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 EHS 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 for business is all about understanding this balance – what goes in must come out.


    environmental-management-mass-balance-approach

    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.

    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 EHS management.

    In an industrial setting management 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.

    Strictly speaking, EHS 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.

    Completing management tasks 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 compliance 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, EHS management can be used to reduce consumption while finding ways to divert waste from landfills via repurposing, reuse, or recycling.

    What are the Benefits of Environmental Management?

    Above we mostly focused on why businesses are required to perform management tasks, but what executives and business owners really care about is what are the benefits of environmental compliance? What does a company get out of doing environmental recordkeeping beyond avoiding EPA fines? There's actually a wide range of business benefits that make EHS management worth your time.

    1. Because EHS management puts focus on your material usage (how much of a material or chemical comes into your facility versus what leaves as product or waste), it gives you concrete data to measure and improve your material costs. For example, EHS management can tell you how much of your paints is ending up in the air as VOC (volatile organic compound) emissions, which directly relates to how much of your material cost is literally vanishing into thin air. Without taking the time to calculate your VOC emissions, you can't quantify the efficacy of your paint application systems or accurately assess the true cost of your painting operations. This principle can be broadly applied to any of your processes where materials come into your facility but get, in part, lost as waste during processing.

    2. You can also view the benefit of EHS management from a workplace culture perspective: the workforce is increasingly prioritizing a business's environmental footprint as part of how they rate job satisfaction and employee loyalty. A company that doesn't demonstrate environmental responsibility is putting itself as critical risk for being competitive in attracting professionals who are looking to add and innovate within the field. Yes, you might have no problem find some workers if you have a shabby compliance record, but you won't attract or retain the type of employees who want are also brand advocates and help advance your organization in the market.

    3. On the topic of markets, consumers are also savvy when it comes to supporting brands that take environmental compliance seriously. This can mean both larger-scale concepts like sustainability and carbon footprint disclosure, but it also goes down to the simple permit compliance level. The EPA publishes nearly all of its findings to the public, so your local community knows if you were in violation of your air permits, for example. In this way, EHS management is also brand management.

    Who is Responsible for Environmental Management?

    Let’s talk specifically about which person(s) within an organization are responsible for EHS management. Above, we said that nearly every business is responsible for having an EHS management process, but which team members do this 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 data 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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    What is the Environmental Management System Framework?

    Having an EHS 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 EHS management:

    ISO 14001:2015

    Plan-Do-Check-Act

    EMS Software

    What is ISO 14001:2015? Is ISO for Environmental Management?

    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 EHS 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 for their business 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.

    What is the Concept of Environmental Management? Plan-Do-Check-Act

    A very simple model that is another useful starting point for creating your business’ EHS 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.

    plan-do-check-act-era-environmental

    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.

    How to Do Environmental Data Management?

    Now this is the big question: how to do EHS management if you are a corporation or other business. And truth be told there are a lot of approaches. Above we talked through the Plan-Do-Check-Act system, which is a proven methodology for EHS management. But that's not the only answer, and it's more of a concept than an actionable solution. Since you're reading this article you're probably looking for something more concrete:

    In most cases the actual "doing" of doing EHS management is done using spreadsheets or enterprise resource management software like a dedicate Environmental Management System (EMS). Spreadsheets aren't exactly designed as calculation engines so they're more suited to storing your environmental data rather than processing your information. An EMS is designed to be both a database and an automation tool that will roll up your emissions numbers for you. 

    So what should you be using your EMS software or spreadsheets to do? What should go in them?

    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 EMS is to get you to collect, analyze and act on environmental data. Everything falls apart if you don’t prioritize data. 

    Here are some (just a sample sampling) of the things that can be tracked in your EMS:


    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.

    The work that environmental managers do is all about measuring and managing these metrics (and many many more) in order to both ensure their operations comply with federal and state environmental regulations as well as improve the overall efficiency of the material throughput of processes to increase profit margins. Let's look at more specifics about what to track next. 

    What does Environmental Management Track and Report?

    Environmental management for businesses 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 EHS management needs to track numerous things in order to get the final numbers for environmental impacts:

    These are just a fraction of the types of data points that need to be tracked, monitored, and sometimes reports as part of EHS 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.

    • Chemical inventory data including: material chemical breakdowns, %VOC, %HAP, archived SDSs, CAS Numbers, quantities stored and purchased.
    • Material throughput: how much of each material was used, how much was generated as waste product. If any waste is generated, where is it stored, is it hazardous, and where are you sending it to be treated?
    • Process mapping:  what equipment is used on site? How efficient is it in terms of material application? Which control devices are connected to these processes? What is the capture efficiency of these devices?
    • Continuous Monitoring Systems (CMS): do you have CMS? Which parameters are you capturing and how often?
    • Emissions to air and water: Which types of emissions and what quantity of emissions are released per source / per facility / per process? These metrics will require some intensive mathematics to determine, typically outlined in your operating permits.
    • Compliance and Permit conditions: What are your limits on emissions? What are the quantities, what are the reporting requirements, and what are your other requirements?

    Once you're tracking all of this data in your EMS it needs to output it into various compliance reports:


    Toxic Release Inventory

    Tier II Reporting

    Biennial waste reporting

    Title V Air Permit reporting

    National Pollutant Release Inventory (NPRI) reporting

    There are many, many other reports which could be included on this list. Your permit might even have unique, individual reporting requirements just for your facility. What's key is that your EMS system gives you the option to both output a standardized compliance report and totally custom reports for your specific operations. 

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    What Are Environmental Management Strategies?

    Your environmental data management strategy should emphasize these elements:

    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 is an Environmental Management Plan?

    Now that you have a clearer picture of what EHS management is, it's time to start thinking about your management plan. An environmental compliance plan is the business side of how you plan to allocate time, resources, and staff to the act of environmental management. This should be a business document that your executives sign off on that describes the who, what, where, and when of environmental compliance management. It needs to address both your internal business logic and your external regulatory/permit conditions:

    • Who: Which staff is responsible for collecting which pieces of data? Is someone responsible for reporting while someone is responsible for data collection? Which executive needs to sign off on compliance reports? 
    • When: when do your permits require you to collect data and report data? Is there a monitoring frequency? When is data generated and how often will you collect it?
    • Where: where in your facility is data generated and where will it be stored? Where is your team located (some businesses, for example, have different teams across different sites).
    • How: how will you do your management tasks? Will you use an EMS software? Are there specific calculation methodologies required by your permits? Also important in an environmental compliance plan is how will your business operate the EHS management department? What is the step by step process to get from data collection to data roll up to report submission?

    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 EHS management processes.

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    Here are the ways in which most businesses want to improve their EHS 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 EHS management and business continuity here: “Business Continuity & Change Management: The Role Of EH&S

    An EHS 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 EHS management data.

    Here’s how most businesses can improve their EHS 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

    How to Get Environmental Management 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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    How to Automate Environmental Management?

    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!

    How Does Environmental Management Use 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 compliance 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.

    What are Environmental Management Best Practices for Business?

    EHS 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 EHS 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.

     

    This Blog Was Co-Authored By:

    sarah-sajedierin-manitou

     

    Alex Chamberlain
    Post by Alex Chamberlain
    August 7, 2019
    Alex Chamberlain is a writer for ERA Environmental Management Solutions.

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