|Vermont DEC has been involved with environmental management systems and technical assistance since the spring of 1998, after being one of several states, including both Vermont and New Hampshire, to receive funding as part of an EPA Headquarters pilot to evaluate the environmental benefits of ISO 14000-equivalent environmental management systems.
VT DEC used some of the grant funds to hire a consultant to develop an EMS design and implementation workshop series. DEC announced the availability of the program to Vermont service sector businesses and manufacturers, with the hope of involving small to mid-sized businesses. Participating businesses receive no-cost training and on-site assistance in developing an EMS that addresses all of the ISO 14001 elements and standards. But certification to the standards is not the intent of the program. Those participants wishing to seek certification could do so on their own. In exchange for the training and assistance, participants agree to complete surveys on environmental performance before, during, and after EMS design and implementation.
About 15 facilities initially responded to the advertisement of the program, with 12 facilities eventually agreeing to participate. Participants included both service-sector businesses and manufacturers, ranging in size from a small electrical utility with 42 employees and a manufacturer of reamers, employing 65 people, to manufacturers with 100-400 employees. In addition, a large health care facility (with over 3000 employees) signed up.
The workshop and program format consists of a series of seven EMS design and implementation workshops over a period of a year, beginning in May 1998 and ending in late April 1999. Each training session addresses several of the 17 elements of an ISO 14001 EMS. Worksheets were developed for many of the elements (such as ranking of significant environmental aspects; and objective and targets development) to assist facilities in completing these elements. Workshops have been spaced two or more months apart to allow facilities to work on completing the assigned EMS elements. The workshops allow for participants to share information, successes, and problems encountered. Staff from the Environmental Assistance Division and Vermont Small Business Development Center provide on-site assistance and review upon request.
Several facilities participating in the project have experienced difficulties in securing management commitment for development of an EMS. Many of the participating facilities are not under pressure to obtain ISO certification and therefore see EMS as a lower priority when other pressing issues come about. Many facilities have general difficulty in allocating time and making the necessary commitment to work on their EMS. It was initially envisioned that facilities in the pilot would complete their EMS in a 6-7 month period. A more realistic time line is now more than one year. Some have had difficulty in forming teams of key players to assist and participate in EMS development. On the other hand, a few participating facilities have since learned or decided at the corporate level to pursue ISO 14001 certification since the pilot began and are now more committed.
Small and mid-sized manufacturers must understand the benefits to their facilities of developing an EMS. This is often not readily apparent, however it is key to management commitment. State programs can help facilitate this process by providing case studies and contacts in other similar facilities that have successfully pursued EMS development. One of the most valuable parts of the EMS training was hearing from a smaller manufacturer (165 employees) that obtained ISO 14000 certification and explained the process and the benefits they have experienced.
The jury is still out on just how valuable an EMS proves to be for smaller businesses participating in the pilot. Many participants sense the value of a more systematic, well documented approach to pollution prevention and compliance that comes about as a result of an EMS. It is readily apparent that pilot facilities with ISO 9000 certification finder it easier in many respects to develop an EMS.
Regulatory Flexibility Considered
Vermont DEC is providing some regulatory flexibility for facilities that have developed an EMS in the area of pollution prevention planning requirements. For this round of Pollution Prevention Plans due July 1, 1999, an EMS Alternative to planning is being offered. (A similar EMS alternative is provided by Washington State.) Facilities that are already ISO 14000 certified and those participating in the pilot are eligible for substituting their EMS for the required plan, provided that the EMS adequately addresses pollution prevention in its objectives and targets and the EMS stands up to established review criteria.