Throughout southwest Michigan and the country, businesses are aggressively trying to become more effective and efficient, even with a robust US economy. As companies adjust, whether through expansion or "rightsizing", an increasing ROI (return-on-investment) is expected. Doing more with less is the maxim of the times. Still, quality, timeliness, and control continue to be challenged by customer satisfaction expectations.

Many companies have successfully implemented quality systems (TQM, ISO-QS 9000) which allow for continual improvement of products and establish recognition of these efforts by their customers. These systems, however, have primarily focused on production and product development and have not taken into consideration other aspects of operations, such as environmental issues. These aspects may be causing unnecessary risk, waste and concern, which take away from efficiency, control and ultimately, profitability.

A similar management system, the Environmental Management System (EMS), is a strategic system, self-designed and implemented, which integrates the environment into the business decision making process. An EMS will enable an organization to understand the environmental effects of its business and enhance environmental performance through self-directed continual improvement processes. While the EMS can be used for global (i.e., ISO 14000 registration) or environmentally noble purposes (e.g., zero-waste processes), many companies may wish to stay on familiar ground and use the EMS to achieve and maintain regulatory compliance.

The basic steps of an EMS, as presented in the ISO 14000 standards, include establishing policy, planning and assessment, implementation, monitoring, management review, and continual improvement. The six basic steps can be stated in a different way to create an EMS model that focuses on regulatory compliance:

• Management commitment and policy,
• Assessment and review of applicable environmental regulations,
• Ranking liability and risk identified during the assessment and review process,
• Implementing procedures to obtain compliance,
• Continual monitoring of compliance activities, and
• Establishing protocol to keep up to date with ever changing environmental regulations.

For the EMS to be successful, top management must be committed to achieving environmental compliance. This commitment should be in writing, readily accessible to the work force, and enforced.

During the assessment and review process, an evaluation of operations and daily employee activities is conducted to determine what environmental regulations apply to the business. Current management structure and practices are also assessed to evaluate if protocols to maintain compliance have been established and are effective. An on-site environmental manager can complete the assessment and review if the company has one. Otherwise, outside services may need to be obtained. Other programs such as Kalamazoo County's Facility Evaluation Program (FEP) are available to help small companies assess environmental compliance. For many companies an unbiased review of their processes is the best way to evaluate and assess environmental compliance.

The next step is to rank areas of non-compliance in order of significance based on liability and risk. By ranking non-compliance, a company can establish a timeline for addressing those issues that need immediate attention. Upper management should be an active partner during this phase of the review process.

Implementing procedures to obtain and maintain compliance is the nuts and bolts of an EMS. The previous two tasks are very strategic by their nature. Implementation of an EMS is the task where protocol is developed and standard operating procedures are written. Individuals within the company can be assigned the responsibility for developing written procedures specific to their function and ensuring that they are carried through. Once a plan for obtaining compliance has been established, to maintain the success of the EMS, it is critical that all employees are educated on the new procedures.

Once a system for achieving compliance has been established, this system should be regularly reviewed. By continually auditing the system on a regular basis, you are establishing assurance that the system is working properly and efficiently. The time frame for conducting audits is determined by each individual company, however, it is recommended that the system be audited at least annually. Auditing the system can be completed by on-site staff or by a third party.

The constant change in environmental regulations offers the greatest challenge to a company's efforts to stay in compliance, since their focus is on production. Many different options exist to keep a company abreast of these changes. These methods can include the use of publications, conferences, the Internet, networking with regulatory agencies, and partnering with environmental professionals. Environmental professionals can assist with regulatory updates and application of these regulations, and allow the company to focus on production. It may be prudent for companies to obtain updates through a quarterly, semi-annual, or annual meeting. The meeting is typically aligned with the presentation of audit results. This allows for strategic decisions and new concepts to be considered for obtaining and maintaining compliance. This process provides the avenues necessary for a company to continually improve while maintaining compliance efficiently and effectively.

Many companies without an EMS react to an environmental risk or concern as it arises, which generally increases the potential liability or cost. A compliance-oriented EMS will modify this reactive structure to a proactive planning and improvement structure, which allows a company to control risks on an ongoing basis. By planning for potential environmental risk or concern, an organization will be gaining control of operations that may have a resultant effect on the environment and their bottom line.

Wendy Schlett is a project manager for Environmental Management Systems at Envirologic Technologies, Inc. She has received certification through the British Standards Institution for implementing ISO 14001/96 Environmental Management Systems. She assists clients with implementing environmental management systems, regulatory compliance reviews, updates, waste minimization, and pollution prevention. For information, contact Wendy Schlett or David Stegink at  616-342-1100.