Incorporating P2 into Your EMS

Environmental Policy Commitments

  • Place the highest priority on waste reduction at the source and improved resource use efficiency for continual EMS performance improvement.
  • Involve staff representatives at all levels in practical solutions for process and environmental improvement within the EMS.
  • Account for the full cost of waste and resource loss and assign the costs to their sources.
  • Distribute the responsibility of environmental improvement evenly throughout the organization.
  • Ensure that the design of new products and re-design of old products consider environmental impact minimization throughout their life cycle as well as end-of-life product recyclability.
  • Purchase environmentally preferable products and services that exhibit low-toxicity and high recyclability, when practical.
  • Establish supply chain guidelines related to lowering life cycle environmental impacts. This may involve product re-formulation, modification of production activities, and/or re-evaluation of service programs.
  • Design service packages to customers that minimize the likelihood of negative environmental impacts and where feasible, produce a positive benefit to the environment.

EMS Planning

  • Allow every business unit and job function to have an active voice in each phase of planning and decision making to maximize “buy-in” and instill a sense of employee ownership for all implemented P2 and resource conservation practices.
    Environmental Aspects

    • Consider resource use and waste generation as environmental aspects.
    • Where feasible, consider environmental aspects throughout each life cycle phase.
    • Utilize process mapping to identify, document and link all environmental aspects of your organizations activities, products and services to the responsible sources.
      Develop a full cost factor to assist in determining the significance of environmental aspects or use full cost accounting methods as a final screening to rank an organization’s significant and non-significant environmental aspects.

    Legal and Other Requirements

    • Ensure all plans for compliance support also include components for pollution prevention related to compliance. · Forecast environmental regulations and other external requirements and brainstorm for P2 solutions that can mitigate or avoid them. · Identify regulatory and other programs that encourage pollution prevention and learn how to cooperate with them for business and environmental advantage. · Seek out industry/business sector leadership opportunities for sharing P2 successes that have led to improved compliance or beyond compliance benefits for your organization through industry trade associations, non-profit organizations, or local, state and federal government environmental initiatives.

    Objectives and Targets
    (Step-by-step guidance for using “systems” approach in establishing objectives and targets. Rationale: Many companies set percent reduction goals for their EMS objectives and targets before investigating whether the goal is achievable. Using the approach provided below, an organization can avoid being too conservative or overshooting on their commitment to reduce a waste or lower resource use.)

    1. Establish general EMS objectives without a quantitative reduction goal for each significant aspect under consideration.
    2. Perform root cause and effect analysis for the source of each significant environmental aspect with an established EMS objective.
    3. For each EMS objective, utilize the cross-functional EMS team for an open-ended brainstorming or brainwriting session to derive potential P2 and resource conservation measures.
    4. Conduct a prioritization session and rank the P2/resource conservation measures taking all applicable business considerations, such as implementability, cost savings potential, and/or worker acceptance.
    5. To determine an achievable % reduction/conservation goal, conduct detailed evaluation of top ranked P2 and resource conservation measures and for those requiring a capital investment perform a full cost economic analysis.
    6. Define quantitative percent reduction/conservation target for each EMS objective based upon the results of the evaluation of top ranked solution.
    • Choose targets for resource efficiency and waste reduction that can be readily measured at the process level. Establish environmental performance indicators (i.e. water use, wastewater pH, VOC emissions, etc.) with the cross-functional EMS team that front line process workers can measure and manage themselves in real time.
    • Create special knowledge improvement targets to ensure that effective P2 solutions from around the world are not overlooked.

Environmental Management Programs

  • Utilize a cross-functional EMS team to develop the implementation action plan for each objective and target.
  • Establish a special environmental management program (EMP) to improve the accounting process for allocating environmental costs to responsible activities, products and services.
  • Establish a special EMP for developing a performance index for the environmental impact of products and services and establish goals for improving the index performance.

EMS Implementation and Operation

  • Distribute the responsibility of environmental improvement through all levels of the organization and develop a procedure for ensuring that all information relevant to your EMS is communicated effectively to every department and job function.Structure and Responsibility
    • Require staff representatives at all levels in practical solutions for process and environmental improvement, including senior executives and front line workers.
    • Make all process supervisors and department managers responsible for the environmental performance of their units.
    • Use full-cost accounting methods to link P2 performance and resource use efficiency to the operating budget and to employee compensation rules.
    • Include P2 and resource management performance in job descriptions and employee evaluations.
    • Where feasible, rotate staff between environmental and production responsibilities.
    • Give highest decision-making priority to projects with significant P2/resource conservation benefits.
    • Integrate quality and environmental improvement facility teams into one single workgroup focused on production efficiency.

    Training, Awareness and Competence

    • Teach employees the importance of following the Waste Management Hierarchy for EMS planning, corrective action, and continual improvement.
    • For staff that perform an activity linked to a significant environmental aspect or are responsible for managing a significant environmental aspect, ensure that all required EMS training include an examination of P2 measures with potential to reduce or eliminate the aspect.
    • Ensure that all staff have both basic training in P2 and resource conservation concepts and specific training for P2 resources and solutions applicable to their functions (such as accounting, marketing, design, etc.).
    • Ensure that all managers, supervisors and other appropriate staff have access to computers and are trained in how to use the Internet to tap into the local and global network of practical P2 and resource conservation solutions.
    • Use case study data in training to show the real business benefits of P2.
    • Provide training on how to use “systems approach” tools during the planning, corrective action, and improvement of an EMS. Explain the importance of using “systems approach” tools – to extract employee knowledge so P2 and resource conservation solutions become custom-fit and geared towards source reduction (i.e. process mapping, pareto analysis, root cause analysis, brainstorming or brainwriting, bubble up-bubble down prioritization, and action planning).
    • Develop training modules that educate employees on the synergistic relationship between product quality improvement (lean manufacturing) and environmental improvement (clean manufacturing).
    • Develop an EMS employee incentives program to reward individuals and entire departments for their environmental improvement efforts.
    • Create friendly competitions between departments and shifts for waste reduction and resource conservation. Measure and post their performance on a regular basis with special rewards going to the “winners”.


    • Create an EMS bulletin board and emphasize how P2 and resource conservation are integrated within various EMS elements. At a minimum, focus on the environmental policy, objectives and targets, EMP action plans, measurement/monitoring metrics and structure and responsibility.
    • Provide mentoring assistance on using an integrated P2/EMS approach for continual environmental improvement.

Operational Control

  • Document all P2 and resource conservation suggestions, implemented or not, in a standard form and collate them as a reference tool for staff.
  • Develop a written procedure for regularly reporting on P2 and resource conservation progress to senior management.
  • Post process maps in each work area containing environmental aspects and highlight those aspects that are identified as significant.
  • Provide simple procedures for monitoring significant aspects and recording and posting their full cost to maximize employee awareness (i.e. water submeters, waste generation charts and scales for measuring sludge weight).
  • Establish a written procedure to ensure that the Waste/Resource Management Hierarchy is followed consistently in all decisions regarding environmental performance.
  • Establish a written procedure that describes how to use the following “systems approach” tools within an EMS:
    1.) Process mapping,
    2.) Full cost accounting,
    3.) Pareto analysis,
    3.) Root cause and effect analysis,
    4.) Brainstorming and prioritization, and
    5.) Implementation action planning.
  • When documented procedures for activities are required because their absence could cause significant environmental impacts, establish additional procedures to ensure that these activities are given highest priority for P2 action.

EMS Checking and Corrective Action

  • Ensure that all significant environmental aspects are managed, monitored and measured to provide a baseline for current and potential future EMS objectives and targets.
  • Apply the Waste/Resource Management Hierarchy in all corrective and preventive actions.Monitoring and Measurement
    • Measure and evaluate environmental performance metrics for each significant environmental aspect at the source of use or generation and track aspect quantity and full aspect cost relative a production-normalizing factor (i.e. total parts cleaned, square feet processed, # of widgets painted, etc.).

    Nonconformance and Corrective and Preventive Action

    • Utilize root cause and effect analysis with cross-functional EMS team to assure the corrective action eliminates the problem causing the non-conformance in such a way that it prevents a re-occurrence.

EMS Management Review and Continual Improvement

  • Ensure that each environmental performance evaluation is directly linked to an evaluation of responsible activities, products and services.
  • Encourage self-evaluation and improvement mechanisms for cross-functional EMS team.
  • Establish benchmarks for P2 performance with leading competitors and/or others and use these to evaluate and improve performance.
  • Review and document the performance of all implemented P2 measures to build upon successes and learn from problems experienced.
  • Ensure that all documented P2 and resource conservation suggestions, implemented or not, are reviewed and updated.

By Colin Kiefer. Special thanks to Burton Hamner of for his contributions on the subject of promoting P2 within an EMS.