Forest Environmental Management Systems

Legal and Other Requirements Puzzle: Moving beyond "Spreadsheets from Hell"

We continue to struggle with the "Legal and Other Requirements Puzzle." Recently we saw a Region 6 "Spreadsheet from Hell"(citation needed!) that will likely require a small army of book-keepers to keep up-to-date and coordinated with other parts of the EMS world. After reeling from that, we were led to Region 1's "Evaluation of Compliance [with applicable laws and other requirements] Procedure [FS Intranet link]" which appears, superficially, to simplify "legal and other" compliance almost down to "Do NEPA!" "Almost," however, soon evaporates when we see the associated Region 1 Spreadsheet from Hell [FS Intranet link]. We propose an alternative path.

Instead of trying to devise a process for "legal and other requirements" compliance from scratch, perhaps we ought to look to see what the Forest Service is already doing, and what the FS ought to soon begin as to EMS process improvement for: planning and NFMA, NEPA, ESA, … compliance.

A Forest Service "organizational approach" to EMS would have operational controls and process improvement requirements (including all EMS elements) for all functions that support work on the ground, including, planning and NFMA compliance, NEPA compliance, and so on. Developing such would relieve forests of the impossibilities of trying to account for legal compliance outside the structure of extant process requirements.

For example, we have a set of directives for Planning (FSM 1920 and FSH 1909.12). We also have specific policy directives outside the Manual/Handbook system for some legal and other requirements. All such could be controlled via EMS at a tier above forest operations. If it were we could then leave more-specific tweaking of law and policy to the local level while taking care of the bulk of legal authorities/responsibilities at levels above the forest.

Doing the EMS at levels above the forest may move us out of "Spreadsheet Hell." And it might help us explain why words from the 2005 NFMA Rule read: "…The scope of the EMS will include, at a minimum, the land management planning process…." [emphasis added] Whadayathink? Is there a better way? Are we on a right track with this proposal?

Another Support System: EMS Webware

Earlier this week I began my exploration of and about GreenWare Environmental Systems. I first dug up a few names at EPA. My intial (and so far only) contact in EPA asked me whether I found anyone actually using GreenWare. The idea I got was that while the file management package at GreenWare was very good, the system they had tried a couple of years ago was quite restrictive and not very forgiving as to documents/records developed elsewhere.

Then they told me about another group called EMS Webware (affiliated with Univ. of Massachusetts, Lowell) who had worked up a system that was perchance more flexible and adaptable. So I called them and they reiterated the same story, and suggested that they had only begun to develop EMS Webware when they found off-the-shelf systems too confining.

In their Feb. 2005 commencial software announcement the EMS Webware folks say:

…The program helps organizations build and implement an environmental management system (EMS) to enhance environmental performance.

University developers from the offices of Environment Health and Safety and Commercial Ventures and Intellectual Property office worked together to create EMS WebWare.

“It provides the tools required from beginning an EMS, to building teams, tracking documents, creating documents, providing links, to providing the security and IT support,” explained Rich Lemoine, director of the Environment Health and Safety office.

EMS programs were introduced by the EPA to promote environmental policy at universities and other public agencies. The International Organization for Standardization (ISO) recommends a model for environmental performance called ISO 14001, which is used by large corporations and from which EMS Webware is modeled.

Conservative business projections have the software bringing in some $750,000 to the university over five years, according to Susu Wong, UMass Lowell's licensing associate and chief marketer of software. Customers would likely include other universities, as well as municipalities and EMS training providers.
UMass Lowell says Beta testers included the city of Lowell, the University of Rhode Island and the Toxics Use Reduction Institute.

“It had to be user-friendly. It had to adapt to any organization,” said Lemoine. “Basically what the system does is say, ‘Here are 17 templates and you can bring in any documents.'”
UMass started working on Webware in 2001 after finding difficulties implementing its own EMS on campus.

“The other systems out there, they weren't flexible, and they weren't going to meet the needs of our institution,” Lemoine said.

UMass Lowell provides all technical support for the software package and its server will host and retain all information organizations might need for future audits or agendas, he said.

So although we will still work to better understand GreenWare, we are in the process of looking further into EMS Webware too. It may be that GreenWare was never as inflexible as the UMass folks say, or it may be the it was but no longer is. In any case we want to investigate at least these two systems and hope to find more. Clearly we need 'something.'

EMS Support Systems: What do we use? What should we use?

A couple of days ago I saw a copy of a spreadsheet tracking legal and other requirements for EMS. What struck me, other than the immense size, was the interrelationship between that document and operational controls and other elements of the ISO standard. Then it hit me, again: Why aren't we using relational databases in our EMS work? Everything is tightly linked together, and trying to sort out all relevant linkages every time something is changed will likely prove futile, or at minimum very expensive and time-consuming. Why are we are cobbling together random spreadsheets, word documents, etc. with little thought given to their interconnectedness?

I remembered that Chris Miller, from the CAT (Content Analysis Team) had suggested that I look at a software package by GreenWare Enviornmental Systems that has been used by many:

Sample Client List:
• Environmental Protection Agency (40 Sites)
• Royal Dutch Petroleum Company (Shell)
• TRW
• ITT Automotive
• Environment Canada
• Tri-County Metropolitan Transportation Authority
• Texas Natural Resource Conservation Commission
• Solvay Polymers, Inc.
• Toshiba International Corporation
• Dupont Canada Inc.
• Dell Computer
• US Department of National Defense
• Inco Ltd.
• Local/municipal governments

GreenWare Government Clients:
• Air Armament Center
• Atlantic Canada Opportunities Agency
• U.S. Department of Energy - BWXT Pantex
• Canadian Forces Base Kingston
• Canadian Forces Support Unit
• Clean Water Services
• Defence Construction Canada
• Department of Homeland Security - Customs and Border Protection
• Department of National Defence HQ
• Environment Canada
• Fort Riley Directorate of Environment and Safety
• Greater Pretoria Metropolitan Council (GPMC)
• Ontario Ministry of Environment and Energy
• Public Works and Government Services Canada
• U.S. EPA (40 Facilities)

In my preliminary look at their approach to EMS, I found that not only does the GreenWare system appear to be entirely compatible with our approach to EMS, but it even includes a "guidebook" or "manual" as they call it to conveniently co-locate all elements of the standard to serve as a basis for working the EMS. It even has spreadsheets for proving up on significance of environmental aspects. Furthermore there is a fully integrated calendar to help schedule all. Finally it seems relatively inexpensive.

So why won't we use it, or another compatible off-the-shelf system (or use one that is primarily off-the-shelf with a contract for enhancement)? Maybe we will, someday. But there seems to be little overt attention being placed to the acquisition of such software right now. Or at least there is little attention that I know about. Why not?

Are so steeped in "event mentality" – doing things once, postponing thought until after "the event" about continued do-ability of whatever it is we are attempting – that we forget that some things need to be designed simply, and inter-connectedly so that we can continue to use them (and improve them) from the moment they are turned on.

Have we been trained by forest planning and other nearly endless "events" that we have forgotten that organizations run best when run simply, while recognizing the complexity of the surrounding environment?

In any case, Why aren't we talking a lot about the urgent need to acquire or devleop adequate system-support for EMS?

For more, see Chris Miller's post in our EMS Support Systems blog.