Proposed EMS program would bring benefits

John Young, director of the Division of Environmental Quality at the Missouri Department of Natural Resources, June 21 presented to MDNR Director Steve Mahfood recommendations for a state environmental management system (EMS) program.

This innovative program the Missouri Partnership for Superior Environmental Performance would use permitting and public relations incentives to encourage facilities to voluntarily implement qualifying EMSes.

An EMS is an organized, voluntary and coordinated process of planning activities, responsibilities, procedures and resources for developing, implementing and maintaining an environmental program. The goal of the proposed state EMS program is to encourage a broad group of Missouri industries to implement EMSes.

Missouri's EMS program recommendations were developed by an advisory group which was established by the Division of Environmental Quality as a result of focus group discussions in 1998.

The proposal developed by Missouri's EMS advisory group includes three components: a basic EMS, certification by a third party and environmental performance above and beyond compliance.

These components may be implemented through two pathways incorporated into four categories of participation: Achiever, Achiever Plus, Certified Achiever and Certified Achiever Plus. Each category presents specific criteria for participation, as well as corresponding incentive benefits.

Participation as an Achiever requires the implementation of a basic EMS, which includes a policy statement, environmental impacts, legal requirements, roles and responsibilities, objectives and targets, record keeping and reporting, training, emergency response, assessment and corrective action.

The Achiever level is based on self-verification, but the organization must provide annual documentation of conformance with all EMS criteria to MDNR.

MDNR may also perform spot checks to ensure EMS implementation. Possible incentives for this level of participation include a permitting gatekeeper who will function as a single point of contact for all Department of Environmental Quality permitting; reliance on the company's internal EMS reporting, record keeping and sampling schedules as much as possible for permit requirements; expedited permits; self-audit policy protections; civil penalty mitigation; assistance with EMS implementation and stakeholder involvement; a recognition certificate from MDNR; news releases; and use of an authorized logo for public relations.

The Certified Achiever EMS criteria include the same requirements as the Achiever, with the addition of third-party certification of the EMS standards (ISO 14001, Responsible Care, or others). MDNR will review and verify the certification. Possible additional incentives include recognition by the director of MDNR and innovative technology research and pilot project incentives.

The Achiever Plus classification is designed for the facility that wants to implement all the elements of a basic EMS and achieve an even higher level of environmental performance without seeking third-party certification.

Criteria for participation at this level include objectives and targets exceeding those required by law, annual written EMS performance results provided to MDNR, regular community involvement and communication regarding EMS standards and performance assessment results, and a system for pollution prevention based on the waste management hierarchy of reduce, reuse, recycle, effectively treat and safely dispose. A possible additional incentive at this level includes recognition from the Governor's Office.

The Certified Achiever Plus EMS criteria include all requirements of the other levels of participation. This classification describes companies that achieve the highest level of environmental performance.

Possible additional incentives include a substantial recognition program, Smart Permits, and emission caps, as well as other advanced incentives.

(Ray K. Forrester is president of The Forrester Group.)