Each piece of an environmental management system (EMS) is designed to work with other pieces. To avoid 'the blind men and the elephant' problem, we need to keep the general EMS system design in mind as we develop any pieces. For example, we might think of education, planning, and regulatory enforcement as activities worthy of developing environmental aspects for since each, if done right, can have very positive outcomes on the environment. But by the ISO standard, we might instead envision them as "environmental controls" that help us reduce environmental impact via a different means.
Note that 'environmental policy' is the driver for implementing and improving an organization's environmental management system so that the organization can maintain and potentially improve its environmental performance. …[P]olicy should reflect the commitment of top management to comply with applicable legal requirements and other requirements, to prevent pollution and to continually improve. The environmental policy forms the basis upon which the organization sets its objectives and targets. …. {Environmental performance: measurable results of an organization's management of its environmental aspects.}
The key pieces of the EMS jigsaw puzzle seem to be environmental policy, 'activities, products and services,' environmental aspects, environmental impacts, environmental objectives, environmental targets, environmental performance, preventative action, corrective action, and any that I may have missed. Note that I do not include 'audits' since I view them with suspicion given my W. Edwards Deming management-theory leanings. At best audits serve as means to other ends. At worst they become self-serving and debilitating to organizations.
ISO 14001 Standard (Excerpts)
A.1 General requirements
…requires an organization to
a) establish … environmental policy,
b) identify environmental aspects .. in order to identify environmental impacts of significance,
c) identify … applicable legal requirements and other requirements,
d) identify priorities and set appropriate environmental objectives and targets,
e) establish … programme(s) to implement the policy and achieve objectives and meet targets,
f) facilitate planning, control, monitoring, preventative corrective actions, auditing and review activities to ensure both that the policy is complied with and that the environmental management system remains appropriate, and
g) be capable of adapting to changing circumstances.
An organization with no existing [EMS should conduct a review covering four key areas]
- identification of environmental aspects…,
- identification of applicable legal requirements and other requirements…,
- examination of existing environmental management practices and procedures, …
- evaluation of previous emergency situations and accidents.
Environmental Aspect
3.6 Environmental aspect: element of an organization's activities or products or services that can interact with the environment.
4.3.1. The organization shall establish, implement, and maintain a procedure(s)
a) to identify the environmental aspects of its activities, products, and services within the defined scope of its environmental management system that it can control and those that it can influence taking into account planned or new developments, or new or modified activities, products and services, and
b) to determine those aspects that have or can have significant impact(s) on the environment (i.e. significant environmental aspects).
A.3.1 An organization should identify the environmental aspects within the scope of its environmental management system, taking into account the inputs and outputs (both intended and unintended) associated with its current and relevant-past activities, products and services, planned new developments, or new or modified activities, products and services. This process should consider normal and abnormal operating conditions, shut-down and start-up conditions, as well as reasonably foreseeable emergency situations…
Organizations do not have to consider each product, component or raw material input individually. They may select categories of activities, products and services to identify their environmental aspects.
Although there is no single approach for identifying environmental aspects, the approach selected could for example consider
a) emissions to air,
b) releases to water,
c) releases to land,
d) use of raw materials and natural resources,
e) use of energy,
f) energy emitted, e.g. heat, radiation, vibration,
g) waste and by-products, and
h) physical attributes, e.g. size, shape, colour, appearance
In addition to those environmental aspects an organization can control directly, an organization should also consider aspects that it can influence, e.g. those related to good and services used by the organization and those related to products and services that it provides. Some guidance to evaluate control and influence is provided below. However, in all circumstances it is the organization that determines the degree of control and also the aspects that it can influence.
Consideration should be given to aspects related to the organization's activities, products and services, such as
- design and development,
- manufacturing processes,
- packaging and transportation,
- environmental performance and practices of contractors and suppliers,
- waste management,
- extraction and distribution of raw materials and natural resources,
- distribution, use, and end-of-life of products, and
- wildlife and biodiversity.
… Changes to the environment, either adverse or beneficial, that result wholly or partially from environmental aspects are called environmental impacts.
Forest Service Experience to Date
It seems that we are at a point where we commonly equate environmental aspect and "activities," rightly or wrongly. In a recent slide presentation, contractor Lynn Penniman provided these as examples of environmental aspects:
- Timber Harvesting
- Road Construction
- Prescribed Burning
- Wildlife Management
- Timber Sale Layout
- Site Prescription Planning
- Maintenance of Road Construction Equipment
- Protection of Special Sites
I notice that "planning'" is included in Penniman's list, although in my introductory remarks I have suggested that we might consider it to be an "operational control" rather than an "environmental aspect." So too, perchance, with "protection of Special Sites." Confusion rules! So be it. We are in the preliminary design stage.
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