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Environmental Management

The role of environmental management for businesses is two-fold: to protect the environment from the effects of manufacturing by-products and to protect your business from noncompliance fines and penalties.

Below you’ll find the essential must-knows about everything you need to know about the process of environmental management for the manufacturing industry and the role of environmental professionals within your organization.

If you’re looking for specific information about air management or a specific environmental compliance report, we’ve included some resources at the end of this page for you.


What is Environmental Management? 

Environmental management can be considered all of the practices, policies, and procedures that your facility undertakes in order to comply with local, state and/or federal environmental legislation. Generally speaking, this means monitoring your releases of chemicals and other by-products to the local air, water, or waste streams.

Most manufacturers oversee their environmental management by looking at what goes into their process and what comes out. Anything entering the facility leave the facility as either a final product or as a waste/by-product. Environmental management is all about understanding this balance – what goes in must come out.waste-management-era-environmental-management

Why is Environmental Management Necessary?

There are many different perspectives on why environmental management is necessary, and they can very greatly depending on your corporate culture and role. For the purposes of this guide, we’re going to assume that you are an EHS professional working within an industrial setting.

Strictly speaking, environmental management is necessary because it is a federally-mandated obligation for nearly every type of business. Various federal regulations, such as the Clean Air Act (CAA) in the United States, regulates and limits the impact that businesses have on local environmental quality and public health.

Environmental management becomes necessary because there is a burden of proof on businesses through their permits (for example, Title V air permits), requiring regular recordkeeping and reporting. As such, businesses need to keep data on their chemical inventories, chemical usages, waste generation, air emissions, water discharges in order to provide compliance reports to federal or state regulators. You will also need these records in case an auditor ever comes to inspect your facility; they will undoubtedly ask to see your records.

Today most organizations also consider environmental management a business necessity because it helps businesses be good stewards of their resources, which ultimately results in lower operating costs. This is sometimes referred to as corporate sustainability.

Essentially, environmental management focuses on resource consumption and waste generation. By taking a “measure it to manage it” approach, environmental management can be used to reduce consumption while finding ways to divert waste from landfills via repurposing, reuse, or recycling.

Who is Responsible for Environmental Management?

Let’s talk specifically about which person(s) within an organization are responsible for environmental management. Above, we said that nearly every business is responsible for having an environmental management process, but which team members do environmental management can differ greatly from facility to facility.

Let’s take a look at a few common scenarios:

It’s not uncommon for organizations to have a dedicated environmental engineer or specialist that is responsible for all air, waste, and water compliance reporting.

Depending on the size of the business, you may also see environmental scientists who specialize in particular types of environmental impacts (like air reporting) or who focus on a specific business sector (like managing all the paint and coating operation recordkeeping).

Many organizations roll up environmental responsibilities into the Health & Safety portfolio. You’ll often see one or more HSE specialists who oversee environmental management reporting.

Some organizations have assistants from each department that send environmental/product data to the environmental specialist, while others have the environmental specialist collect the data themselves.

There’s no right or wrong way to assign your environmental management tasks, as long as the personnel responsible have access to high quality data and are able to understand the calculations required to generate compliance reports. The set up you choose will depend on your team size and available resources.

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Environmental Management System Framework

Having an environmental management system is probably the most important tool in keeping a facility in compliance with environmental regulations. An environmental management system (EMS) can take many forms – a set of processes, a series of paper forms, various spreadsheets, software, and more. The first step is simply to have a formalized set of EMS steps that your team can follow.

This page will outline some of the most common and fundamental frameworks that exist for environmental management:

ISO 14001:2015

Plan-Do-Check-Act

EMS Software

ISO 14001:2015

ISO stands for the International Organization for Standardization. The organization publishes best practices that can be implemented and adapted to essentially any business, and offers certifications based on adherence to those standards.

ISO 14001:2015 is the most recent publication (from the year 2015) that outlines the standards for an environmental management system. ISO 14001:2015 has the three primary goals of giving you a system that will:

Enhance environmental performance

Keep you in compliance with environmental regulations

Setting and meeting environmental improvement goals

It’s important to note that you can choose to follow ISO 14001:2015 exactly or implement the parts that meet your current capabilities. However, you can only claim to be ISO certified by following the entire OSP 14001:2015 guidelines and having audits done by certified ISO auditors. If you’re just looking for guidance on starting or improving your environmental management system we recommend looking at ISO 14001:2015 but don’t try to tackle it all at once.

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Anyone considering ISO 14001:2015 environmental management should also know that these standards do not set out which tools you should use to actualize their recommendations. It’s up to you to create or purchase the paper or software tools you’ll need to crunch the numbers, write reports, and do environmental recordkeeping.

Plan-Do-Check-Act

A very simple model that is another useful starting point for creating your business’ environmental management system is the “Plan-Do-Check-Act” cycle. It’s a basic framework that lays out a foundation to set goals (including compliance goals), measure them, and try to learn lessons from your mistakes and successes.

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The Plan-Do-Check-Act divides your actions into 4 categories: planning, doing, checking, and acting. These are best understood as an endless circle that starts at planning and continues to improve your operations.

PLAN

At this stage, you set your goal and come up with a plan of action. For example, if you’re goal-setting for a compliance report you would take the time to identify which information you need to compile, where that data can be found within your environmental data management system or files, and then set out a timeline to assess and submit your environmental compliance report.

DO

Depending on the size of the business, you may also see environmental scientists who specialize in particular types of environmental impacts (like air reporting) or who focus on a specific business sector (like managing all the paint and coating operation recordkeeping).

CHECK

Many organizations roll up environmental responsibilities into the Health & Safety portfolio. You’ll often see one or more HSE specialists who oversee environmental management reporting.

ACT

Some organizations have assistants from each department that send environmental/product data to the environmental specialist, while others have the environmental specialist collect the data themselves.

Environmental Data Management

There’s an age-old business adage coined by recognized management thinker Peter Drucker: “You can’t manage what you don’t measure”. This most definitely applies to environmental management.

Environmental management, in an industrial setting, has the end goal of ensuring our operations do not harm the local environment. The effect our actions have on the air, water, and wildlife around us can be concretely measured and quantified – albeit with some challenges. This is what we mean when we talk about environmental data management.

There are countless data points that need to be measured, tracked, and accounted for in EH&S. Data can be collected about incoming materials, about outgoing emissions, about process efficiency, about sustainability – the sky is the limit. Only you can determine which data points are relevant (as long as you meet the needs of your regulatory compliance and environmental permits).

The purpose of an Environmental Management System like the ones listed above is to get you to collect, analyze and act on environmental data. Everything falls apart if you don’t prioritize data.

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Your environmental data management strategy should emphasize:

Accuracy

You should be basing decisions about your environmental impact on data analysis – that data must be accurate or you’re making the wrong choices.

Transparency

You need to know where your data came from and when it was created – as well as who on your team managed or entered it.

Focus on the granular

in environmental management, the small details count. Decimal points and exact chemical component records, for example, all feed your reports and compliance in a way that a “big picture” view cannot.

Solid record-keeping

data should be kept for at least 5 years in case you ever get audited. Data should be accessible and organized, but also secure. An environmental compliance audit will take into account your physical recordkeeping practices, so keep things neat and tidy.

Think streamlined

the less you process, manipulate, and touch your data the better. Collect the highest quality data you can from the source and then manipulate it as little as you can. Environmental data management should be about keeping things centralized rather than spread out over multiple sheets and databases.

What does Environmental Management Track and Report?

Environmental management fundamentally tracks your by-products and waste that are generated by your operations and enter the local air, water bodies, or waste streams (landfills, treatment centers, etc.).

It’s important to keep in mind that environmental impacts are generated not just by processes on your property – the full scope of emissions from Scope 1 to Scope 3 covers all sorts of emissions, including those generated by the energy you purchase and consume, or the emissions from when you transport goods or employees.

However, it’s a bit simple to reduce environmental reporting to just these three categories. The reality is that environmental management needs to track numerous things in order to get the final numbers for environmental impacts:


Which chemicals are getting used or processed at your facility.

The quantity of those chemicals which gets used, and the quantity stored.

The VOC content and other emission data about those chemicals.

The amount/weight of particulate matter generated by cutting or grinding.

The application efficiency of paint, coating, topcoat or basecoat activities.

Control device efficiencies.

Monitoring EPA chemical lists for reportable and hazardous chemicals.

These are just a fraction of the types of data points that need to be tracked, monitored, and sometimes reports as part of environmental management. The second part to the answer to “what does environmental management track and report?” includes the numerous environmental compliance reports that may be required.


Toxic Release Inventory

Tier II Reporting

Biennial waste reporting

Title V Air Permit reporting

National Pollutant Release Inventory (NPRI) reporting

How to Improve Environmental Management

Environmental management is data-intensive with an emphasis on calculations and chemical determinations. Ideally, anything you report to the EPA should be accurate and delivered on time. However, even if you are confident that your data is accurate, there are always ways to improve your environmental management processes.

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Here are the ways in which most businesses want to improve their environmental management:

 

Increase the speed/reduce the hours spent on data management. Read a short article for more on this topic: “How to Know if Your Environmental Management is Taking too Long”

Accuracy of recordkeeping and data collection so that reports are easier to verify and submit.

Efficiency in data collection processes. Reduce how many hands or reviews are needed from point of generation to validation to submission.

Better change management to help keep up with changes in regulations or internal processes. Read a short article about Environmental management and business continuity here: “Business Continuity & Change Management: The Role Of EH&S

An environmental management system can always be improved, but it’s up to you to decide where you want to focus your efforts. Sometimes improvements require changing up your internal processes, and other times it’s about upgrading the technology that you use.

For example, doing chemical calculations with Excel spreadsheets can introduce a number of efficiency issues when it comes to QAQC or change management – so if those are your primary concerns then you should consider a technology upgrade.

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If you’re having trouble getting data from your different operations, you might need to improve internal processes around who is responsible for collecting and sharing environmental management data.

Here’s how most businesses can improve their environmental management. We’ll go into more detail about each of these below:

Get your product data direct from vendors

Incorporate automation in your data roll up, QAQC, and reporting

Virtual modelling of site processes

Data Direct from Vendors

The more humans that handle your environmental data, the more you risk something going wrong. This can be as simple as a typo or forgetting an entire chemical from your inventory. But no matter how small the error, it can completely throw off your reporting.

Our mantra is “direct from the source is best” – which in terms of environmental management means that whenever you receive a new chemical from your supply chain, you should be reporting using the data they themselves use and provide with as little transcription as possible.

Now, we know this isn’t always possible. It depends on the supplier, their own data management practices, and your authority over the partnership. For example, if you are a small client, you might not have the clout to demand a full sheet of chemical component and emissions data from them. But larger clients can often flex some muscle and get better quality data as part of their purchasing agreements.

Putting the principle of “direct from vendor” into practice doesn’t need to be difficult – it’s all about keeping hands out of the data before it gets processed for reports. At ERA, we create digital portals between supplier spreadsheets and our database and link them automatically through secure protocols. This means that when a supplier sends over a shipment of new products (or old products with new chemical blends) we fetch that data and upload it to our database, where a product manager can approve or refuse the shipment. When something is approved, the data is automatically updated in chemical inventory reports – without the vendor or purchaser changing, moving, or otherwise manipulating the data.

This system also helps move away from paper recordkeeping by keeping everything digital and auditable.

The end goal is to remove any human hands from touching the data – you want your EHS team to be able to view and QAQC the data sent to you, without worrying about human and transcription errors which are difficult to trace back and correct.

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Automation

Automation is by far the best tool in the Environmental management toolbox and can be utilized in a number of ways to improve a number of processes.

Modern environmental managers are strong advocates of automation because they know:

It reduces manual data entry time

It eliminates the chance of human errors and typos

It is easier to change/update an automated process and see immediate results

Environmental specialists often look to automation to speed up their EH&S data management by automating QAQC – for example, having rules built-into your spreadsheets that reject improperly entered data (like rejecting negative density values). There are numerous little rules that your EH&S team abides by when it comes to your data, and we recommend by doing a self audit to find out where most of your data errors originate from. Incorporate automation of the rules that get broken most often, and then automate outwards from there.

Another way EH&S managers are automation experts is in creating complex formulas in spreadsheets that can calculate things like HAPS, VOCs, etc. We must warn you though, the issue with hard-coded spreadsheets chock-full of formulas is that they are very difficult to keep up-to-date the moment a regulation changes. Many environmental managers becomes spreadsheet managers rather than true data analysts, which is a fate most want to avoid. Find out here: are you an environmental expert or a spreadsheet expert?

Automation is also something that can be incorporated into your reporting, if you are using some sort of digital environmental reporting tool. For example, if you have a quarterly report you need to create for your executives that typically involves cross-referencing several sheets, compiling and crunching numbers, you can set these processes to occur at a set time and simply send you the final report to review and approve.

Anything repeatable and predictable is a prime candidate for automation!

Virtual Modelling

You probably already have some kind of modelling at place in your environmental management – if you have spreadsheets that calculate emissions based on control efficiency, application efficiency, emission rates… any of those types of data points, then you’ve built a rudimentary process model on paper.

The goal of virtual modelling is to create a tool that you can attribute specific process properties to. For example, modelling out a tank would mean being able to set if it’s fixed or floating roof, vertical or horizontal, splash or submerged load, etc. Each of these qualities changes the calculation used to determine fugitive emissions. A virtual model allows you to modify any of these properties and automatically be able to apply the updated calculation.

That’s the difference between a modelling tool and a fixed calculation tool; a spreadsheet built to calculate tank emissions from a specific type of tank needs to be fully rebuilt if you improve your physical tank conditions, or when the EPA updates the calculation requirements. Modelling tools are quite different, as they are able to rearrange and update when just a piece of the puzzle gets modified.

This was seen most notably in the EPA’s TANKS 4.09 reporting tool – it was purpose built for one type of calculation, but it was too difficult to keep rebuilding from scratch as the science of tank emissions improved. Today, EPA does not support or accept data from TANK 4.09.

So how can you improve your environmental management with virtual modelling? It can be a bit complex, depending on the types of tools you are currently using. If you’re still using Excel for environmental management, you may be able to create a few custom formulas based on rules – but generally, most businesses choose to work with a consultant who specializes in their processes or develop their own database-driven software.

We recommend virtual modelling to all manufacturers that we work with and provide a wide-library of modelling tools to match nearly any type of process.

Environmental Management Conclusions

Environmental management is a business practice that is all about measuring the performance and outcomes of your processes – what goes in and what comes out. It’s fundamentally grounded in data management and applies a scientific methodology to your everyday activities.

An environmental manager has specialized knowledge about the impact of industrial activities on the local air, water, and public health. They combine chemical and natural sciences to business processes to calculate and report emissions and find ways to make those processes more sustainable. Environmental managers are data experts, but care must be taken not to spend all day collecting data rather than analyzing it.

An environmental management system is the general category for the standardized set of processes that your business uses to manage data, processes, and reporting. For some businesses, this is a set of paper processes while others use software or other tools. ISO 14001 is an example of the type of framework many businesses use for their EMS structure, but the key is to find one that works for your goals and available resources.

Once you have an environmental management system in place and understand what your permits and federal laws require you to track and measure, you can start looking for ways to maximize efficiency. Your first priority should be on improving data accuracy, then start applying automation to speed up processes.

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This post was written by Alex Chamberlain

Alex Chamberlain is a writer for ERA Environmental Management Solutions.

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