Environmental Management Systems (EMS) serve as tools for strategic planning to implement an organization's environmental priorities. The prime emphasis of this sort of strategic planning is quality improvement and assurance; accomplished through planning, well-documented action, re-evaluation, and implementation of improvements through revisions of plans and procedures. Based on total quality management and implementation of organizational learning, EMS is a tool that can help integrate environmental considerations into an organization's day-to-day operations and management culture.

EMSs provide a standard framework for an organization to establish its own specific environmental goals and then measure its performance in achieving those goals. The tool applies well-accepted business and planning principles to environmental issues and includes the following steps:

• PLAN: Identify the key issues (environmental aspects of operations, regulations, stewardship commitments) and establish what you want to do (policy, priorities, objectives, targets, and schedule).
• DO: Identify those responsible and affected; develop procedures and tools to fulfill objectives and meet the plan; develop and provide training relevant to the plan and the people involved; follow the established procedures and processes in the course of carrying out business.
• CHECK if expectations are met: Assess performance; determine if meeting objectives and targets; identify/audit if things are working as planned and if not, why not; determine corrective actions and measures for the future.
• ACT/ADJUST: Periodically review the entire process to identify opportunities to improve. Identify needed changes and next steps/adjustments; determine if anything should be added to the plan.

Only a handful of states have launched EMSs or other processes with the explicit goal of bringing about continual environmental performance improvement; a wider set of states has implemented one or several components of an EMS, as defined by the International Organization for Standardization (ISO and ISO 14001 in particular). [N]

In response to strong public interest, environmental stewardship was established as a government-wide objective, codified in Executive Order 13148, in April 2000. [N] Section 401 of this order directs each agency to implement an environmental management system at all appropriate agency facilities. The President followed up on this initiative by asking all agencies to promote the use of Environmental Management Systems (EMS) in federal, state, local, and private facilities, with annual reports on the matter. As part of its stewardship objectives, the Federal Highway Administration (FHWA) is encouraging the use of EMS in the construction, operation, and maintenance of transportation facilities. [N] [N] AASHTO is promoting the use and implementation of EMS, and has designed a "roadmap" to assist DOTs that are considering implementation. [N] AASHTO EMS resources are posted on AASHTO's Center for Environmental Excellence website.

State DOTs have begun to look at EMS as an organizing framework because it responds to some of their key needs, including:

• The desire to systematically demonstrate better environmental performance.
• Responsiveness to stakeholder preferences.
• Efficient use of financial resources.
• Ensuring coverage of complex liability issues.
• Regulators' requests.
• Awareness that environmental stewardship leads to regulatory streamlining.
• Control over priorities and timelines of the EMS.
• Organizational culture and personal commitment.
• Integration of environmental systems into strategic planning processes that are already in place. Environmental management systems include elements of quality control, health and safety, finance, and human resource management.
• Promotion of a positive organizational image.

In addition CEQ notes that under the federal "Modernizing NEPA Implementation" effort, EMS certification could provide advantages in getting projects through the NEPA and possibly the permitting process. [N]

Many of the economic and environmental benefits from implementing an EMS are derived from the proactive approach of pollution prevention. Pollution prevention strategies help reduce or eliminate environmental concerns at the source, resulting in less waste and clean-up, more efficient use of inputs, reduced risk and liability that may be reflected in lower insurance premiums and avoided contingency expenses, and many other environmental, health, safety, and financial benefits. EMSs can provide a way for air, water, waste and other environmental programs to be considered and integrated in a common impact reduction and opportunity implementation program. Under the EMS framework, an agency is able to ensure that major environmental risks, liabilities, and impacts are properly identified, minimized, and managed. It enhances the organization's reputation and image in the local community and creates a greater awareness of environmental performance within the organization across all departments, which can help improve overall management planning and promote cooperation. A more detailed overview of the benefits of EMS follows.

Environmental management systems have many notable benefits for DOTs; some examples are provided below. Collectively these benefits have the result of increasing predictability in DOTs core business processes. An EMS can take permitting and regulatory compliance issues out of the critical path of project development, by incorporating processes which identify, address, and resolve those issues in advance. Instead the focus shifts to how DOTs can continually improve environmental processes, whether regulated or not. Public support often grows and contractor performance improves as well. [N]

EMSs offer DOTs a way to address the public's interest in environmental protection stewardship, and enhancement. Agencies or facilities that adopt EMSs focus their attention on their highest-priority effects on the environment. Through the continuous improvement process and involvement of employees at all levels—with particular emphasis on ideas and input from the "shop floor"— EMSs can promote realization of new environmental opportunities.

EMSs provide a way to institutionalize what many leaders in state DOTs are already trying to do. In other places, EMSs emerge from environmental commitments made at the highest levels of executive leadership within a state. Organizations utilize an EMS process to develop goals, objectives, and procedures relating to the organization's environmental activities or performance. Common objectives for public agencies include achieving compliance with all regulations, going above and beyond compliance to voluntary stewardship and environmental enhancement, or implementing systemic process improvement. Implementing an EMS can improve cost savings and improve efficiency—a general objective for all public agencies operating within limited budgets. EMSs are in line with broader state DOT, FHWA and AASHTO objectives to improve environmental performance and demonstrate environmental stewardship.

Public and agency opinions of DOT projects play a large role in transportation decision-making. A 1990 public poll showed that 75 percent of U.S. consumers considered a company's environmental image in their shopping decisions. [N] While government agencies are subject to a different set of public decision-making processes through legislative budget-setting and through public meetings for projects on a local level, citizens, environmental groups, and the media can still mobilize public sentiment, alter accepted norms, and change the way people think about the environment and the role of the agency or facility in protecting it. Public interest and information regarding the environmental impacts and activities of DOTs and other organizations have grown, raising expectations of DOTs and the importance of DOTs' responsiveness and credibility with regard to environmental stewardship.

An organization has far more credibility in environmental stewardship when it has in place a process to assess its environmental performance. The general public offers greater support for an organization that can demonstrate how it continuously seeks to improve environmental performance. Improved relationships with regulators and other customers are a common outcome of EMS implementation. Developing and maintaining a positive public image with respect to environmental stewardship assists relationships with lawmakers and the media. For example, by implementing their environmental initiative, the New York State Department of Transportation (NYSDOT) has gained stronger, more positive working relationships with external agencies, citizens, local municipalities and other environmental groups, which in turn and have avoided costs by reducing delay, litigation, and frustrating rework, as well as wasted effort arguing contentious issues.

Although regulators and environmental review agencies will never relinquish all oversight responsibilities, they recognize when an agency with an EMS is taking its environmental responsibilities seriously. Implementation of an EMS signals an agency's serious approach to avoiding and minimizing environmental impacts and frequently leads to stronger interagency relationships. For example, The Pennsylvania Department of Transportation (PennDOT) District 5's efforts for consistency and planning in habitat assessments have improved relationships with U.S. Fish and Wildlife Services (USFWS) and streamlined NPDES compliance and oversight.

EPA, the multi-state working group on environmental management systems, and other regulators at the state and federal levels are moving forward with EMS as a policy option because they believe that organizations that adopt EMSs may be in compliance with environmental regulations at rates greater than non-EMS adopting facilities, over the long run. Regulators suggest that the environmental regulatory system may become less relevant for organizations that adopt EMS, as they continually improve their EMS and upgrade their environmental goals, objectives, and performance.

In some cases, regulatory agencies have specifically requested that an EMS be developed, or established an incentive to that effect. Mass Highway's environmental management program was developed in response to EPA's Environmental Performance Track. The agency reports that their EMS has led to improved relations with regulatory authorities, easing oversight burdens and permitting delays. In other industries, EPA's National Environmental Investigation Center has started to require EMS as a condition of settlement, with accompanying review of current management systems and development of detailed procedures, self-inspection, and monitoring processes which give regulators greater confidence in an entity's future performance and ability to catch and address problems in a timely way. [N] EPA's compliance-focused EMS guide is available on-line. EPA's Implementation Guide for Small and Medium Size Organization contains valuable information for DOTs and is available on-line. [N]

Even if the organization already has a compliance program, an EMS can help enhance consistency and efficiency in compliance, and capitalize on opportunities to move beyond compliance into voluntary stewardship and environmental enhancement. Through developing and utilizing an EMS, organizations can identify and address compliance problems and prevent them from recurring. Once a facility implements its EMS, that facility should be in conformance with all environmental regulations and in the process of exploring further avenues for environmental improvement.

As a result of using a structured, consistent audit program in operations and maintenance, Maine DOT has substantially improved and maintained their level of environmental compliance. In 2000, EPA enforcement staff conducted compliance inspections at several Maine DOT maintenance facilities and testing labs. Although very minor improvements were pointed out and immediately addressed by Maine DOT, no major problems were found and no fines were imposed. Employee "ownership" of and pride in their facilities and actions has risen substantially. In turn, the level of compliance achieved is much higher than with prior initiatives. John Dority, Maine DOT's Chief Engineer, said "[o] ur EMS has been remarkably successful in avoiding environmental penalties and fines. In most cases, the violations just don't exist when enforcement agencies visit our facilities. In cases where violations are found, we have found that the best possible response to the violation is to tighten up our EMS to make sure that similar incidents never happen in the future. Enforcement agencies have been quick to agree that tighter policies or tighter protocols are a more lasting solution than punitive fines." [N]

EMSs can rationalize and streamline how an agency addresses its various regulatory responsibilities. Eventually, EMS can form the basis for States to seek greater environmental delegations of authority from Federal agencies. Organizations and facilities that adopt EMSs and are able to reduce their environmental impacts beyond regulatory standards may lessen their environmental reporting burdens and the costs associated with them. Those that demonstrate proactive environmental management initiatives are in a better position to negotiate to reduce their regulatory burden and streamline environmental approvals. For example, PennDOT's EMS for maintenance facilities in Districts 10, 11 and 12 has been recognized by Pennsylvania Department of Environmental Protection (DEP) staff as best management practices that, in turn, ease oversight, monitoring, and permitting needs. The procedures and processes of the EMS generated sufficient confidence in state water quality regulators that inspections were reduced. PennDOT's internal documentation began to substitute for other reporting requirements.

In the process of redesigning operations and reducing environmental impacts, some organizations discover new opportunities to prevent rather than merely control adverse environmental impacts. Reducing resource use saves money while enhancing the environment. Organizations that implement EMSs typically discover ways to manage their operations as a whole more effectively.

During the extreme conditions of a recent winter operators and managers confirmed that materials usage control practices adopted by PennDOT helped them extend the life of their road salt inventory by as much as three weeks (based on their experience under similar conditions). PennDOT District 10 analysis of erosion and sedimentation control procedures and practices estimated training and planning may provide two weeks of work crew and equipment productivity at no increase in cost, by doing things right the first time instead of going back to correct problems, translating to cost avoidance of $25,000/year for District labor and equipment. EMS procedures and processes in Districts 10, 11 and 12 have been recognized by regulatory staff as best management practices that allow for a District-wide permit, eliminating monitoring and analyses, again saving resources. [N]

An EMS can be used to establish quality goals and performance standards for both broad-scale processes, such as project development, and for very specific field functions like materials handling and construction techniques within construction, maintenance, and operations units. Implementation of EMSs has resulted in improved pollution control and resource use, fewer accidents and spills, and improved safety and environmental quality for both employees and citizens. In most cases, EMSs facilitate the agency's move beyond legal standards for regulated activities to identification of opportunities for reducing non-regulated environmental impacts of its activities. Environmental effects of agency operations and the most promising, immediate opportunity areas frequently extend beyond what is controlled by environmental regulations. EMSs allow implementation of change identified by and at a pace set by the action agency. Then the agency establishes targets or indicators they can use to track improved environmental performance.

Research confirms that facilities, agencies, and organizations can reap substantial benefits from improving the management of their environmental impacts and publicizing their proactive environmental activities. [N]

EMS implementation typically results in efficiency gains. Public agencies at all levels — federal, state, and local — have begun implementing EMSs in an effort to reduce operational costs by using fewer resources, optimizing the use of resources that are needed, and increasing reuse and recycling. Although it requires an up-front investment in time, staff, and management commitment, an EMS can result in cost savings over time. Efficiency gains may include reduced liability and lower costs, including more favorable insurance and bond ratings.

Among NHDOT's significant accomplishments, the Traffic Bureau eliminated an environmental liability of shipping 6,000 gallons of waste paint to Illinois for treatment on an annual basis. Following review of environmental aspects of operations, this practice was halted. Equipment was purchased to process the waste paint at Traffic's facility, solid waste from which is now used by a start up company in its manufacturing process for plastic construction materials such as noise barriers. In addition to elimination of the environmental liability, NHDOT is saving $15,000 annually through this process improvement. NHDOT also began hydrostripping worn aluminum traffic signs. This has resulted in lower resource use, and lower cost to deploy signing, since the reused blanks are 40 percent less costly than new material. Through inventory controls, the Bureau's target is to utilize 95 percent of recycled sign material for sign manufacturing in five years. New Hampshire's DOT Commissioner was quoted as saying, "we cannot afford not to have an EMS." [N]

Efficiency gains also extend to management and operations. Organizations perform better when they systematically manage their affairs. An EMS improves productivity by systematically addressing environmental concerns as part of overall management practices and organizational strategies. EMSs give the people who know operations best a) the responsibility to identify the environmental aspects of their activities, b) the means to measure progress against a baseline, and c) the incentive to make improvements. This results-oriented approach by insiders can be more effective than process-oriented oversight by outside groups that may want to add marginally effective extra steps. In effect, an EMS is a tool for reviewing all the environmental aspects of a job, including external regulatory requirements, and coming up with a systematic way to address them. An EMS provides a framework for examining and collating best practices for day-to-day-operations.

At Maine DOT, EMS processes and procedures have enabled managers/supervisors to more efficiently manage their materials (by sharing among facilities) and waste. These actions have provided costs savings. More efficient management of materials and control of facility operations lead to reductions in the space needed to conduct/support maintenance activities. From an immediate perspective, less space means less opportunity for noncompliance and a reduction in the costs and environmental impacts associated with noncompliance. From a long term perspective, a need for less space could lead to savings in land maintenance and acquisition costs. [N]

NHDOT built on and incorporated existing programs in constructing their EMS. The Department realized organizational efficiencies by merging expanded health and safety program requirements into EMS plans, enabling several important elements of department activities (environment, health, and safety) to be addressed in one operational document. Despite these efficiencies, NHDOT found that sufficient new staff resources were required in order to maintain written procedures, support program development, support the internal audit function, and maintain records needed to perform performance measurement and corrective action tasks. Consequently, NHDOT added an EMS Manager to facilitate the steps in developing an EMS, assist in procedure development and implementation, and support internal and external communications. [N]

Organizations that have implemented EMSs also commonly report that the organization as a whole and individuals throughout developed a much better understanding of their work, its impacts, and how it all relates to each other. The EMS fostered a greater sense of responsibility, awareness, and meaning in the work at hand, from the corporate to the individual level. EMSs have been a tool for extending employee involvement and awareness in many organizations, with EMS practices providing a foundation for other quality improvement actions and showing all employees that they play a vital role.

Matt Jordan, Director of Public Works & Utilities, Gastonia NC said, "[w]e went from an organization doing a lot of different tasks and jobs to (staff) seeing how it fits into the whole department and feeling they'll make a difference. It's also a good way to meet regularly, respond to their suggestions, and utilize their experience." The Idaho National Engineering and Environmental Laboratory reported, " EMS gave our employees a willingness to take initiative and responsibility for environmental performance." [N] During employee interviews for the ISO 14001 readiness audit in PennDOT District 10, an operator commented on Erosion and Sedimentation Control procedures to the third party auditor, saying "I've worked here for more than 20 years. We never did this before but that doesn't mean we were right. This is what I want to do for my children and grandchildren." [N]

Mass Highway managers noticed an increased environmental awareness in the substantial majority of maintenance employees. This awareness, coupled with environmental procedures, responsibilities, training, and assessments, helps Mass Highway prevent environmental problems and makes it easier to correct such problems when they do occur in turn, reducing costs of compliance (including potential fines) and corrective actions.

State transportation agencies, like all government entities, are increasingly pressured to do more with less. Efficiency and performance measurement have been watchwords, and performance measurement is steadily increasing both on the state and federal levels. Twice as many laws enacted in the 105 th Congress (1997-98) had provisions pertaining to performance as the previous Congress. [N] A third of state agencies in a recent survey said they measured performance across the agency. [N] Not only is such information increasingly demanded by external stakeholders and funders, such documentation facilitates management at the highest levels and increases the ability of agency staff to communicate with key stakeholders and demonstrate responsiveness. EMSs can increase agencies' ability to respond to these demands with solid data and show improved performance. [N] [N]

The structure of an EMS may vary, though the most common is the ISO 14001 standard because it offers the opportunity to become recognized and certified. ISO stands for the International Organization for Standardization, which adopted the ISO acronym because ISO means "equal". ISO 14001 certification is an effective and widely recognized method for demonstrating an organization's commitment to environmental performance and quality management. [N] Though ISO standards have been developed for hundreds of products and processes worldwide, with the 14001, ISO has suggested a broader, strategic approach than most of their other product and process standards. Their purpose was to develop environmental management system standards that can be implemented in any type of organization in either public or private sector (companies, administrations, public utilities). As such the 14000 series share much in common with the ISO 9000 series for quality management.

ISO defines EMS as "that part of the overall management system which includes organizational structure, planning activities, responsibilities, practices, procedures, processes and resources for developing, implementing, achieving, reviewing and maintaining environmental policy." [N] The EMS provides the structure by which specific activities related to environmental protection and compliance can be efficiently and effectively carried out.

ISO 14001 compliant Environmental Management Systems have six key elements:

1. Environmental Policy: An organization's environmental policy serves as the basis for EMS design and implementation. It sets out the organization's goals and defines the actions the organization will follow. Environmental policies should demonstrate a commitment to compliance, pollution prevention, and the well being of employees, customers, and the local community. The policy must be approved by top management and communicated to all employees, since they will play an integral role in meeting the goals of the policy.
2. Planning: Careful planning allows the organization to proceed with implementation of an EMS in a logical, orderly manner. Planning should include comprehensive analysis of an organization's operations and the inherent environmental impacts, as well as consideration of the steps necessary to meet new goals. Standard operating procedure may be modified to meet the goals of the new Environmental Policy.
3. Implementation and Operation: Roles and responsibilities should be clearly defined for all staff. Implementation of an EMS often requires across-the-board training and other forms of support to acclimate all levels of staff to new priorities and practices. Documented procedures help establish and maintain momentum toward the organization's environmental and economic performance goals.
4. Checking and Corrective Action: Maintenance of an EMS fosters a high level of organizational discipline. Auditing, monitoring, and measurement of environmental indicators are necessary to achieve the goals and assess progress toward the objectives defined in the Environmental Policy. They also provide opportunities to create performance incentives for all levels of staff.
5. Management Review: The development, implementation, and maintenance of a successful EMS must be strongly supported by an organization's top management. Top management review strengthens the awareness and commitment through leadership of the EMS goals, assigning decisions regarding staff responsibilities and performance evaluation and ensuring continuing suitability, adequacy, and effectiveness of the organization's operations and practices. It should be conducted on a regular schedule.
6. Continual Improvement: Continual improvement is an inherent outcome of an effectively implemented EMS. Performance reviews and updating the gap analysis can help guide the organization's progress. Improvements should emphasize preventive actions.

In considering whether to develop an EMS which could achieve registration to the ISO 14001 standard, Washington State DOT (WSDOT) developed the following comparison table of characteristics of, differences between, and examples of a non-certification EMS, ISO consistent and ISO 14001 registered organizations: [N]

Table 3 : Characteristics and Examples of Non-Certification, ISO Consistent and ISO 14001 Registered Organizations

While ISO and EMSs emphasize a holistic approach, DOTs may find it most practical to look at the individual parts of an EMS, some of which they may already have in place and assess what they are missing or want to do next. This process is typically termed a "gap analysis."

An EMS should build on policies, procedures, processes, and tools an organization already has in place, to the maximum extent practicable. Consequently, many organizations like to start with a "gap analysis," looking at elements of an EMS, often as defined by ISO 14001, compared to what an organization has already done. Gap analysis tools are available for self-evaluation. EMS specialists have such tools available. The sections of this report, especially the conclusion of each section on standards and measures, also contain bulleted lists of questions or elements DOTs can use as checklists in evaluating gaps and/or ways to improve what they may have already developed.

The New South Wales ( Australia) Regional Transportation Authority developed the following cross-reference to identify which components of their environmental management system addressed ISO 14001 elements: [N]

Table 4 : Comparison between NSW RTA EMS and Elements of ISO 14001

AASHTO's Center for Environmental Excellence website contains EMS resources developed for the State DOT EMS Workshop in August 2003, including an 11-step EMS "roadmap" for DOTs.