The Oregon Department of Transportation has been able to reduce environmental impacts from its maintenance yards and improve environmental awareness, while also reducing costs thanks to an Environmental Management System (EMS) implemented across the state.
“ODOT’s EMS program is a cornerstone of our maintenance environmental program and encouraging stewardship,” according to Luci Moore, ODOT’s State Maintenance and Operations Engineer. “Our EMS program was developed in coordination with our front line managers to turn complicated environmental regulations into a program they could effectively and successfully manage across the state. Through adaptive management of the program over time, ODOT has improved conditions and material management practices at our yards.”
ODOT’s EMS program extends to all of ODOT’s maintenance yards statewide and describes “best management practices” (BMPs) for materials and wastes found at the yards.
An Employee Materials Management Handbook, which fits in a shirt pocket, summarizes essential information for maintenance crews. The pocket guide outlines “need to know” information about material storage, handling, and disposal, enabling road crews to meet regulations, support sustainability goals, and promote a healthy environment.
The pocket summary is supported by a full manual, which includes waste “cheat sheets”; spill response and management procedures; material labelling guidance; management of storage tanks and site drainage; permitted landfills; handling of road waste, including roadkill; pesticide handling; documentation requirements; technical references; legal citations; and a list of contacts who can provide help. Electronic versions of program materials including forms and checklists necessary to document a facility’s participation with the EMS Program are located on the agency EMS website.
Implementation of the Oregon DOT EMS program at maintenance yards has demonstrably:
- reduced the level of impact that maintenance yards have on the environment;
- reduced waste generation;
- decreased costs;
- delivered cleaner facilities;
- increased environmental awareness; and
- documented ODOT’s implementation of good practices; and
- helped satisfy a gubernatorial Executive Order that ODOT promote sustainable practices.
ODOT developed the EMS Program in 2004 with a hand-selected technical team that included representatives from roadway maintenance, specialty crews, safety, fleet, facilities management, hazmat and Oregon’s Department of Environmental Quality. Participants at the kick-off meeting reviewed a list of typical maintenance yard activities and identified gaps and overlaps in material management practices.
The team met monthly. Everyone on the team went through candidate BMPs to determine not only if the practices met laws and expectations, but also if the crews could implement the practices without unintended consequences.
The EMS Program is comprised of three parts: Policy, Procedures Manual, and the Handbook.
The EMS Procedures Manual contains 21 material specific procedures. Each procedure includes BMPs for storage, handling, and disposal. The EMS Manual also contains BMPs for drainage and water quality. BMPs throughout the Manual that are required by law or ODOT policy are identified by the word “must.” The word “should” is used to identify BMPs that reflect good stewardship and industry standards. This allows crews to easily identify requirements from recommendations.
ODOT distributed the initial versions of the EMS Policy, Procedures Manual, and Employee Handbook by the end of 2004. Statewide training that involved every maintenance employee began in the spring of 2005. ODOT updated the entire program in early spring 2009 after a line-by-line review of the original Manual. Supplemental training was provided. ODOT published the third and current version in 2013. Training classes are offered biannually.
A statewide steering team (the EMS Technical Team) meets biannually. The team focuses on systemic issues, regulatory changes, and concerns from the crews. The team, in conjunction with the Maintenance Leadership Team, determines when updates to the EMS manuals are appropriate. Guidance materials are updated as needed to improve success.
Auditing is an important part of the program. Three levels of audits are used to evaluate the EMS program: monthly field audits, regional audits, and statewide reviews.
Monthly field audits are one-page inspections of each maintenance yard conducted by local staff. monthly audits are kept onsite and reviewed during regional audits. Regional audits are triennial inspections of each maintenance yard conducted by the district manager, a yard representative, and a technical expert. Statewide reviews are conducted by the technical team as part of the biannual meetings.
Random site visit are conducted in addition to formal audits. Site visits provide an opportunity for technical specialists to identify and assist with site-specific issues that have proved challenging for local staff.
Seven procedures were selected as indicators of EMS program implementation.
- site drainage;
- aerosol cans;
- pesticides; and
- winter maintenance.
ODOT selected these specific procedures because of the type of wastes generated, the degree of regulation, continued confusion implementing the BMPs, and potential to impact natural resources. All seven priority procedures are evaluated at each maintenance yard during the regional audit. Responses to questions regarding the implementation of “must” BMPs in the priority procedures are compiled to evaluate compliance with the EMS Program.
In 2007 (when ODOT starting using the current performance measures) average statewide compliance was already at 94 percent. By 2012, the average had reached 98 percent. It remained at 98 percent through 2014.
Better Compliance, Less Waste Generation
Over the years, the EMS program has proven very beneficial. For example:
- In 2005, an ODOT facility received four citations ($14,432) for waste management and water quality violations. In 2012 the same facility was inspected and received zero violations.
- A 40-acre compound that houses at least 20 crews including maintenance, electrical, and bridge plus a heavy equipment repair shop, a sign shop, and a surplus property distribution center completed a two-day regulatory inspection with no citations. The regulatory inspector interviewed crew and well as managers. Each person was able to provide informed, engaged answers.
- Prior to the EMS program ODOT had 68 active hazardous waste identification numbers for maintenance yards and fleet repair shops. Identification numbers are required for small and large quantity generators. Small and large quantity generators are required to pay annual fees plus additional generation costs. By 2011, all ODOT facilities were conditionally exempt generators (CEGs). CEGs are the lowest category of hazardous waste generator and are exempt from fees,
- ODOT maintenance yards have reduced their hazardous waste generation. Since 2012, the statewide total hazardous waste generation for 98 facilities (including 3 heavy equipment repair shops) has been less than 2 tons annually.
ODOT is considering ways to better analyze the audit information to identify areas needing improvement. Based on prior analysis, ODOT has directed funds to construct stormwater improvements, upgrade storage tanks, and better contain deicer chemicals.
ODOT has found that one of the challenges to maintaining the EMS program is keeping the maintenance crews actively engaged so folks don’t return to less desirable practices. New employees, who did not participate in development of the EMS program, need to learn about implementation of current practices.
Another issue has been maintaining the focus of the EMS program. Because the program is successful, there are ongoing requests to add additional practices or topics. The EMS Technical Team reviews requests to determine if suggestions fit the scope of the program.
For DOT’s wanting to improve their EMS program, ODOT recommends obtaining buy-in from the people charged with implementing the process. The crews need to understand how applying the EMS program will help them. Each state will need to determine for itself, which practices are “required” and which practices are “recommended,” based on local regulations, permit requirements, and agency policies.
ODOT strives to maintain a practical program where direct onsite benefits are evident, roles and expectations are clear, BMPs allow operational flexibility, implementation is straightforward and achievable, paperwork is minimal, and local staff has easy access to answers.
“An important piece of creating the EMS program was enabling the team who developed it to speak their minds so that honest problems were identified and honest solutions could be developed,” said Jeff Moore Oregon DOT Clean Water Program Coordinator. “This was done by making sure no topic was off limits and that everyone felt safe saying whatever they wanted to say. There were no judgements and no repercussions for information or opinions shared within the group during EMS development. ….This approach worked to everyone’s advantage in that ultimately the whole team was invested in developing an EMS that could be implemented and achieve realistic and practical goals.”
For additional information, link to the ODOT EMS program website, or contact Shawna Secord, ODOT Operations and Policy Analyst with the Clean Water Program of the Maintenance and Operations Branch, at [email protected].