Procedure 5. Managing Environmental Management Systems (EMS)

The SC Site Office Manager (or Manager of any other SC Field Element) maintains an organization with the necessary competency to oversee EMSs in accordance with (ISO 14001:2015). This competency may be maintained on staff or through the SC Integrated Support Center (ISC), as necessary.

An EMS is a management tool enabling an organization of any size or type to:

• Identify and control the environmental impact of its activities, products or services,

• Improve its environmental performance continually, and

• Implement a systematic approach for setting and achieving environmental objectives and targets and demonstrating that they have been achieved.

Management and Operating (M&O) contractors implement them at U.S. Department of Energy (DOE) sites.

NOTE:  ISO 14001:2015 is a protected document. Authorized copies are not available online. SC Site Offices should purchase a copy from ISO. Obtaining unauthorized copies constitutes intellectual property theft and undermines an organization DOE relies on. To purchase a copy, visit the ISO Store.

GOGO facilities are considered DOE sites (per DOE O 436.1, Section 6) and GOGO Directors must develop and implement their own EMSs per DOE O 436.1, Section 4.c.(3).

DOE Site Office Managers must ensure that EMSs are integrated into the site’s ISM system developed pursuant to DOE O 450.2, Change 1, Integrated Safety Management, and DOE P 450.4A, Change 1, Safety Management System Policy.

Executive Order 13693, Planning for Federal Sustainability in the Next Decade, Section 7 (i), requires each Federal agency to continue to implement and deploy formal environmental management systems (EMSs) where effective and appropriate to achieve desired performance in environmental management and sustainability.

Per DOE O 436.1, Section 5.e, Site Office Managers ensure that the requirement is met.  They:

"(2) Ensure that EMSs covering all site activities are certified to or conform with the International Organization for Standardization’s (ISO) 14001 [...]

(a) At sites with multiple contracts, where appropriate, designate a lead coordinating contractor to maintain a site-wide EMS that accounts for all site operations.

(b) At sites with multiple EMSs, ensure the sustainability objectives and targets established in each are provided for in a consolidated SSP.

(3) Monitor site performance in implementing the requirements of this Order (e.g., DOE O 436.1) and make such information available annually to their PSO/Associate Administrator.

DOE O 436.1 assigns responsibility for EMS implementation to Field Managers. The DOE Memorandum dated October 24, 2016, Departmental Use of Environmental Management Systems, Attachment 2, DOE Environmental Management System Declarations of Conformance to ISO 14001:2015, Fiscal Year 2018, provides the following guidance for EMS implementation:

"The Field Manager, or other appropriate senior manager, should maintain appropriate records documenting:

1. Completion of the required three-year independent external EMS audit and

2. The Field Manager's, or other appropriate senior manager's, determination that the EMS conforms to the ISO 14001:2015 standard.

To ensure that each Departmental EMS is conformant with ISO 14001, each EMS shall be the subject of a formal audit by a qualified party outside the control or scope of the EMS. The audit findings shall be accepted by the Field Manager, or other appropriate senior manager, accountable for the implementation of the EMS. The Field Manager, or other appropriate senior manager, shall declare conformance to EMS requirements, based on the results of the formal audit.

If an EMS is ISO-registered, then the registrar constitutes a qualified party outside the control or scope of the EMS. The registrar conducts a full audit every three years. The most recent registration audit meets the three-year audit requirement. If an EMS will not be registered to ISO 14001:2015, the organization will need to identify a qualified auditor outside the control or scope of the EMS.

All departmental EMSs shall submit a new declaration of conformance to ISO 14001:2015 by October 1, 2018. Departmental EMSs shall submit a new declaration of conformance every three years thereafter. The deadline for subsequent declarations of conformance is three years from the last declaration."

For non-ISO registered EMSs, the responsible SC Site Office must conduct or arrange for the independent audit consistent with the SC Subject Area: Assessments. Additionally, SC Site Office Managers must follow any technical direction concerning three year audits of EMSs provided by the DOE Office of Health, Safety, and Security (HS 1).

Copies of the EMS declaration should be sent to the EMS contact in the appropriate PO where applicable; to the director of the Office of Sustainable Environmental Stewardship (AU-21); and to the director of the Sustainability Performance Office (SPO).

The SC Site Office, or SC ISC Manager determines how EMS applies to their own organization element. If deemed necessary, the SC Site Office or SC ISC Manager may obtain compliance in two ways:

• If co-located on a site with a M&O contractor, obtain coverage through the M&O contractor’s EMS, providing agreed upon information to enable that coverage. The level of information provided to the M&O contractor is entirely at the discretion of the SC Site Office or SC ISC Manager.

• Develop an independent SC Site Office EMS.

The former is assumed unless an EMS for the DOE organizational unit is explicitly prepared. In either case, examples of pertinent DOE (i.e., office setting) environmental aspects which could be addressed in the EMS include:

• Purchasing,
• Electronics use,
• Energy management,
• Water consumption,
• Paper consumption,
• Recycling,
• Local transportation (both business and routine commuting), or
• Business air travel.

Whether within or outside of the EMS framework, SC Site Office or SC ISC specific sustainability efforts associated with the aspects identified above should be promoted.

The SC Site Office maintains records in accordance with the schedule identified in DOE Records Schedule for Environmental Records. See also Procedure 7, Transferring and Destroying Records, of the SC Subject Area: Records Management