ATTACHMENT B:  ENVIRONMENTAL MANAGEMENT SYSTEMS
This attachment contains the following sections:  
•	What is an Environmental Management System?
•	Environmental Management Systems References and Internet Resources
•	Basic EMS Worksheets
•	ISO-Comparable EMS Worksheets

What is an Environmental Management System?  

Many facilities in the public and private sectors are interested in improving their environmental management practices.  Internationally, voluntary environmental management standards have emerged to bring expectations about environmental management and environmental performance into harmony.  One of these efforts, conducted by the International Organization for Standardization (often known by its French acronym, ISO) has resulted in a series of international environmental management standards known as the ISO 14000 series.  Many public agencies, including the Oregon Department of Environmental Quality, are promoting the ISO 14000 Environmental Management System series of standards as a tool for facilities to develop formal environmental management systems.  
The ISO 14000 standards were developed through an international, consensus-based process.  They consist of specifications and guidance documents on a variety of topics, including environmental management systems, auditing, labeling, performance evaluation, and life cycle assessment.  Facilities can be certified to the ISO 14001 EMS standard through a formal third party audit process.  
Many facilities have benefited economically by improving efficiency and reducing environmental risks throughout their environmental processes.  An environmental management system (EMS) can help a facility address environmental issues proactively and comply with regulations.  
Many facilities find that process mapping and other pollution prevention assessment tools can simplify development of an EMS.  Process mapping can be used to identify environmental impacts of a facility’s operations; materials accounting can help track and manage materials that flow through a facility; cost accounting tools help monitor costs associated with environmental management; and decision-making tools can help identify alternatives and solutions.  Facilities that have developed a Toxics Use Reduction and Hazardous Waste Reduction (TURHWR) Plan under Oregon’s TURHWR program may have already established a strong foundation on which to build an EMS. In addition, Oregon’s TURHWR rules allow an EMS to substitute for a TURHWR plan.  
The EPA has developed an excellent “how-to” implementation guide entitled “Environmental Management Systems:  An Implementation Guide for Small and Medium-Sized Organizations” (NSF International, Ann Arbor Michigan, 11/96).  It is free and downloadable off the Internet at www.epa.gov/owmitnet/wm046200.htm.  Hard copies are also available from DEQ.  
For more information about environmental management systems, visit the Internet Web sites listed in the following section.  EPA also is developing a new EMS clearinghouse, located at www.epa.gov/ems.  
•	Green Permit Environmental Management Systems
The Green Environmental Management Systems (GEMS) Permits require implementation of an environmental management system, depending on the type of permit desired:  a Basic EMS, ISO-Comparable EMS, or ISO-Conformant EMS.  
•	Basic EMS
A Basic EMS has the following characteristics:  
The EMS is centered on and driven by environmental impacts.  It includes a core set of planning activities that ensures a facility will:
•	Identify operations and processes that impact the environment
•	Evaluate impacts that are significant
•	Set objectives and targets to reduce significant impacts
•	Identify and implement activities to achieve identified targets
The EMS promotes integration of environmental management and business functions by integrating environmental management with other operations and overall management practices. For example, it should include:
•	Environmental policies defined by top management
•	Consideration of the effect of operating conditions and controls on targeted environmental impacts
•	Implementation authorities, responsibilities and resources 
•	Periodic management review of environmental performance and other results
The EMS provides for continual improvement through the following:
•	Specific timelines, authorities, and designated responsibilities for executing the plan 
•	Procedures to monitor compliance and correct or eliminate problems 
•	Periodic evaluation to assess progress and identify needed improvements
•	Monitoring and evaluating activities related to targeted impacts
The EMS can be verified easily.  It should ensure that activities and compliance with GEMS commitments can be verified objectively through documentation or other means.
•	ISO-Comparable EMS
An ISO-Comparable EMS is one that performs the same functions as described in the ISO 14001 standard.  Worksheets are included to help the facility evaluate its comparability.
Some basic elements of an ISO-comparable EMS include:  
•	Environmental policies
•	Identification of environmental aspects
•	Legal and other requirements
•	Objectives and targets
•	Environmental management system
•	Structure and responsibility
•	Training, awareness and competence
•	Communication
•	Documentation
•	Document and operational control
•	Emergency preparedness and response
•	Monitoring and measurement
•	Nonconformance and corrective and preventive actions
•	Records and audits
•	Management review
The worksheets include examples of situations where specific elements may be missing from the EMS, and the resulting impacts.  
•	ISO-Conformant EMS
An ISO-Conformant EMS is one that has been certified by an accredited registrar as meeting the ISO standard.  An ISO-conformant EMS does not have to be verified by the agencies, except those components of the Green Permit program that are different from the ISO 1400s standard (such as the definitions, scope).  

Web Sites of Interest

The following resources provide general information on EMS’s and state and federal programs.  For more information, contact DEQ’s Green Permits program at (503) 229-5946.  
International Organization for Standardization (ISO)
http://www.iso.ch/welcome.html
ISO developed the ISO 14001 series of standards, guidance documents and technical reports, including the ISO 14001 Environmental Management System standard.  
American National Standards Institute (ANSI)
http://www.ansi.org/iso14000/index.htm
ANSI coordinates the development of American National Standards and is one of five permanent members of the governing ISO council.  ANSI distributes copies of the ISO 14000 standards.  
National Database on Environmental Management Systems 
http://www.eli.org/isopilots
The National Database on Environmental Management Systems is a national effort to evaluate the effectiveness of environmental management systems.  This site is sponsored by the Environmental Law Institute, the University of North Carolina and the U.S. Environmental Protection Agency, in partnership with the Multi-State Working Group.  The site contains the data protocols, data, public reports and other information on the database project.  The site includes links to other ISO 14000 information on the Internet.  
Multi-State Working Group on Environmental Management Systems
http://www.mswg.org
(located on the State of Pennsylvania web page)
The Multi-State Working Group on Environmental Management Systems is a consortium of federal and state agencies, non-governmental organizations, industry representatives and academia that is examining the public policy implications of environmental management systems, particularly ISO 14001.  Oregon is a member state. The site includes links to other ISO 14000 information on the Internet.  
NGO Working Group on ISO 140000
http://www.ecologia.org/iso14000/
ECOLOGIA and the Community Nutrition Institute (CNI) have been concerned about the lack of non-governmental organization (NGO) participation in the ISO 14000 standard setting process and are working with other environmental NGOs to influence the process through the NGO Initiative: ISO 14000 project. 
EPA Office of Reinvention and Policy
http://www.epa.gov/reinvent
The EPA is testing innovative approaches to environmental protection through a number of voluntary initiatives.  The site provides links to the various projects, including Project XL.  
EPA Standards Network
http://es.epa.gov/partners/iso/iso.html 
This Enviro$sen$e site contains answers to frequently asked questions about ISO 14000.  
EPA Environmental Management Systems Clearinghouse
http://www.epa.gov/ems 
North Carolina Division of Pollution Prevention and Environmental Assistance
http://www.p2pays.org/iso/index.htm 
Wisconsin Department of Natural Resources, Environmental Cooperation Pilot Program
http://www.dnr.state.wi.us/org/caer/cea/ecpp/ecpp.htm
Wisconsin Department of Natural Resources
http://www.dnr.state.wi.us/org/other/iso
European Union Environment Website
http://europa.eu.int/comm/emas
Information about the Eco-Management and Audit Scheme (EMAS) and other environmental news and publications from Europe.
Principles of Pollution Prevention
http://www.pollutionprevention.com  
A web page developed by Dr. Robert Pojasek to introduce principles of pollution, including process mapping, zero waste goals, and other methods to help facilities take a systems approach to achieve cleaner production and sustainable development goals.  Distance learning tools are included.  
National Pollution Prevention Roundtable ISO 14000 White Paper
http://www.p2.org/iso.html 
The National Pollution Prevention Roundtable’s white paper on ISO 14000 and its strengths and weaknesses in relation to pollution prevention.  

Verification Worksheet for a Basic EMS

Facility and Verifier Data	
Facility:	Date:	
Verifier:	Date:	

PURPOSE OF THE WORKSHEET
•	To assist a facility to demonstrate that its EMS meets the criteria for a GEMS Participant Basic EMS.
•	To assist verification that the EMS qualifies for a GEMS Participant Permit.
•	To provide a record of verification.
DEFINITION
A Basic EMS is driven by environmental impacts, helps integrate environmental and business functions, provides for continual improvement and is verifiable. It includes a commitment to achieving and maintaining regulatory compliance and to applying the pollution prevention hierarchy to the environmental management program. It is a tool to improve environmental performance of regulated activities and to excel in the management and reduction of regulated pollutants and toxic substances.
USE OF WORKSHEET
1.	Four pages of the Worksheet are filled in by the facility, one for each functional purpose (EMS element) of their Basic EMS.
2.	The facility fills in the left-hand column of the first cell of each page by listing the elements of their EMS that relate to that functional purpose. They describe the purpose of each element and provide and/or reference documentation. (Some documentation may have to be reviewed at the facility site.)
3.	The facility fills in the left-hand column of the second cell by describing the methods and activities that they have implemented to accomplish those purposes.
4.	The Verifier completes the checklist on the Verification Guidance page by reviewing the facility information and other documentation and placing a check mark when the item is adequately represented. 
 	NOTE: All check boxes need not be checked for an EMS to be in conformance. Judgement must be exercised as to what represents major or minor non-conformances. Several unchecked boxes for a clause would represent a non-conformance.
5.	DEQ staff reviews the information and accompanying documents, fills in the “Notes” column, and assigns an Assessment Code, C, S, or N, based on an overall assessment of all the items of the EMS element. 
6.	The Summary Worksheet is used to compile the results of the verification.

SUMMARY WORKSHEET	

I.	EMS CHARACTERISTICS AND SCOPE FOR A 
BASIC EMS

This summary worksheet compiles results from individual verification worksheets for each clause of the Basic EMS standard.

Facility: 	Date: 	
Verifier: 	
Basic EMS Clause	Assessment C/S/N	
I. Centered on and Driven by Environmental Impacts		
II. Promotes Integration of Environmental Management and Business Functions		
III. Provides for Continual Improvement		
IV. Supports Verification		
TOTAL COUNT:	C
	S
	N

I. EMS is centered on and driven by environmental impacts	

This Column to be Filled in by Facility	This Column for Verifier Notes	
ELEMENTS – List elements of your EMS that serve the purpose described in this Basic EMS clause. 	
		
IMPLEMENTATION – Describe the methods and activities that have been implemented.	
		
Assessment Codes: C = In Conformance;  S = Sufficiently In Conformance (Non-Conformances are minor); N = Not In Conformance	Verifier Assessment Code		

I. EMS is centered on and driven by environmental impacts

VERIFICATION GUIDANCE
GEMS PARTICIPANT PERMIT EMS GUIDELINES CHECKLIST
	Does the EMS have a core planning activity to identify facility operations and processes that have an environmental impact relative to regulated activities and pollutants?
	Does the facility have a procedure, and has that procedure been used, to identify legal requirements relative to emissions to air, releases to water, contamination of land, and waste management?
	Does the facility have a procedure, and has that procedure been used, to identify the facility operations and processes that have an impact relative to those legal requirements, covering a variety of operating conditions?
	Does the EMS have a core planning activity to evaluate which impacts are significant?
	Does the facility have a procedure, and has that procedure been used, to identify which environmental impacts have or could have a significant impact on the environment?
	Does the EMS set objectives and targets for reducing the facility’s highest priority impacts?
	Does the facility have a process, and has it implemented the process, for selecting its highest priority impacts and setting objectives and targets accordingly?
	Do the objectives and targets demonstrate a knowledge and commitment to pollution prevention according to the hierarchy?
	Does the EMS select and implement activities to achieve identified targets?
	Have program and action items been defined to achieve the applicable targets?
	Has responsibility for achievement of applicable targets been designated to specific staff positions?
	Have methods been defined to measure progress towards achievement of the targets?
PURPOSES
This element helps base actions and decisions about how to spend limited resources on a thorough understanding of environmental impacts. It also focuses activities on consistent performance goals, and grounds activities in a basis of fact. It also translates an understanding about where we are, what is expected of us, and where we want to be into actionable plans – “How are we going to get there?” – and forces consideration of who has what role in improving performance and what resources are needed.
IMPACTS OF ABSENCE
•	Too narrow a consideration of environmental issues, not considering all legal requirements.
•	An EMS that does not help a company maintain compliance.
•	Schism between the EMS and the really important stuff.
•	No long-term focus on improving performance.
•	No accountability for achieving goals.
•	Unattainable goals set for PR value.

II. The EMS promotes integration of environmental management and business functions, including facility operations and overall organizational management.	

This Column to be Filled in by Facility	This Column for Verifier Notes	
ELEMENTS – List elements of your EMS that serve the purpose described in this Basic EMS clause. 	
		
IMPLEMENTATION – Describe the methods and activities that have been implemented.	
		
Assessment Codes: C = In Conformance;  S = Sufficiently In Conformance (Non-Conformances are minor); N = Not In Conformance	Verifier Assessment Code		

II. The EMS promotes integration of environmental management and business functions, including facility operations and overall organizational management.

VERIFICATION GUIDANCE
GEMS PARTICIPANT PERMIT EMS GUIDELINES CHECKLIST
	Does the EMS include an environmental policy defined by top management?
	Does the facility have an environmental policy?
	Has top management played a central role in defining or approving the environmental policy:
	Does the environmental policy include a commitment to maintaining regulatory compliance?
	Does the environmental policy include a commitment to the pollution prevention hierarchy?
1. Source Reduction (highest priority)  2. Recycling  3. Treatment  4. Disposal
	Does the EMS consider operating conditions and controls and their effect upon targeted environmental impacts?
	Has the facility identified the operating conditions that have an impact on the targeted environmental impacts?
	The EMS should identify specific authorities, responsibilities and resources needed for implementation.
	Are roles, responsibilities and authorities clearly defined and communicated throughout the organization?
	Have the necessary human, financial and technological resources been defined and provided?
	Does the EMS provide for periodic management review of system results and environmental performance?
	Is there a periodic process for management review that involves top management?
	Have issues identified in management review been pursued?

PURPOSES
This element represents a statement of management’s intent for the EMS and clarifies values.  It says “How good do we intend to be?”, sets direction for development of the EMS, sets expectations of stakeholders, and guides employees in the absence of other explicit direction. It also applies policies, targets and activities directly to specific operating conditions, and points to the need to monitor and maintain operational control systems. It makes it clear who is responsible for what, and provides the authority and resources to carry out the responsibilities.
IMPACTS OF ABSENCE
•	Purpose and intent of the EMS is unclear, resulting in an EMS that isn’t aligned with management’s intentions.
•	No evidence that management stands behind environmental policies may cause cynicism, both internally and externally.
•	Inability to reliably meet performance goals because the processes and operations that impact performance are not identified and controlled.

•	An EMS that is disconnected from senior management and from the realities of the business.
•	Lack of accountability for achieving goals and completing corrective actions.

III. The EMS provides for continual improvement of the system and environmental performance.	

This Column to be Filled in by Facility	This Column for Verifier Notes	
ELEMENTS – List elements of your EMS that serve the purpose described in this Basic EMS clause. 	
		
IMPLEMENTATION – Describe the methods and activities that have been implemented.	
		
Assessment Codes: C = In Conformance;  S = Sufficiently In Conformance (Non-Conformances are minor); N = Not In Conformance	Verifier Assessment Code		

III. The EMS provides for continual improvement of the system and environmental performance.

VERIFICATION GUIDANCE
GEMS PARTICIPANT PERMIT EMS GUIDELINES CHECKLIST
	Does the EMS create specific timelines, authorities and designated responsibilities for plan execution and activity implementation?
	See verification step II. C above.
	Are timelines for plan execution clearly defined?
	Are timelines for activity implementation clearly defined?
	Does the EMS create procedures to routinely monitor compliance, and correct or eliminate problems (i.e. through root cause analysis)?
	Has the facility established procedures to monitor and measure on a regular basis the performance of processes, systems and equipment that effect compliance-based environmental impacts?
	Have the procedures been followed?
	Has the facility established procedures for investigating, analyzing and correcting problems that arise?
	Does the EMS periodically assess progress towards the targets and identify needed system improvements?
	Has the facility established procedures or schedules for monitoring performance relative to improvement targets?
	If the facility fails to achieve a target, are the causes and needed improvements identified?
PURPOSES
This element makes it clear what needs to be done by when and assures an effective sequence of work. It also requires that commitments to regulatory agencies and the public are taken seriously and that the organization takes primary responsibility in monitoring their performance to meet the agreed conditions. It ensures that appropriate resources are applied to identify and correct problems.
It also assures that activities achieve targeted improvement, or that changes are instituted if improvement falls short of targets.
IMPACTS OF ABSENCE
•	No accountability for when the plan and activities should be carried out.
•	Guesswork in management and maintenance of environmental compliance systems.
•	Problems that are hard to fix don’t get fixed.
•	Problems are repeated over and over.
•	Guesswork in monitoring and reporting environmental improvement.
•	Falling short of a target is not identified.

IV. The EMS supports verification by incorporating documentation or other means that can demonstrate to a third party that the system conforms with the Basic EMS Standard.	

This Column to be Filled in by Facility	This Column for Verifier Notes	
ELEMENTS – List elements of your EMS that serve the purpose described in this Basic EMS clause. 	
		
IMPLEMENTATION – Describe the methods and activities that have been implemented.	
		
Assessment Codes: C = In Conformance;  S = Sufficiently In Conformance (Non-Conformances are minor); N = Not In Conformance	Verifier Assessment Code		

IV. The EMS Supports Verification by incorporating documentation or other means that can demonstrate to a third party that the system conforms with the Basic EMS standard.
VERIFICATION GUIDANCE
GEMS PARTICIPANT PERMIT EMS GUIDELINES CHECKLIST
	What means were used to demonstrate that the EMS was in conformance with this standard:
	Documentation of the EMS planning process 
	Records that planning activities took place 
	Documentation of the outcomes of planning activities
	Written policies, procedures and timelines
	Documentation of the assignment of roles and responsibilities
	Records of implementation actions
	Records of results and outcomes of implementation actions 
	Documentation of standard practice and schedules for monitoring activities 
	Records of monitoring activities
	Document control procedures, including records of changes to documents and assurance that the current document is the one made available
	Other:		
	Were means available to verify that the EMS was in conformance with each clause of this standard?  Which clauses were not third-party verifiable due to lack of means to do so?

		

IMPACT OF ABSENCE
•	Inability to verify that the EMS has been properly implemented.

Verification Worksheets for an ISO 14001 Comparable Ems

Facility and Verifier Data	
Facility:	Date:	
Verifier:	Date:	

PURPOSE OF THE WORKSHEETS
•	To assist the facility in demonstrating that their EMS is comparable to an ISO 14001 EMS.
•	To assist verification that the EMS qualifies for a GEMS Achiever or GEMS Leader Permit.
•	To provide a record of verification.
DEFINITION
An ISO 14001 Comparable EMS is functionally equivalent to an ISO 14001 EMS. Each ISO clause has a corresponding element(s) in the facility’s EMS that serves the same purpose. The facility’s EMS, however, may use different implementation methods. 
USE OF WORKSHEETS
7.	One Worksheet page is used for each ISO 14001 clause.
8.	The facility fills in the left-hand column of the first cell of each page by listing the elements of their EMS that are comparable to the ISO clause. They describe the purpose of each element. They also provide and/or reference relevant documentation. (Some documentation may have to be reviewed at the facility site.)
9.	The facility fills in the left-hand column of the second cell by describing the methods that their EMS has implemented to achieve the purposes of that element.
10.	The Verifier completes the checklist on the Verification Guidance page by reviewing the facility information and other documentation and placing a check mark when the item is adequately represented. 
 	NOTE: All check boxes need not be checked for an EMS to be in conformance. In an ISO 14001 certification audit unchecked boxes would be considered “potential non-conformances”. However, judgement must be exercised as to what represents a major or a minor non-conformance. Several unchecked boxes for an ISO clause would represent a non-conformance.
11.	The Verifier fills in the right-hand column, including an Assessment Code, C, S, or N, based on an overall assessment of all the items of the EMS element.
12.	The Summary Worksheet is used to compile the results of the verification.
NOTE: Use Basic EMS Verification Worksheets for GEMS Participant Permits.

SUMMARY WORKSHEET FOR AN ISO COMPARABLE EMS

This summary worksheet to be completed by verifier. It compiles results from the individual verification worksheets.

ISO Clause	Is this a Critical Element?	Assessment
C/S/N	
4.2 Environmental policy	Y		
4.3.1 Environmental aspects	Y		
4.3.2 Legal and other requirements	Y		
4.3.3 Objectives and targets	Y		
4.3.4 Environmental management programs	Y		
4.4.1 Structure and responsibility			
4.4.2 Training, awareness and competence			
4.4.3 Communication	Y		
4.4.4 EMS documentation			
4.4.5 Document control			
4.4.6 Operational control			
4.4.7 Emergency preparedness & Response			
4.5.1 Monitoring and measurement			
4.5.2 Nonconformance and corrective and preventive action			
4.5.3 Records			
4.5.4 Environmental management system audit	Y		
4.6 Management review	Y		
TOTAL COUNT:	C	S	N	
ARE ANY CRITICAL ELEMENTS NON-CONFORMANT (Y/N)?		

4.2 Environmental policy	
Purpose of ISO Clause (in ISO’s Words):  
To state intentions and principles in relation to overall environmental performance.
To provide a framework for action and for setting environmental objectives and targets.
Clarification of Purpose:
Statement of management’s intent for the EMS, clarifies values. Says “How good do we intend to be?”  Sets direction for development of EMS. Sets expectations of stakeholders. Guides employees in absence of other explicit direction.
Methods Specified by the ISO Clause:
Top management shall define the organization's environmental policy and ensure that it:
a.	Is appropriate to the nature, scale and environmental impacts of its activities, products and services;
b.	Includes a commitment to continual improvement and prevention of pollution**;
c.	Includes a commitment to comply with relevant environmental legislation and regulations, and with other requirements to which the organization subscribes;
d.	Provides the framework for setting and reviewing environmental objectives and targets;
e.	Is documented, implemented and maintained and communicated to all employees;
f.	Is available to the public.
** GEMS adheres to the pollution prevention hierarchy and EMSs shall be evaluated in terms of the USEPA definition of pollution prevention (see OAR 340-014-0105).			
This Column to be Filled in by Facility	This Column for Verifier Notes	
ELEMENTS: List elements of your EMS that achieve the same purpose as this ISO clause. Reference documentation.	
		
IMPLEMENTATION: Describe the methods that are implemented to achieve the purpose of this clause.	
		
Assessment Codes: C = Comparable or In Conformance;  S = Sufficiently Comparable (Minor non-conformances may exist); N = Not Comparable or Not In Conformance	Verifier Assessment Code:		

4.2 Environmental policy
VERIFICATION GUIDANCE
GEMS PERMIT GUIDELINES
GEMS ACHIEVER (Tier II):  The environmental policy should embody:
	Achieving and maintaining compliance with regulatory requirements 
	Applying the pollution prevention definition and hierarchy when setting goals and targets and implementing environmental impacts
1.	Source Reduction (highest priority)
2.	Recycling
3.	Treatment
4.	Disposal
	Excelling in performance relative to all regulated pollutants and activities. 
	A strong commitment to achieving superior performance relative to all site-based environmental aspects that are determined to have significant impacts, including both regulated and unregulated environmental impacts. 
GEMS LEADER (TIER III):  In addition to the provisions in Tier II, the environmental policy should embody a strong commitment to: 
	Providing environmental leadership for their industry and/or the community
	Addressing life cycle and/or sustainability impacts of their activities, products and services. 
PURPOSE
Statement of management’s intent for the EMS, clarifies values.  Says “How good do we intend to be?”  Sets direction for development of EMS.  Sets expectations of stakeholders.  Guides employees in absence of other explicit direction.
IMPACT OF ABSENCE
•	Purpose and intent of EMS is unclear resulting in an EMS that isn’t aligned with management’s intentions.
•	No evidence of management standing behind environmental policies causes cynicism, both internally and externally.
•	Stakeholders’ expectations not set, causes misunderstandings and mistrust.

4.3.1 Environmental aspects	
Purpose of ISO Clause (in ISO’s Words):  
To identify the elements of an organization's activities, products or services that can interact with the environment.
Clarification of the Purpose:
Base actions and decisions on how to spend limited resources on thorough understanding of environmental impact. Ensures consideration of who are the stakeholders and what do they think is important, and what decisions do we make that have an environmental impact. Also should result in a recognition that activities, products, and services have many environmental impacts beyond those that are regulated.
Methods Specified by the ISO Clause:
The organization shall:
a.	Establish and maintain procedure(s) to identify the environmental aspects of its activities, products and services that it can control and over which it can be expected to have an influence,
b.	Determine those that have or can have significant impacts on the environment.
c.	Ensure that the aspects related to these significant impacts are considered in setting its environmental objectives.
d.	Keep this information up-to-date.			
This Column to be Filled in by Facility	This Column for Verifier Notes	
ELEMENTS: List elements of your EMS that achieve the same purpose as this ISO clause. Reference documentation.	
		
IMPLEMENTATION: Describe the methods that are implemented to achieve the purpose of this clause.	
		
Assessment Codes: C = Comparable or In Conformance;  S = Sufficiently Comparable (Minor non-conformances may exist); N = Not Comparable or Not In Conformance	Verifier Assessment Code:		

4.3.1 Environmental aspects
VERIFICATION GUIDANCE
GEMS PERMIT GUIDELINES
GEMS ACHIEVER (TIER II):  The aspect/impact analysis should include: 
	A thorough examination of regulated and unregulated site-based environmental impacts.
	A determination of which site-based aspects have a significant impact on the environment, taking into consideration local, regional and global environmental conditions.
	A consideration of stakeholder input in identifying and determining the significance of environmental impacts.
	The analysis of aspects should address the operational provisions of the regulation or permit (e.g. training, maintenance, etc.).
	A provision for reexamining this analysis and keeping it up-to-date based on new understandings about environmental conditions or impacts.
GEMS LEADER (TIER III):  In addition to the provisions in Tier II the aspects/impacts analysis would include some of the following elements:
	An examination of all environmental impacts of activities, products and services throughout their life cycle. 
	Some form of life cycle analysis, either quantitative or qualitative, that addresses all life cycle stages including resource extraction, premanufacturing processing and transportation, manufacturing, distribution, packaging, use, and disposal/recycling.
	An analysis of activities, products and services that do or may potentially impact future environmental sustainability
	An examination of the literature on sustainability for definitions and concepts and to identify activities, products and services that are perceived to have sustainability impacts.
	A determination of which life-cycle or sustainability impacts are most significant for the environment, taking into consideration local, regional and global conditions.
	A provision for reexamining this analysis and keeping it up-to-date, including incorporating new scientific and management knowledge about environmental conditions and impacts.
	A requirement that suppliers provide information on environmental performance (optional:  requires adoption of a formal environmental management system).

PURPOSE
Base our actions and decisions on a thorough understanding of environmental impact.  Forces consideration of who are our stakeholders and what do they think is important, and what decisions do we make that have an environmental impact.  Also forces recognition that our activities, products, and services have MANY environmental impacts other than those that are regulated.

IMPACT OF ABSENCE
•	Fixing unimportant or convenient problems while higher impact issues go unaddressed.
•	Too narrow a consideration of environmental issues. 

4.3.2 Legal and other requirements	
Purpose of ISO Clause (in ISO’s Words):  
To identify and have access to legal and other requirements that are applicable to its environmental aspects 
Clarification of Purpose:
Ensures that the EMS recognizes legal responsibilities and is a tool to fulfill them. Ensures that the EMS explicitly recognizes other commitments, such as environmental initiatives of a parent company, (such as Responsible Care).
Methods Specified by the ISO Clause:
The organization shall:
a.	Establish and maintain a procedure to identify legal and other requirements
b.	Establish and maintain a procedure to have access to legal and other requirements			
This Column to be Filled in by Facility	This Column for Verifier Notes	
ELEMENTS: List elements of your EMS that achieve the same purpose as this ISO clause. Reference documentation.	
		
IMPLEMENTATION: Describe the methods that are implemented to achieve the purpose of this clause.	
		
Assessment Codes: C = Comparable or In Conformance;  S = Sufficiently Comparable (Minor non-conformances may exist); N = Not Comparable or Not In Conformance	Verifier Assessment Code:		

4.3.2 Legal and other requirements
VERIFICATION GUIDANCE
GEMS PERMIT GUIDELINES
GEMS ACHIEVER AND GEMS LEADER (ALL TIERS):  In order to adequately assure compliance with legal and other requirements, check that GEMS Achiever and GEMS Leader facilities have:
	A procedure to identify all applicable federal, state and local legal requirements, including all permit conditions, and to keep the information updated.
	A record of any other requirements that the facility, or the parent company, have committed to that apply to the facility, including voluntary industry codes of practice, contracts, customer commitments, or internal requirements.
	A record of GEMS Permit guidelines and requirements that the facility, or the parent company, have committed to that apply to the facility.
	Accessibility to the terms and conditions of these legal and other requirements.
	A process for keeping this information up to date including periodic review, update and communication as appropriate.

PURPOSE
Ensure that the EMS recognizes legal responsibilities and is a tool to fulfill them.  Also ensures that the EMS explicitly recognizes other commitments, such as environmental initiatives of a parent company.

IMPACT OF ABSENCE
•	An EMS that does not help a company maintain compliance.
•	Schism between the EMS and the REALLY important stuff.
•	Poor compliance.

4.3.3 Objectives and targets	
Purpose of ISO Clause (in ISO’s Words):  
To set an overall environmental goal for the organization to achieve
To set a detailed performance requirement that needs to be met in order to achieve the objectives.
Clarification of Purpose 
Focuses activities on consistent performance goals. Grounds activities in a basis of fact. Distills all the above into “what are we going to do?” Sets up Environmental Performance Evaluation. Ensures that views of interested parties and business realities are considered.
Methods Specified by the ISO Clause:
The organization shall:
a.	Establish and maintain documented environmental objectives and targets at each relevant function and level within the organization
b.	Consider the legal and other requirements
c.	Consider its significant environmental impacts
d.	Consider its technological options and financial, operational and business requirements
e.	Consider the views of interested parties
f.	Establish objectives and targets consistent with environmental policy, including commitment to pollution prevention.			
This Column to be Filled in by Facility	This Column for Verifier Notes	
ELEMENTS: List elements of your EMS that achieve the same purpose as this ISO clause. Reference documentation.	
		
IMPLEMENTATION: Describe the methods that are implemented to achieve the purpose of this clause.	
		
Assessment Codes: C = Comparable or In Conformance;  S = Sufficiently Comparable (Minor non-conformances may exist); N = Not Comparable or Not In Conformance	Verifier Assessment Code:		

4.3.3 Objectives and targets
VERIFICATION GUIDANCE
GEMS PERMIT EMS GUIDELINES
ALLGEMS PERMITS:  The following elements are required for both GEMS Achiever and GEMS Leader facilities:
	A procedure for establishing Objectives and Targets for the different functions and levels of the organization.
	Documentation of the objectives and targets.
	Objectives and targets that are consistent with the environmental policy.
	Objectives and targets that have considered the views of interested parties.
	Objectives that address:
 Significant environmental aspects	 Legal and other requirements	
 Technological, financial, operational and business requirements	 Targets that are quantified where possible	
	Targets that provide detailed performance requirements to achieve the objectives.
	A procedure to update the Objectives and Targets based on audits and management review.
TIER II:	GEMS Achiever Permit facilities should define:
	Objectives and targets that, if achieved, will assure that the facility achieves superior environmental performance for site-based aspects that have significant impacts, including both regulated and unregulated impacts. For example:
 Energy conservation	 Water conservation	 Material use conservation	
 Toxic use reduction	 Carbon emissions	 Hazardous waste reduction	
 Solid waste reduction	 Reuse & recycling	 Employee commuting	
 Land use	 Habitat conservation	 Landscape management	
									
TIER III:	GEMS Leader Permit facilities should define:
	Objectives and targets that, if achieved, will assure that the facility provides industry leadership in applying sustainability principles to activities, products and services. 
 Life cycle assessment	 Supply chain management	 Product life extension	
 Design for environment	 End of life product mgmt.	 Environmental labeling	
 Industry mentoring	 Industry codes & BMP	 Habitat restoration	
									
PURPOSE
Focuses activities on consistent performance goals. Grounds activities in a basis of fact. Distills all the above into “what are we going to do?” Ensures that views of interested parties are considered.
IMPACT OF ABSENCE
•	EMS degenerates into series of anecdotes about “wins”.
•	No long-term focus on improving performance.
•	No way to show improved performance.

4.3.4 Environmental management program(s)	
Purpose of ISO Clause (in ISO’s Words):  
To achieve the organization’s objectives and targets
Clarification of Purpose:
Translates an understanding about the facility (where we are, what is expected, and where we want to be) into action plans – “How are we going to get there?” Should result in consideration of who has what role in improving performance and what resources are needed.
Methods Specified by the ISO Clause:
The organization shall:
a.	Establish and maintain program(s) for achieving objectives and targets
b.	Include designation of responsibility for achieving objectives and targets
c.	Include means and time-frame by which they are to be achieved
d.	For new developments and new or modified activities, products or services, the program(s) shall be amended where relevant			
This Column to be Filled in by Facility	This Column for Verifier Notes	
ELEMENTS: List elements of your EMS that achieve the same purpose as this ISO clause. Reference documentation.	
		
IMPLEMENTATION: Describe the methods that are implemented to achieve the purpose of this clause.	
		
Assessment Codes: C = Comparable or In Conformance;  S = Sufficiently Comparable (Minor non-conformances may exist); N = Not Comparable or Not In Conformance	Verifier Assessment Code:		

4.3.4 Environmental management program(s)
VERIFICATION GUIDANCE
GEMS PERMIT EMS GUIDELINES
ALLGEMS PERMITS:  The following elements should be present for both GEMS Achiever and GEMS Leader facilities:
	Programs that are consistent with the objectives and targets and the facility’s GEMS Permit.
	Assignment of responsibility for achieving objectives and targets at each function and level of the facility.
	A means for achieving the objectives and targets, including methods and resources.
	A designated time frame.
	A procedure for modifying the program based on:
	Audits of progress toward targets.
	New developments or new or modified activities, products or services.
	A procedure for monitoring progress toward the objectives and targets
	Pollution prevention initiatives as a preference to pollution control activities.

PURPOSE
Translates an understanding about where we are, what is expected of us, and where we want to be into actionable plans – “How are we going to get there?”.  Forces consideration of who has what role in improving performance and what resources are needed.

IMPACT OF ABSENCE
•	Unattainable goals set for PR value.
•	No accountability for achieving goals.
•	Goals established but no real way to achieve them.
•	Insufficient resources to achieve goals.

4.4.1 Structure and responsibility	
Purpose of ISO Clause (in ISO’s Words):
To facilitate effective environmental management through assignment of roles, responsibilities and provision of resources.
Clarification of Purpose:
Makes it clear who is responsible for what, and that adequate resources will be provided.
Methods Specified by the ISO Clause:
The organization shall:
a.	Define roles, responsibilities and authorities and document and communicate to the organization’s employees
b.	Management shall provide resources essential to the implementation and control of the EMS, including human resources, specialized skills, technology, and finances
c.	Top management shall appoint a specific management representative who assures that the EMS is established, implemented and maintained and reports to top management on performance of EMS and needed improvements.			
This Column to be Filled in by Facility	This Column for Verifier Notes	
ELEMENTS: List elements of your EMS that achieve the same purpose as this ISO clause. Reference documentation.	
		
IMPLEMENTATION: Describe the methods that are implemented to achieve the purpose of this clause.	
		
Assessment Codes: C = Comparable or In Conformance;  S = Sufficiently Comparable (Minor non-conformances may exist); N = Not Comparable or Not In Conformance	Verifier Assessment Code:		

4.4.1 Structure and responsibility
VERIFICATION GUIDANCE
GEMS PERMIT EMS GUIDELINES
ALL GEMS PERMITS:  The following elements should be present for both GEMS Achiever and GEMS Leader facilities:
	Clearly defined roles, responsibilities, and authorities.
	Roles, responsibilities, and authorities have been communicated throughout the organization.
	Human, financial and technological resources essential to the implementation and control of the EMS have been provided.
	A management representative has been appointed who is responsible for implementation and maintenance of the EMS.
	A management representative has been appointed who is responsible for reporting to top management.

PURPOSE
Makes it clear who is responsible for what, and that adequate resources are available.

IMPACT OF ABSENCE
•	No accountability for EMS activities.
•	The Environmental Professional is responsible for anything that has anything to do with the environment but has no true authority or resources.  They carry a big club called “fines and jail” but other than invoking that club they are ignored.

4.4.2 Training, awareness and competence	
Purpose of ISO Clause (in ISO’s Words):  
To ensure the capability of personnel, especially those carrying out specialized environmental management functions.
Clarification of Purpose:
Ensure that people have the necessary training and background to fill their roles in the EMS successfully, whether they are the President, an Environmental Professional, a Production Worker, or a Janitor.
Methods Specified by the ISO Clause:
The organization shall:
a.	Identify training needs
b.	Require that all personnel whose work may create a significant impact upon the environment to receive appropriate training
c.	Establish and maintain procedures to make its employees or members at each relevant function and level aware of:
– the importance of conformance with policy and procedures and requirements of the EMS
– the significance of environmental impacts of their work activities and benefits of improved personal performance
– their roles and responsibilities in the EMS
– the potential consequences of departure from specified operating procedures
d.	Personnel performing tasks that can cause significant impacts shall be competent on the basis of education, training and/or experience			
This Column to be Filled in by Facility	This Column for Verifier Notes	
ELEMENTS: List elements of your EMS that achieve the same purpose as this ISO clause. Reference documentation.	
		
IMPLEMENTATION: Describe the methods that are implemented to achieve the purpose of this clause.	
		
Assessment Codes: C = Comparable or In Conformance;  S = Sufficiently Comparable (Minor non-conformances may exist); N = Not Comparable or Not In Conformance	Verifier Assessment Code:		

4.4.2 Training, awareness and competence
VERIFICATION GUIDANCE
GEMS PERMIT EMS GUIDELINES
ALL GEMS PERMITS:  The following elements should be present for both GEMS Achiever and GEMS Leader facilities:
	A determination of what job function may have a significant environmental impact.
	An identification and evaluation of training needs for all employees whose job functions may have a significant environmental impact, and delivery of appropriate training.
	An identification and evaluation of training needs for all contractors whose duties may have a significant environmental impact, and delivery of appropriate training.
	General awareness training for all employees and managers that addresses the environmental policy and the organizations environmental impacts.
	Training and awareness activities for all employees that address the types of environmental impacts appropriate to the facility’s Tier.
	Periodic refresher training.
	A method of determining that employees have the appropriate education, training and experience to perform tasks for which they are responsible which can cause significant environmental impact.

PURPOSE
Ensure that people have the necessary training and background to fill their roles in the EMS successfully, whether they are the President, the Environmental Professional, a Production Worker, or the Janitor.

IMPACT OF ABSENCE
•	Unqualified people.  Leads to poor execution and potentially to environmental emergencies.
•	Repeated dissatisfaction about people’s performance.  No one succeeds.  Assumption becomes that the people are dumb, or lazy, or don’t care.

4.4.3 Communication	
Purpose of ISO Clause (in ISO’s Words):  
To ensure effective internal and external communication regarding its environmental aspects and EMS
Clarification of Purpose:
Ensures broad internal communications, and that communications from external stakeholders are recognized and responded to. Also ensures that an explicit, consistent policy regarding external communications is followed.
Methods Specified by the ISO Clause:
Organization shall establish and maintain procedures for:
a.	Internal communication between the various levels and functions of the organization
b.	Receiving, documenting and responding to relevant communication from external interested parties
c.	Consider processes for external communication on significant environmental aspects and record decisions.			
This Column to be Filled in by Facility	This Column for Verifier Notes	
ELEMENTS: List elements of your EMS that achieve the same purpose as this ISO clause. Reference documentation.	
		
IMPLEMENTATION: Describe the methods that are implemented to achieve the purpose of this clause.	
		
Assessment Codes: C = Comparable or In Conformance;  S = Sufficiently Comparable (Minor non-conformances may exist); N = Not Comparable or Not In Conformance	Verifier Assessment Code:		

4.4.3 Communication
VERIFICATION GUIDANCE
GEMS PERMIT EMS GUIDELINES
ALL GEMS PERMITS:  The following elements should be present for both GEMS Achiever and GEMS Leader Permit facilities:
Internal Communication:
	A procedure for internal communications between various functions and levels of the organization related to the EMS and environmental aspects.
	An assignment of responsibility for reviewing, updating and overseeing implementation of the internal communication procedure.
	Examples of communications that have occurred between functions and levels of the organization.
External Communication:
	A procedure for providing two-way dialogue regarding environmental performance that proactively encourages public inquiries and comments.
	Mechanisms to discuss environmental policy, annual performance report, environmental aspects and significant impacts, and establishing objectives and targets with stakeholders.
	A mechanism for receiving, documenting, considering and responding to communications received from stakeholders.
	Examples of external communications that have been received, documented, considered and responded to.
GEMS LEADER PERMITS:  The external communication program for a GEMS Leader Permit facility should, in addition to the above, include:
	A procedure to communicate with appropriate stakeholders regarding impacts that may occur beyond the site, e.g. life cycle impacts of products or services.
	Procedures to establish and maintain understanding, constructive dialogue and partnership with significant stakeholders.
Reporting:
	A procedure for reporting environmental performance annually to DEQ in satisfaction of GEMS reporting guidelines.
	(OPTIONAL BUT RECOMMENDED) A procedure to prepare an annual Environmental Performance Report for distribution to stakeholders.

PURPOSE
Ensure free internal communications, and that communications from external stakeholders are recognized and responded to.  Also ensures that an explicit, consistent policy regarding external communications is followed.

IMPACT OF ABSENCE
•	Poor internal communication.  Right hand doesn’t know what left is doing.  People don’t know who to ask if they have questions or concerns.
•	Frustrated stakeholders because their attempts at communication are not dealt with effectively.
•	Views of interested parties not considered when setting O&T.  (Note that 4.3.3 says that views of interested parties must be considered when setting O&T.  It is difficult to consider this input if we don’t know we have any.)

4.4.4 Environmental management system documentation	
Purpose of ISO Clause (in ISO’s Words):  
To describe the core elements of the EMS and their interaction
To provide direction on where to obtain more detailed information on the operation of specific parts of the EMS
Clarification of Purpose:
Makes the EMS intelligible. Creates an EMS that is durable and robust: survives personnel changes, rapid growth, downsizing, time, etc. Provides objective basis for audit. Should result in agreement on how the EMS works. Ensures accountability. Creates the mechanism for capturing lessons learned – a way to hold the gains. Ensures analysis of process and an understanding that many processes and people have a role in the EMS.
Methods Specified by the ISO Clause:
Organization shall establish and maintain information in paper and electronic form to:
a.	Describe the core elements of the EMS and their interaction
b.	Provide direction to related documentation.			
This Column to be Filled in by Facility	This Column for Verifier Notes	
ELEMENTS: List elements of your EMS that achieve the same purpose as this ISO clause. Reference documentation.	
		
IMPLEMENTATION: Describe the methods that are implemented to achieve the purpose of this clause.	
		
Assessment Codes: C = Comparable or In Conformance;  S = Sufficiently Comparable (Minor non-conformances may exist); N = Not Comparable or Not In Conformance	Verifier Assessment Code:		

4.4.4 Environmental management system documentation
VERIFICATION GUIDANCE
GEMS PERMIT EMS GUIDELINES
ALL GEMS PERMITS:  The following elements should be present for both GEMS Achiever and GEMS Leader facilities:
	Written or electronic information that covers all clauses of the standard:
	Describing the requirements of the management system and their interaction
	Cross-referencing related documents
PURPOSE
Makes the EMS intelligible. Creates an EMS that is durable and robust: survives personnel changes, rapid growth, downsizing, time, etc.  Provides objective basis for audit.  Forces explicit agreement on how the EMS works.  Ensures accountability.  Creates the mechanism for capturing lessons learned – a way to hold the gains.  Forces analysis of process and an understanding that many processes and people have a role in the EMS.

IMPACT OF ABSENCE
•	Constantly re-inventing the wheel.
•	Poor accountability.  “I thought that was YOUR job!”, or “I thought we did that every OTHER month!”
•	Figuring out a better way to do things but there’s no real way to implement the change.  Everyone goes back to the old ways.
•	Audits degenerate into “I don’t think you’re doing it right!”, or “I don’t like the way you do it!”.

4.4.5 Document control	
Purpose of ISO Clause (in ISO’s Words):  
To control documents required by the EMS.
Clarification of Purpose:
Creates a mechanism to change processes, ensures that everyone who needs to know does know, and provides a way to “hold the gains”. Eliminates confusion about what is the current right way to do things. Provides a way for the appropriate people to control the process so that practice and results don’t change spuriously.
Methods Specified by the ISO Clause:
Organization shall establish and maintain procedures for controlling all documents required by the Standard, to ensure that:
a.	All documents can be located
b.	All documents are periodically reviewed, revised as necessary and approved for adequacy by authorized personnel
c.	The current versions of relevant documents are available at all locations where operations essential to the effective functioning of the EMS are performed
d.	Obsolete documents are promptly removed from all points of issue and points of use, or otherwise assured against unintended use
e.	Any obsolete documents retained for legal and/or knowledge preservation purposes are suitably identified.
Documentation shall be legible, dated (with dates of revision) and readily identifiable, maintained in an orderly manner and retained for a specified period.
Procedures and responsibilities shall be established and maintained concerning the creation and modification of the various types of document. 			
This Column to be Filled in by Facility	This Column for Verifier Notes	
ELEMENTS: List elements of your EMS that achieve the same purpose as this ISO clause. Reference documentation.	
		
IMPLEMENTATION: Describe the methods that are implemented to achieve the purpose of this clause.	
		
Assessment Codes: C = Comparable or In Conformance;  S = Sufficiently Comparable (Minor non-conformances may exist); N = Not Comparable or Not In Conformance	Verifier Assessment Code:		

4.4.5 Document control
VERIFICATION GUIDANCE
GEMS PERMIT EMS GUIDELINES
ALL GEMS PERMITS:  The following elements should be present for both GEMS Achiever and GEMS Leader facilities:
	A document control procedure, such that documents:
	Can be located
	Are periodically reviewed, revised and approved
	Have current versions available at essential locations, with no obsolete versions.
	EMS documents that are managed according to the procedures and are legible, identified, and dated.
	Obsolete version are retained for reference and are suitably identified.
	An assignment of responsibility for the creation and modification of documents.

PURPOSE
Creates a mechanism to change processes, ensures that everyone who needs to know does know, and provides a way to “hold the gains”.  Eliminates confusion about what is the current right way to do things.  Provides a way for the appropriate people to control process so that practice, and therefor results, don’t change spuriously.

IMPACT OF ABSENCE
•	Confusion about “Do we STILL do it this way?  I thought we changed it last week!”, or “I have two procedures and don’t know which one is right”, or “This note on the wall has been changed 6 times.  What the heck am I supposed to follow?”
•	Documents become “dead”.

4.4.6 Operational control	
Purpose of ISO Clause (in ISO’s Words):  
To ensure that operations, activities, and goods and services used by the organization that are associated with the identified significant environmental aspects are controlled so that they:
a.	Are carried out under specified conditions, and 
b.	Do not lead to deviations from the environmental policy and the objectives and targets.
Clarification of Purpose:
Provides operational consistency. Ensures that the “hands-on” processes that directly control environmental impacts and the achievement of environmental goals are appropriately controlled. Also ensures that the facility recognizes its position of authority in controlling “subcontractors” and exercise appropriate controls with them.
Methods Specified by the ISO Clause:
Organization shall identify those operations and activities that are associated with the identified significant environmental aspects in line with its policy, objectives and targets.
Organization shall plan these activities, including maintenance, in order to ensure that they are carried out under specified conditions.
Organization shall: 
a.	Establish and maintain documented procedures to cover situations where absence could lead to deviations from the environmental policy and objectives and targets.
b.	Stipulate operating criteria in the procedures
c.	Establish and maintain procedures related to the identifiable significant environmental aspects of goods and services used by the organization and communicate relevant procedures and requirements to suppliers and contractors.			
This Column to be Filled in by Facility	This Column for Verifier Notes	
ELEMENTS: List elements of your EMS that achieve the same purpose as this ISO clause. Reference documentation.	
		
IMPLEMENTATION: Describe the methods that are implemented to achieve the purpose of this clause.	
		
Assessment Codes: C = Comparable or In Conformance;  S = Sufficiently Comparable (Minor non-conformances may exist); N = Not Comparable or Not In Conformance	Verifier Assessment Code:		

4.4.6 Operational control
VERIFICATION GUIDANCE
GEMS PERMIT EMS GUIDELINES
ALL GEMS PERMITS:  The following elements should be present for both GEMS Achiever and GEMS Leader facilities:
	An identification of those operations and activities that are associated with its identified significant environmental aspects.
	Documented procedures that stipulate operating criteria and controls for identified operations in consideration of the need to prevent deviations from the environmental policy, objectives and targets.
	Procedures related to significant environmental aspects of goods and services it uses

GEMS LEADER PERMITS:	
	Procedures to communicate procedures and requirements related to significant environmental aspects to relevant suppliers and contractors.
	Examples of communications with suppliers and contractors.

PURPOSE
Provides operational consistency.  Ensures that the “hands-on” processes that directly control environmental impacts and the achievement of environmental goals are appropriately controlled.  Also ensures that we recognize our position of authority in controlling “subcontractors” and exercise appropriate controls with them.

IMPACT OF ABSENCE
•	See 4.4.5, above, but applied to working details rather than macro EMS processes.  An unstable system.
•	Differences in performance operator to operator, shift to shift, month to month.
•	Inability to reliably meet performance goals because the processes and operations that impact performance are not identified and controlled.
•	Changes in performance due to uncontrolled changes of materials or of supplier performance.

4.4.7 Emergency preparedness and response	
Purpose of ISO Clause (in ISO’s Words):  
To identify potential for and respond to accidents and emergency situations.
To prevent and mitigate the environmental impacts that may be associated with them.
Clarification of Purpose:
Ensure that the operation is prepared for reasonably foreseeable emergencies, can prevent them wherever possible, can deal with these situations effectively, and mitigate the effects.
Methods Specified by the ISO Clause:
Organization shall:
a.	Establish and maintain procedures to identify potential for and respond to accidents and emergency situations.
b.	Establish and maintain procedures for preventing and mitigating the environmental impacts that may be associated.
c.	Review and revise, where necessary, its emergency preparedness and response procedures, in particular, after the occurrence of accidents or emergency situations.
d.	Periodically test such procedures where practicable.			
This Column to be Filled in by Facility	This Column for Verifier Notes	
ELEMENTS: List elements of your EMS that achieve the same purpose as this ISO clause. Reference documentation.	
		
IMPLEMENTATION: Describe the methods that are implemented to achieve the purpose of this clause.	
		
Assessment Codes: C = Comparable or In Conformance;  S = Sufficiently Comparable (Minor non-conformances may exist); N = Not Comparable or Not In Conformance	Verifier Assessment Code:		

4.4.7 Emergency preparedness and response
VERIFICATION GUIDANCE
GEMS PERMIT EMS GUIDELINES
ALL GEMS PERMITS:  The following elements should be present for both GEMS Achiever and GEMS Leader Permit facilities:
	A defined set of responsibilities, a management structure and a plan for emergency response to accidents and emergencies.
	Procedures to identify potential accidents and emergency situations.
	Procedures to respond to accidents and emergency situations.
	Procedures that address prevention and mitigation of environmental impacts associated with accidents and emergencies.
	A training program that includes specific provisions for skills in emergency preparedness for appropriate individuals.
	Procedures for periodic review and revision of emergency preparedness.
	If any accidents or emergencies have occurred, a review of procedures following the occurrence.
	Periodic drills or exercises to test the implementation of the procedures.

PURPOSE
Ensure that the operation is prepared for reasonably foreseeable emergencies, can deal with these situations effectively.

IMPACT OF ABSENCE
•	Events that could or should be minor turn into major emergencies.

4.5.1 Monitoring and measurement	
Purpose of ISO Clause (in ISO’s Words):  
To monitor and measure the key characteristics of operations and activities that can have a significant impact on the environment.
To track performance, relevant operational controls and conformance with the organization’s environmental objectives and targets.
To periodically evaluate compliance with relevant environmental legislation and regulations.
Clarification of Purpose:
Ensures that performance measurement is based on sound metrics and that metrology processes are reliable and sound. Requires that commitments to stakeholders (such as permit conditions) are taken seriously and that the organization takes primary responsibility in monitoring their performance to meet the agreed conditions, rather than waiting for stakeholders to call. Also ensures that goals are real because the facility must establish consistent ways to demonstrate that it is meeting them or not.
Methods Specified by the ISO Clause:
Organization shall:
a.	Establish and maintain documented procedures to monitor and measure, on a regular basis, the key characteristics of its operations and activities that can have a significant impact on the environment.
b.	Track performance, relevant operational controls and conformance with the organization’s environmental objectives and targets
c.	Calibrate and maintain monitoring equipment, and retain records of this process according to the organization’s procedures
Establish and maintain a documented procedure for periodically evaluating compliance with relevant environmental legislation and regulations. 			
This Column to be Filled in by Facility	This Column for Verifier Notes	
ELEMENTS: List elements of your EMS that achieve the same purpose as this ISO clause. Reference documentation.	
		
IMPLEMENTATION: Describe the methods that are implemented to achieve the purpose of this clause.	
		
Assessment Codes: C = Comparable or In Conformance;  S = Sufficiently Comparable (Minor non-conformances may exist); N = Not Comparable or Not In Conformance	Verifier Assessment Code:		

4.5.1 Monitoring and measurement
VERIFICATION GUIDANCE
GEMS PERMIT EMS GUIDELINES
ALL GEMS PERMITS:  The following elements should be present for both GEMS Achiever and GEMS Leader Permit facilities:
	Documented procedures to monitor and measure on a regular basis key characteristics of operations and activities that can have a significant impact on the environment.
	Monitoring and measurement records that track performance, operational controls and conformance with the organization’s objectives and targets.
	Performance measures that provide a clear and quantified measure of environmental performance in context with past performance.
	(OPTIONAL, BUT RECOMMENDED) Performance measures that provide a clear and quantified measure of environmental performance in context with similar facilities within the industry sector.
	Monitoring and measurement records that track operational controls 
	Requirements and procedures to calibrate and maintain equipment designed to monitor and measure the key characteristics of its operations and activities that can have a significant impact on the environment.
	Records of this process.
	Documented procedures for periodically evaluating compliance with laws and regulations.
	Evidence of the evaluation of compliance.

PURPOSE
Ensures that performance measurement is based on sound metrics and that metrology processes are reliable and sound.  Requires that commitments to stakeholders (like permit conditions) are taken seriously and that the organization takes primary responsibility in monitoring their performance to meet the agreed conditions, rather than waiting for downstream neighbors to call.  Also ensures that goals are real because we must establish consistent ways to demonstrate that we are meeting them or not.

IMPACT OF ABSENCE
•	EMS is disconnected from reality.
•	“Seems to me that we got a lot better at recycling this year.  Gee, must be maybe a 50% increase?  Maybe even 60%!”
•	 “It’s OK if that thermometer goes a little over the limit because it always reads a few degrees high.”
•	“I use my finger to measure temperature of process waste water.”
•	“We know when we exceed BOD limits because the guy next door complains.”

4.5.2 Nonconformance and corrective and preventive action	
Purpose of ISO Clause (in ISO’s Words):  
To handle and investigate nonconformance
To mitigate any impacts caused 
To initiate and complete corrective and preventive action.
Clarification of Purpose:
To ensure that appropriate resources are applied to restore the EMS to a state of conformance, especially when a problem is recurring or resists standard methods. Corrective action fixes the problem while preventive action prevents it from recurring. Ensures that “fixed” problems stay fixed. Preventive action creates an EMS that is proactive rather than reactive.
Methods Specified by the ISO Clause:
Organization shall:
a.	Establish and maintain procedures for defining responsibility and authority for handling and investigating nonconformance, taking action to mitigate any impacts caused and for initiating and completing corrective and preventive action
b.	Implement and record any changes in the documented procedures resulting from corrective and preventive action.
Corrective and preventive action shall be appropriate to the magnitude of problems and commensurate with the environmental impact encountered.			
This Column to be Filled in by Facility	This Column for Verifier Notes	
ELEMENTS: List elements of your EMS that achieve the same purpose as this ISO clause. Reference documentation.	
		
IMPLEMENTATION: Describe the methods that are implemented to achieve the purpose of this clause.	
		
Assessment Codes: C = Comparable or In Conformance;  S = Sufficiently Comparable (Minor non-conformances may exist); N = Not Comparable or Not In Conformance	Verifier Assessment Code:		

4.5.2 Nonconformance and corrective and preventive action
VERIFICATION GUIDANCE
GEMS PERMIT EMS GUIDELINES
ALL GEMS PERMITS:  The following elements should be present for both GEMS Achiever and GEMS Leader Permit facilities:
	Procedures and designation of responsibility for investigating and handling non-conformance from the EMS, including identification of the cause.
	Procedures for corrective and preventive action.
	A process to evaluate the environmental impact of a non-conformance and assess the appropriateness of the corrective and preventive actions.

PURPOSE
To ensure that appropriate resources are applied to restore the EMS to a state of conformance, especially when a problem is recurring or resists standard methods.  Causes “fixed” problems to stay fixed. Preventive action creates an EMS that is proactive rather than constantly reactive.

IMPACT OF ABSENCE
•	Repeated performance problems or recurring compliance violations.
•	Problems that are hard to fix don’t get fixed.
•	An audit program with ineffective corrective action falls apart very quickly because of cynicism.

4.5.3 Records	
Purpose of ISO Clause (in ISO’s Words):  
To demonstrate conformance to ISO 14001.
To support implementation and operation of the EMS.
To record the extent to which planned objectives and targets have been met.
Clarification of Purpose:
The EMS’s memory. It allows the EMS to learn from the past. Proof that things happened as planned, or didn’t. Fulfills certain regulatory requirements. Provides evidence for audits.
Methods Specified by the ISO Clause:
Organization shall establish and maintain procedures for identification, maintenance and disposition of environmental records, including records of training and audits and reviews.
Records shall be legible, identifiable and traceable to the activity, product or service involved.
Records shall be stored and maintained in such a way that they are readily retrievable and protected against damage, deterioration or loss.
Their retention time shall be established and recorded.
Records shall be maintained to demonstrate conformance to the requirements of the standard.			
This Column to be Filled in by Facility	This Column for Verifier Notes	
ELEMENTS: List elements of your EMS that achieve the same purpose as this ISO clause. Reference documentation.	
		
IMPLEMENTATION: Describe the methods that are implemented to achieve the purpose of this clause.	
		
Assessment Codes: C = Comparable or In Conformance;  S = Sufficiently Comparable (Minor non-conformances may exist); N = Not Comparable or Not In Conformance	Verifier Assessment Code:		

4.5.3 Records
VERIFICATION GUIDANCE
GEMS PERMIT EMS GUIDELINES
ALL GEMS PERMITS:	The following elements should be present for both GEMS Achiever and GEMS Leader Permit facilities:
	Procedures to identify, maintain and dispose of environmental records.
	Legible and identifiable records for training, audits results and management reviews.
	Mechanisms for record storage and retrieval.

PURPOSE
The EMS’s memory – allows EMS to learn from the past.  Proof that things happened as planned, or didn’t.  Fulfills certain regulatory requirements.  Provides evidence for audits.

IMPACT OF ABSENCE
•	Inability to quickly locate records required by law, such as training records or waste manifests.  
•	“I don’t remember if I closed that valve last week or not.”
•	“Who approved this shipment?”
•	“How often do we really check the toxics vault?”
•	“How much IPA have we bought this year?”
•	“Have we told the supplier that we need low sulfur diesel fuel or not?”

4.5.4 Environmental management system audit	
Purpose of ISO Clause (in ISO’s Words):  
To ensure that periodic environmental management system audits are carried out.
Clarification of Purpose:
Demonstrates management’s commitment to have an EMS with integrity. Ensures congruence between documented procedure and actual practice. It is the main feedback mechanism to assure management and third party stakeholders that things are actually happening as planned. Helps EMS improve through constant and repeated review.
Methods Specified by the ISO Clause:
Organization shall establish and maintain procedures for periodic EMS audits to be carried out.
1.	To determine if the EMS conforms to planned arrangements for environmental management, including ISO requirements 
2.	To determine whether it has been properly implemented and maintained
3.	To provide information on the results of audits to management.
Audit program and schedule shall be based on the environmental importance of the activity concerned and the results of previous audits.
Audit procedures shall be comprehensive and cover the audit scope, frequency and methodologies, as well as the responsibilities and requirements for conducting audits and reporting results.			
This Column to be Filled in by Facility	This Column for Verifier Notes	
ELEMENTS: List elements of your EMS that achieve the same purpose as this ISO clause. Reference documentation.	
		
IMPLEMENTATION: Describe the methods that are implemented to achieve the purpose of this clause.	
		
Assessment Codes: C = Comparable or In Conformance;  S = Sufficiently Comparable (Minor non-conformances may exist); N = Not Comparable or Not In Conformance	Verifier Assessment Code:		

4.5.4 Environmental management system audit
VERIFICATION GUIDANCE
GEMS PERMIT EMS GUIDELINES
ALL GEMS PERMITS:  The following elements should be present for both GEMS Achiever and GEMS Leader Permit facilities:
	A program and procedure for periodic EMS auditing.
	Audit procedures that cover:
	Audit scope		Frequency and schedule
	Methodologies		Responsibilities for conducting and reporting results
	Audits of a scope sufficient to measure conformance with the requirements of the EMS.
	Provision of information to management regarding results of the audit.
	Audit procedures that are appropriate to the environmental importance of the activity.
SURVEILLANCE AUDIT GUIDELINES
An ISO 14001 registered facility is expected to receive an external surveillance audit on generally an annual basis by their registrar. The ISO Guidelines (ISO/IEC Guide 62, 1996) read: “The certification/registration body shall carry our periodic surveillance and reassessment at sufficiently close intervals to verify that its organizations whose EMS are certified/registered continue to comply with the certification/registration requirements. Note: In most cases it is unlikely that a period greater than one year for periodic surveillance would satisfy the requirements of this clause.”
Surveillance audits should have an “external” element by one of the following:
1.	Be performed by a qualified auditor who is independent from the company, and holds no conflict of interest relative to the company
2.	Be performed by a qualified auditor who may be from within the company, but is independent of the organizational unit which is covered by the EMS
3.	Be performed by an internal auditor, but such that audit reports and findings are provided to DEQ for review, who may at their option perform on-site verification.
The following surveillance procedures should be present for both GEMS Achiever and GEMS Leader facilities:
	A program for periodic surveillance audits that meets the above guidelines.
	Procedures for providing information to DEQ in the annual report regarding results of the audit(s) and associated corrective actions.

PURPOSE
Demonstrates management’s commitment to have an EMS with integrity - “We insist on congruence between documented procedure and actual practice.”  The main feedback mechanism to assure management that things are actually happening as planned.  Helps EMS improve through constant and repeated review.

IMPACT OF ABSENCE
•	Documented “EMS” that is not implemented in practice.
•	Practice that diverges from documented procedure over time.
•	Cynicism because of knowledge that the documents are only for show.
•	Documented procedure that reflects “best practice” but actual practice that doesn’t.

4.6 Management review	
Purpose of ISO Clause (in ISO’s Words):  
To ensure the EMSs continuing suitability, adequacy and effectiveness.
To ensure that the necessary information is collected to allow management to carry out this evaluation.
Clarification of Purpose:
Adjusts the EMS based on changes in business conditions, what works and what doesn’t, internal audit findings, etc. Also is usually the mechanism for focusing management attention on environmental performance metrics and progress on environmental programs.
Methods Specified by the ISO Clause:
Organization’s top management shall, at intervals that it determines, review the EMS to ensure the EMSs continuing suitability, adequacy and effectiveness.
The management review shall ensure that the necessary information is collected to allow management to carry out this evaluation.
The review shall be documented.
The review shall address the possible need for changes to policy, objectives and other elements of the EMS, in light of EMS audit results, changing circumstances and the commitment to continual improvement.			
This Column to be Filled in by Facility	This Column for Verifier Notes	
ELEMENTS: List elements of your EMS that achieve the same purpose as this ISO clause. Reference documentation.	
		
IMPLEMENTATION: Describe the methods that are implemented to achieve the purpose of this clause.	
		
Assessment Codes: C = Comparable or In Conformance;  S = Sufficiently Comparable (Minor non-conformances may exist); N = Not Comparable or Not In Conformance	Verifier Assessment Code:		

4.6 Management review
VERIFICATION GUIDANCE
GEMS PERMIT EMS GUIDELINES
ALL GEMS PERMITS:  The following elements should be present for both GEMS Achiever and GEMS Leader Permit facilities:
	A documented management review process that involved top management.
	Designated intervals for management review.
	Documentation of reviews that have occurred.
	Evidence that changes to policy, objectives and other EMS elements were addressed in light of audit results and/or changing circumstances.

PURPOSE
Adjusts the EMS based on changes in business conditions, what works and what doesn’t, internal audit findings, etc.  Also is usually the mechanism for focusing management attention on environmental performance metrics and progress on environmental programs.

IMPACT OF ABSENCE
•	An EMS that is disconnected from senior management and from the realities of the business.
•	Lack of accountability for achieving goals and completing corrective actions.