readily identifiable, remain legible, carry an authorizing signature, and specify the dates when the document is in effect. These documents should be readily accessible in those areas where operations essential to the effective functioning of the EMS are performed. The system for document control should include the following specifications:

Location where a document is stored;

Required review cycle for documents;

Procedure for updating documents and removal of obsolete versions from active work areas;

Clear designation and archiving of obsolete documents; and

Archive retention policies.

4.6 Operational Controls

Operations related to SEAs should be planned consistent with the Environmental Policy and objectives and targets. The EMS Coordinator and Core EMS Team will be responsible for identifying, establishing and implementing operational controls necessary for improving environmental performance by:

Documenting procedures and maintaining best practices where their absence could cause nonconformities with the Environmental Policy and/or objectives and targets;

Stipulating operating criteria in the procedures;

Training personnel for specific activities;

Communicating relevant procedures to contractors, suppliers and vendors.

4.7 Emergency Preparedness and Response

An emergency preparedness and response program is essential for helping to prevent accidents and incidents from occurring and to actually respond to emergencies. Since the USIBWC already addresses emergency preparedness, the organization should update and communicate existing emergency preparedness and response procedures

A 4-7 to staff representatives as well as contractors, suppliers and vendors. The EMS will help complement existing emergency procedures.

4.8 Action Items

In order to complete development and implementation of the Implementation element, the USIBWC should:

Document and communicate EMS roles and responsibilities to appropriate personnel and contractors, suppliers and/or vendors;

Complete formation of Core EMS Team, EMS Steering Committee and EMS Implementation Teams;

Develop environmental training program and tracking system;

Provide general EMS awareness training and communicate Environmental Policy to top management, staff and contractors;

Provide competency-based environmental training for appropriate staff;

Contact nearby federal facilities, local authorities and other potential resources for coordinating EMS activities and training when available;

Incorporate EMS information and awareness into internal and external communications;

Review existing documentation system and develop EMS documentation control system;

Document EMS processes and procedures when relevant;

Identify, establish and implement operational controls necessary for improving environmental performance; and

Review and communicate existing emergency preparedness and response program to staff and contractors, suppliers and/or vendors.

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Section 5

5.1 Checking Element

Throughout the implementation of an EMS, checking provides a means of proactively identifying and correcting management system deficiencies. The checking element should include procedures for evaluating the root cause of problems and identifying corrective actions to address those deficiencies. Preventive actions are also important to in remedying future environmental problems or nonconformities. This element typically involves ongoing activities of checking and corrective action.

5.2 Monitoring and Measurement

The USIBWC should monitor and measure its environmental performance.

Monitoring and measuring quantifiable performance indicators will be useful in demonstrating that the EMS is actually improving the organization’s environmental performance. A consistent monitoring program will also help to identify nonconformities.

The USIBWC should develop a monitoring and measurement program that includes:

Regular monitoring and measurement of key operations which may significantly impact the environment;

Tracking environmental performance consistent with the Environmental Policy, objectives and targets and SOPs;

Calibrating and maintaining equipment to assess whether appropriate equipment is used and effective;

Evaluating compliance with applicable legal requirements and other voluntary requirements or standards.

Monitoring and measuring for objectives and targets and EMPs for meeting those objectives and targets should be given priority. Eventually, the USIBWC should have in place procedures for monitoring and measuring each significant environmental aspect and operational control.

Existing programs for self-inspections should also be updated and maintained.

5.3 Evaluation of Compliance

On a regularly scheduled basis, a review of each facility should be conducted by the Environmental Management Division to assess compliance against regulatory requirements and other voluntary requirements or standards.