Code
of Environmental Management Principles (CEMP) For Federal Agencies
I. BACKGROUND
On August 3, 1993, President Clinton
signed Executive Order No. 12856, which pledges the Federal Government
to implement pollution prevention measures, and publicly report and
reduce the generation of toxic and hazardous chemicals and associated
emissions. Section 4-405 of Executive Order 12856 requires the Administrator
of the Environmental Protection Agency (EPA) to establish a Federal
Government Environmental Challenge Program. Similar to the "Environmental
Leadership" program proposed in 1993 by EPA's Office of Enforcement,
the program is designed to recognize and reward outstanding environmental
management performance in Federal agencies and facilities. The program
shall consist of three components to challenge Federal agencies to:
1) agree to a code of environmental principles emphasizing pollution
prevention, sustainable development, and "state of the art" environmental
management programs; 2) submit applications to EPA for individual Federal
facilities for recognition as "Model Installations"; and
3) encourage individual Federal employees to demonstrate outstanding
leadership in pollution prevention. The program is geared toward recognizing
those departments, agencies, and Federal installations where mission
accomplishment and environmental leadership become synonymous and to
spotlight these accomplishments as models for both Federal and private
organizations.
On September 12, 1995 the Interagency
Pollution Prevention Task Force signed a charter encouraging the federal
government to achieve, among other items, environmental excellence
through two areas of activity including: a) active agency and facility
participation in the Environmental Challenge Program and, b) participation
in the establishment of an agency Code of Environmental Management
Principles.
The term "agency" is
used throughout the CEMP to represent the participation of individual
Federal government bodies. It should be recognized that many Cabinet-level "agencies" have
multiple levels of organization and contain independently operating
bodies (known variously as bureaus, departments, administrations, services,
major commands, etc.) with distinct mission and function responsibilities.
Therefore, while it is expected that a "parent agency" would
subscribe to the CEMP, each parent agency will have to determine the
most appropriate level(s) of explicit CEMP implementation for its situation.
Regardless of the level of implementation chosen for the organization,
it is important that the parent agency or department demonstrate a
commitment to these principles.
Overview of Principles
Five broad environmental management
principles have been developed to address all areas of environmental
responsibility of federal agencies. More discussion of the intent and
focus of each principle and supporting elements may be found in the
next section, "Implementation of The Code of Environmental Management
Principles."
The five Principles are as follows:
1. Management Commitment:
The agency makes a written top-management
commitment to improved environmental performance by establishing policies
which emphasizes pollution prevention and the need to ensure compliance
with environmental requirements.
2. Compliance Assurance and
Pollution Prevention:
The agency implements proactive
programs that aggressively identify and address potential compliance
problem areas and utilize pollution prevention approaches to correct
deficiencies and improve environmental performance.
3. Enabling Systems:
The agency develops and implements
the necessary measures to enable personnel to perform their functions
consistent with regulatory requirements, agency environmental policies
and it's overall mission.
4. Performance and Accountability:
The agency develops measures to
address employee environmental performance, and ensure full accountability
of environmental functions.
5. Measurement and Improvement:
The agency develops and implements
a program to assess progress toward meeting it's environmental goals
and uses the results to improve environmental performance.
II. IMPLEMENTATION OF THE CODE
OF ENVIRONMENTAL MANAGEMENT PRINCIPLES
Each of the five principles, which
provide the overall purpose of the step in the management cycle, is
supported by Performance Objectives, which provide more information
on the tools and mechanisms by which the principles are fulfilled.
The principles and supporting Performance Objectives are intended
to serve as guideposts for organizations intending to implement environmental
management programs or improve existing programs. It is expected that
each of these principles and objectives would be incorporated into
the management program of every organization. The degree to which each
is emphasized will depend in large part on the specific functions of
the implementing organization. An initial review of the existing program
will help the organization to determine where it stands and how best
to proceed.
Principle 1: Management
Commitment:
The agency makes a written
top-management commitment to improved environmental performance by
establishing policies which emphasizes pollution prevention and the
need to ensure compliance with environmental requirements.
PERFORMANCE OBJECTIVES:
1.1 OBTAIN MANAGEMENT SUPPORT
The agency ensures support
for the environmental program by management at all levels and assigns
responsibility for carrying out the activities of the program.
Management sets the priorities,
assigns key personnel, and allocates funding for agency activities.
In order to obtain management approval and support, the environmental
management program must be seen as vital to the functioning of the
organization and as a positive benefit, whether it be in financial
terms or in measures such as regulatory compliance status, production
efficiency, or worker protection. If management commitment is seen
as lacking, environmental concerns will not receive the priority
they deserve.
Organizations that consistently
demonstrate management support for pollution prevention and environmental
compliance generally perform at the highest levels and will be looked
upon as leaders that can mentor other organizations wishing to upgrade
their environmental performance.
1.1.1 Policy Development
The agency establishes
an environmental policy followed by an environmental program
that complements its overall mission strategy.
Management must take the lead
in developing organizational goals and instilling the attitude
that all organization members are responsible for implementing
and improving environmental management measures, as well as develop
criteria for evaluating how well overall goals are met. The environmental
policy will be the statement that establishes commitments, goals,
priorities, and attitudes. It incorporates the organization's mission
(purpose), vision (what it plans to become), and core values (principles
by which it operates). The environmental policy also addresses
the requirements and concerns of stakeholders and how the environmental
policy relates to other organizational policies.
1.1.2 System Integration
The agency integrates the
environmental management system throughout its operations, including
its funding and staffing requirements, and reaches out to other
organizations.
Management should institutionalize
the environmental program within organizational units at all levels
and should take steps to measure the organization's performance
by incorporating specific environmental performance criteria into
managerial and employee performance evalualtions.
Organizations that fulfill
this principle demonstrate consistent high-level management commitment,
integrate an environmental viewpoint into planning and decision-making
activities, and ensure the availability of adequate personnel and
fiscal resources to meet organizational goals. This involves incorporating
environmental performance into decision-making processes along
with factors such as cost, efficiency, and productivity.
1.2 ENVIRONMENTAL STEWARDSHIP
AND SUSTAINABLE DEVELOPMENT
The agency strives to facilitate
a culture of environmental stewardship and sustainable development.
"Environmental Stewardship" refers
to the concept that society should recognize the impacts of its activities
on environmental conditions and should adopt practices that eliminate
or reduce negative environmental impacts. The President's Council
on Sustainable Development was established on June 29, 1993 by Executive
Order 12852. The Council has adopted the definition of sustainable
development as; "meeting the needs of the present without compromising
the ability of future generations to meet their own needs."
An organization's commitment
to environmental stewardship and sustainable development would be
demonstrated through implementation of several of the CEMP Principles
and their respective Performance Objectives. For example, by implementing
pollution prevention and resource conservation measures (see Principle
2, Performance Objective 2.3), the agency can reduce its negative
environmental impacts resulting directly from its facilities. In
addition, by including the concepts of environmental protection and
sustainability in its policies, the agency can help develop the culture
of environmental stewardship and sustainable development not only
within the agency but also to those parts of society which are affected
by the agency's activities.
Principle 2: Compliance
Assurance and Pollution Prevention:
The agency implements proactive
programs that aggressively identify and address potential compliance
problem areas and utilize pollution prevention approaches to correct
deficiencies and improve environmental performance.
PERFORMANCE OBJECTIVES:
2.1 COMPLIANCE ASSURANCE
The agency institutes support
programs to ensure compliance with environmental regulations and
encourages setting goals beyond compliance.
Implementation of an environmental
management program should be a clear signal that non- compliance
with regulations and established procedures is unacceptable and injurious
to the operation and reputation of the organization. Satisfaction
of this performance objective requires a clear and distinct compliance
management program as a component of the agency's overall environmental
management system.
An agency that fully incorporates
the tenets of this principle demonstrates maintainable regulatory
compliance and addresses the risk of non-compliance swiftly and efficiently.
It also has established a proactive approach to compliance through
tracking and early identification of regulatory trends and initiatives
and maintains effective communications with both regulatory authorities
and internally to coordinate responses to those initiatives. It also
requires that contractors demonstrate their commitment to responsible
environmental management and provides guidance to meet specified
standards.
2.2 EMERGENCY PREPAREDNESS
The agency develops and implements
a program to address contingency planning and emergency response
situations.
Emergency preparedness is not
only required by law, it is good business. Properly maintained facilities
and trained personnel will help to limit property damage, lost-time
injuries, and process down time.
Commitment to this principle
is demonstrated by the institution of formal emergency-response procedures
(including appropriate training) and the appropriate links between
health and safety programs (e.g., medical monitoring for federal
employees performing hazardous site work).
2.3 POLLUTION PREVENTION AND
RESOURCE CONSERVATION
The agency develops a program
to address pollution prevention and resource conservation issues.
An organization committed to
pollution prevention has a formal program describing procedures,
strategies, and goals. In connection with the formal program, the
most advanced organizations have implemented policy that encourages
employees to actively identify and pursue pollution prevention and
resource conservation measures, and instituted procedures to incorporate
such measures into the formal program. Resource conservation practices
would address the use by the agency of energy, water, and transportation
resources, among others. Pollution prevention policies and practices
should follow the environmental management hierarchy prescribed in
the Pollution Prevention Act of 1990: 1) source reduction; 2) recycling;
3) treatment; and 4) disposal.
Section 3-301(b) of Executive
Order 12856 requires the head of each federal agency to make a commitment
to utilizing pollution prevention through source reduction, where
practicable, as a primary means of achieving and maintaining compliance
with all applicable federal, state and local environmental requirements.
Principle 3: Enabling Systems:
The agency develops and implements
the necessary measures to enable personnel to perform their functions
consistent with regulatory requirements, agency environmental policies
and its overall mission.
PERFORMANCE OBJECTIVES:
3.1 TRAINING
The agency ensures that personnel
are fully trained to carry out the environmental responsibilities
of their positions.
Comprehensive training is crucial
to the success of any enterprise. People need to know what they are
expected to do and how they are expected to do it. An organization
will be operating at the highest level when it has an established
training program that provides instruction to all employees sufficient
to perform the environmental aspects of their jobs, tracks training
status and requirements, and offers refresher training on a periodic
basis.
3.2 STRUCTURAL SUPPORTS
The agency develops and implements
procedures, standards, systems, programs, and objectives that enhance
environmental performance and support positive achievement of organizational
environmental and mission goals.
Clear procedures, standards,
systems, programs, and short- and long-term objectives must be in
place for the organization to fulfill its vision of environmental
responsibility. A streamlined set of procedures, standards, systems,
programs, and goals that describe and support the organization's
commitment to responsible environmental management and further the
organization's mission demonstrate conformance with this principle.
3.3 INFORMATION MANAGEMENT,
COMMUNICATION, DOCUMENTATION
The agency develops and implements
systems that encourage efficient management of environmentally-related
information, communication, and documentation.
Information management, communication,
and documentation are necessary elements of an effective environmental
management program. The need for advanced information management
capabilities has grown significantly to keep pace with the volume
of available information to be sifted, analyzed, and integrated.
The ability to swiftly and efficiently digest data and respond to
rapidly changing conditions can be key to the continued success of
an organization.
Organizations adopting this
principle have developed a sophisticated information gathering and
dissemination system that supports tracking of performance through
measurement and reporting. They also have an effective internal and
external communication system that is used to keep the organization
informed regarding issues of environmental concern and to maintain
open and regular communication with regulatory authorities and the
public. Those organizations operating at the highest level ensure
that employees have access to necessary information and implement
measures to encourage employees to voice concerns and suggestions.
Principle 4: Performance
and Accountability:
The agency develops measures
to address employee environmental performance, and ensure full accountability
of environmental functions.
PERFORMANCE OBJECTIVES:
4.1 RESPONSIBILITY, AUTHORITY
AND ACCOUNTABILITY
The agency ensures that personnel
are assigned the necessary authority, accountability, and responsibilities
to address environmental performance, and that employee input is
solicited.
At all levels, those personnel
designated as responsible for completing tasks must also receive
the requisite authority to carry out those tasks, whether it be in
requisitioning supplies or identifying the need for additional personnel.
Similarly, employees must be held accountable for their environmental
performance. Employee acceptance of accountability is improved when
input is solicited. Encouraging employees to identify barriers to
effective performance and to offer suggestions for improvement provides
a feeling of teamwork and a sense that they control their own destiny,
rather than having it imposed from above.
4.2 PERFORMANCE STANDARDS
The agency ensures that employee
performance standards, efficiency ratings, or other accountability
measures, are clearly defined to include environmental issues as
appropriate, and that exceptional performance is recognized and
rewarded.
Organizations that identify
specific environmental performance measures (where appropriate),
evaluate employee performance against those measures, and publicly
recognize and reward employees for excellent environmental performance
through a formal program demonstrate conformance with this principle.
Principle 5: Measurement
and Improvement:
The agency develops and implements
a program to assess progress toward meeting it's environmental goals
and uses the results to improve environmental performance. Guidance
for Implementation:
PERFORMANCE OBJECTIVES:
5.1 EVALUATE PERFORMANCE
The agency develops a program
to assess environmental performance and analyze information resulting
from those evaluations to identify areas in which performance is
or is likely to become substandard.
Measurement of performance is
necessary to understand how well the organization is meeting its
stated goals. Businesses often measure their performance by such
indicators as net profit, sales volume, or production. Two approaches
to performance measurement are discussed below.
5.1.1 Gather and Analyze
Data
The agency institutes a
systematic program to periodically obtain information on environmental
operations and evaluate environmental performance against legal
requirements and stated objectives, and develops procedures to
process the resulting information.
Managers should be expected
to provide much of the necessary information on performance through
routine activity reports that include environmental issues. Performance
of organizations and individuals in comparison to accepted standards
can also be accomplished through periodic environmental audits
or other assessment activities.
The operation of a fully-functioning
system of regular evaluation of environmental performance along
with standard procedures to analyze and use information gathered
during evaluations signal an organization's conformance with this
principle.
5.1.2 Institute Benchmarking
The agency institutes a
formal program to compare its environmental operations with other
organizations and management standards, where appropriate.
"Benchmarking" is
a term often used for the comparison of one organization against
others, particularly those that are considered to be operating
at the highest level. The purpose of Benchmarking is twofold: first,
the organization is able to see how it compares with those whose
performance it wishes to emulate; second, it allows the organization
to benefit from the experience of the peak-performers, whether
it be in process or managerial practices.
Benchmarking against established
management standards, such as the ISO 14000 series or the Responsible
Care program developed by the Chemical Manufactures Association
(CMA), may be useful for those agencies with more mature environmental
programs, particularly if the agencies' activities are such that
their counterparts in the private sector would be difficult to
find. However, it should be understood that the greater benefit
is likely to result from direct comparison to an organization that
is a recognized environmental leader in its field.
5.2 CONTINUOUS IMPROVEMENT
The agency implements an
approach toward continuous environmental improvement that includes
preventive and corrective actions as well as searching out new
opportunities for programmatic improvements.
Continuous improvement is approached
through the use of performance measurement to determine which organizational
aspects need to have more attention or resources focused upon them.
Continuous improvement may be
demonstrated through the implementation of lessons learned and employee
involvement programs that provide the opportunity to learn from past
performance and incorporate constructive suggestions. In addition,
the agency actively seeks comparison with and guidance from other
organizations considered to be performing at the highest level.
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