EMS Design Protocol--Modifications between Version 2.1 and 2.3

September 8, 1999

EXPLANATORY MEMO ON MODIFICATIONS FROM

EMS DESIGN PROTOCOL VERSION 2.1 TO 2.3

  1. Explanation of Changes

After reviewing the state pilot managers’ very helpful comments on the EMS Design Protocol, UNC and ELI have added them all to Version 2.3. The comments fall into two general categories: (1) improving the introductory language in the protocol as well as the general flow of the document; and (2) modifications in the text of questions. The specific changes are listed below.

The review process led UNC, ELI, and EPA to identify further changes that were needed to achieve two major improvements for Version 2.3. First, the language in the protocol was made more clear and specific so it will be easier for facilities to submit high quality data on the design of their EMSs. Second, these better design data will make the QA/QC process much easier for the states, facilities, and UNC/ELI. Moreover, the modifications will also enable UNC and ELI to analyze the very important EMS design questions that interest states, facilities, EPA, and the broader research community. Both UNC and ELI expect that Version 2.3 of the EMS Design Protocol is a significant improvement.

UNC and ELI will be glad to help participating facilities that are already answering the EMS Design Protocol by explaining these changes and, for the firms that have already finished this protocol, with determining any additional information they may need to submit to the database.

  1. Modifications to EMS Design Protocol Language and Structure
  1. Added thank you to facility at end of page 2 of facility letter
  2. Changed contact names as to whom facilities should call for questions about the protocol—removed John Villani’s information and added Deborah Amaral, Nicole Darnall, and Deborah Gallagher (see letter pg. 3 and protocol cover page)
  3. Changed the timing of the protocol to reflect our discussions in Milwaukee and when it must be submitted – November 30, 1999 (see page ii)
  4. Added another thank you to the facility at end of page ii
  5. Added protocol title, version number, and date to the header for each page
  6. Removed references to “pilot facilities that adopt ISO 14001 EMSs” and instead refer to “pilot facilities that adopt EMSs”
  7. Added a Table of Contents with page numbers
  8. Added a date when the facility completed the baseline?[check this]protocol (page 1 of protocol)
  9. Added a date when the facility completed (or expects to complete) its EMS design (page 1 of protocol)
  10. Embedded all tables into text
  11. Numbered tables so they are in sequence 1, 2, 3, 4, . . .
  12. Revised headers of all Interested Parties Tables (old 1a through 1d) to be more specific about the data being sought
  13. Added footnote to Table 1
  14. Added footnote to Table 2
  15. Modified all references to external parties so that the document is consistent with MSWG/EPA language and our Glossary using the term “outside interested parties”
  16. Added key word definitions under specific questions, where appropriate, so that facilities have a better understanding of what type of information is being sought
  17. Added thank you at end of page 28
  18. Modified introductory language in Appendix 1: Environmental Condition Indicators
  19. Added definitions to Glossary

III.Modifications to Specific Questions

1.Question 1.A—added “Adoption of an ISO 14001-based EMS is consistent with facility’s overall environmental principles” and “Adoption of an EMS may increase our revenues”

2.Question 1.A—separated “EMS adoption may be a valuable public relations or marketing tool” so that it asks about two distinct motivations: “EMS adoption may be a valuable public relations tool” and “EMS adoption may be a valuable marketing tool”

  1. Modified question 3.D. to refer to “outside interested parties” rather than “the public”
  2. Remove question 3.E
  3. Question 2.B—added “Please explain the nature of this support”
  4. Modified question 3.A so that it is a yes/no question
  5. Modified question 3.B.4 to be more specific, asking approximately how many total person hours and over a duration of how many months it took to determine the facility’s environmental policy
  6. Modified question 4.B.1 so that it is a yes/no question with an imbedded response
  7. Modified question 4.B.6 to be more specific, asking approximately how many total person hours and over a duration of how many months it took to determine the facility’s environmental aspects and impacts
  8. Revised question 4.C to be in two parts (4.C and 4.D), asking about differences in the process for determining aspects and impact and the stakeholder involvement without the ISO-based EMS or without the state-sponsored program. Similar revisions were made to questions 5.B, 6.E, 10.B, 11.C, and 15.G, and questions 7.C, 9.C, 12.E, 13.D, and 14.B were removed.
  9. Modified question 5.A.1 so that it is a yes/no question
  10. Added question 5.A.2, which asks about specific pressures that influenced the facility during the process of determining the significance of its aspects
  11. Added question 5.A.3, which asks whether and how environmental indicators were considered during the facility’s significance determination process
  12. Modified question 5.A.7 to be more specific, asking approximately how many total person hours and over a duration of how many months it took to determine the facility’s significance of its environmental aspects and impacts
  13. Modified question 6.B.1 to be more specific, asking about how the significance of environmental aspects and impacts was considered when determining the facility’s environmental objectives and targets
  14. Added question 6.B.3, to ask whether and how environmental indicators were considered when setting the facility’s objectives and targets
  15. Added question 6.B.4 and 6.B.5 to determine whether the facility had a core EMS development team and how this team worked
  16. Modified question 6.B.9 to be more specific, asking approximately how many total person hours and over a duration of how many months it took to determine the facility’s objectives and targets
  17. Modified question 6.C so that it is a yes/no question
  18. Modified question 6.D to be more specific and to refer to “outside interested parties” rather than “the public”
  19. Added Section 7 to ask three questions about supply chain management
  20. Modified question 8.A to be more specific about which individuals (job titles) were given responsibility for implementing and maintaining the EMS
  21. Divided question 8.B so that it is now 8.B and 8.C, asking how environmental performance is incorporated into the incentive structure of (1) managers (2) non-management employees
  22. Added three questions at beginning of Section 11, Monitoring and Measurement of Regulatory Compliance, to address EPA’s question about how the facility’s EMS addresses discoveries of violations, if they occur
  23. Modified old question 11.B (now question 11.C) to be more specific about what types of EMS procedures are in place to determine the impact of new or modified activities on compliance.
  24. Added question 12.E, 12.F, 12.G to address EPA’s concerns about how compliance audits are performed
  25. Added question 13.A.4 about actions resulting from top management’s review of the EMS.
  26. Divided question 14.A into two separate questions (14.A and 14.B) on certification and auditing issues
  27. Added additional items (auditors, registration, and corrective actions) to Table 8, Cost of EMS Design” to include all the types of costs that facilities might incur during the EMS design process
  28. Modified question 15.E on the benefits of the EMS design process so that it is now four very specific questions (15.E.1 - 15.E.4). Added to 15.E an introductory text on the types of direct, indirect, monetary, and non-monetary benefits that might be incurred in the EMS design process.
  29. Added questions 15.F, 15.G, and 15.H to include former Protocol 1.2, Costs and Benefits - Preliminary Measurement Protocol, in theEMS Design protocol. Previously, these questions were an attachment, and they have often been overlooked in the protocols previously completed by pilot facilities.

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