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Pollution Prevention in an EMS - P2 Opportunity Assessments



Earlier this year I created a webpage on EMS resources on the Internet on behalf of Univ of Nebraska and P2RX. It is still online tho not recently updated at - The link was --> /Ecolink/emspage.htm Since then we have been thinking a lot about how to make sure an EMS promotes Pollution Prevention. So I have prepared a table of P2 actions for each of the 10 standard elements of an EMS as spec'd in the somewhat authoritative report, Improving Environmental Performance and Compliance: 10 Elements of Effective Environmental Management Systems ( The draft is included below. If you are interested in EMS and P2, I hope you will review this list and offer your own suggestions or comments how to make it more effective and realistic. If there is enough input (I will track and acknowledge contributions) then perhaps some group like the National Pollution Prevention Roundtable might adopt it as an advisory document. You can type in your additions to the list below and reply direct to me at [email protected] (please don't send to the listserv, I will compile all suggestions and send a clean update). Please make your additions in CAPS or some other different font so they are obvious. Thanks for your help, now you can skip that boring meeting and think about something useful.


How Can an EMS Be Designed to Promote Pollution Prevention?

An Environmental Management System (EMS) is a system to improve environmental performance in an organization. This can be achieved by compliance and end-of-pipe controls, Pollution Prevention (P2) focused on process and product improvement, or a combination of these. An EMS does not promote P2 in itself; it must be specifically designed to encourage and promote P2.

The basic principles of an EMS are described in the publication, Improving Environmental Performance and Compliance: 10 Elements of Effective Environmental Management Systems (published by the Commission for Environmental Cooperation of the North American Agreement on Environmental Cooperation).

We have identified P2 strategies appropriate for each of these elements. The table below identifies some of them. We are interested in feedback and suggestions how to make this more effective and authoritative.

1. Environmental Policy
  • Involve all staff at all levels in practical solutions for process and environmental improvement
  • Constantly improve resource efficiency and EMS performance
  • Account for all the costs of waste and pollution and assign them to their sources
  • Design products that minimize environmental impacts throughout their life cycle
  • Purchase environmentally preferable products and services when practical, especially less-toxic and recyclable materials

2. Environmental Requirements and Voluntary Undertakings
  • Link all identified environmental aspects to the internal sources or activities that affect them.
  • Forecast environmental regulations and other external requirements and brainstorm P2 solutions that can mitigate or avoid them.
  • Identify process and product improvement requirements that will be necessary for competitiveness and develop environmental performance goals for them.
  • Identify regulatory and other programs that encourage pollution prevention and learn how to cooperate with them for business and environmental advantage.
  • Ensure all plans for compliance support also include components for pollution prevention related to compliance.

3. Objectives and Targets
  • Establish quantifiable and readily-measured goals for resource efficiency, toxics reduction and waste reduction at the process level. Have process workers design indicators that they can measure and manage themselves in real time.
  • Establish objectives and targets for improving the management accounting process for assigning all compliance and environmental costs to responsible activities.
  • Develop an index for the environmental impact of products and services and establish goals for improving the index performance.
  • Create knowledge improvement targets to ensure that effective P2 solutions from around the world are not overlooked.

4. Structure, Responsibilities and Resources
  • Make all process supervisors and department managers responsible for the environmental performance of their units. Minimize the number of dedicated environmental staff.
  • Use full-cost accounting to link P2 performance to the budget and to employee compensation rules.
  • Include P2 performance in job descriptions and employee evaluations.
  • If feasible, rotate staff between compliance and production responsibilities.
  • Give highest decision-making priority to projects with potentially signficant P2 benefits.

5. Operational Control
  • Have activity workers produce simple process diagrams that are readily available and have basic statistics on wastes and emissions at every step.
  • Provide simple procedures for measuring and reporting on process or product environmental impact that give the employees feedback in real time (these might include process controls such as water submeters, run charts on waste generation or water use, etc.)
  • Establish a procedure to ensure that the P2 Hierarchy is followed consistently in all decisions regarding environmental performance.
  • When documented procedures for activities are required because their absence could cause significant environmental impacts, establish additional procedures to ensure that these activities are given highest priority for P2 action.
  • Have a procedure for regularly reporting on P2 progress to senior management.

6. Corrective and Preventive Action and Emergency Procedures
  • Apply the P2 Hierarchy in all corrective and preventive actions.
  • Use a hazard analysis to identify potential emergency situations and make the related activities a priority for P2.

7. Training, Awareness and Competence
  • Provide modules on P2 in all existing training.
  • For staff with significant environmental aspects to manage, ensure that required EMS training includes detailed P2 methods and solutions.
  • Besides basic training in P2 concepts, ensure all staff have basic training in specific P2 resources and solutions applicable to their functions (such as accounting, marketing, design, etc.).
  • Give key staff training in how to use the Internet to tap into the local and global network of practical P2 solutions.
  • Use case study data in training to show the real business benefits of P2.

8. Organizational Decision-making and Planning
  • Use life-cycle analysis to identify environmental threats and opportunities up and down the product or service chain that could affect business performance, from natural resource harvesters to product disposers.
  • Develop proactive strategies to minimize environmental risks in the product or service chain.
  • Ensure that all senior managers have specific P2 goals to meet. Integrate P2 strategies into planning for business-driven process and product changes.
  • Empower and encourage work teams to pro-actively make P2 improvements that do not need signficant capital or other resources.
  • Give priority in decision-making to proposals that could significantly improve environmental performance.

9. Document Control
  • Ensure that data on process environmental performance, fully-loaded materials costs (including waste management costs), and waste fate is made readily available and understandable to relevant staff.
  • Use electronic documentation to minimize paper use and improve records management.
  • Document all P2 suggestions, implemented or not, in a standard form and collate them as a reference tool for staff. Ensure the documents are reviewed and updated regularly.

10. Continuous Evaluation and Improvement
  • Ensure that environmental evaluation is directly linked to evaluation of responsible products and processes.
  • Encourage self-evaluation and improvement processes among worker teams.
  • Use performance audits as P2 opportunity assessments.
  • In P2 assessments, use cross-discipline teams including representatives of all line departments and support departments.
  • Establish a solid process for getting P2 improvement ideas from outside the organization, including training, networking, use of Internet, etc.
  • Establish benchmarks for P2 performance with leading competitors and/or others and use these to evaluate and improve performance.

If you have any suggestions, comments or ideas how to improve these recommendations for promoting P2 in an EMS, please contact Burt Hamner at [email protected]. Contributions will be acknowledged in the final. The revised "living" document will be posted at CleanerProduction.Com for all to use.
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Super Moderator
Marc I'll go ahead a fall on my sword here.....This thing went backburner.

I will say though that this guy, whoever he is is off track with the relationship of P2 and EMS, specifically ISO 14001 based ones.

A well designed and functioning EMS does not focus on P2 (end of the pipe) thinking, by that time it's too late and damage is being done. Historically P2 has been a reactive approach to pollution control, and end-of-the-pipe is just that...the end.

An ISO 14001 based EMS must focus on 2P "Prevention of Pollution" or be pro-active in addressing potential issues at the "beginning" not the "end".

I will give this caveat, much of the info that was previously presented is good stuff and makes sense, but the reasoning has got to be placed at the front and not the back of the process.


Fully vaccinated are you?
Staff member
I never did follow up on this. Randy, is the list valid or what's the scoop? Which sections are not valid?


Super Moderator
I looked at this stuff and it appears to me to be a mishmash put together by someone with very limited experience with ISO 14001 who also seems to be quite lost.

We see this thing start out by saying and EMS....well lets read it

An Environmental Management System (EMS) is a system to improve environmental performance in an organization. This can be achieved by compliance and end-of-pipe controls, Pollution Prevention (P2) focused on process and product improvement, or a combination of these. An EMS does not promote P2 in itself; it must be specifically designed to encourage and promote P2.

No way Jose....If we wait for the end of the pipe or the P2 approach the damage is done or it's gonna happen. I've stood my ground on this in this thread and in many others and I publicy state it. I'm not going to get on my :soap: because it will take all night. I will say that some of the info is not too bad and is usable, but the wrong start can lead to the wrong finish.


Fully vaccinated are you?
Staff member
OK - I've been reviewing some old threads and came across this one and thought I'd ask.
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