Environmental Management System Development Process (2013)

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3 Airports are implementing environmental management sys- tems (EMS) to manage critical and complex issues of envi- ronmental performance and compliance. The status of current EMS practices at airports, though, has not been well docu- mented. Individual airports may have provided information on their approaches and the content of their systems, but a comprehensive understanding of what the industry is doing was not available. This study was undertaken to answer the basic questions of why, what, and how with regard to EMS practices at North American airports. STUDY METHODOLOGY The study is based on a literature review of EMS practices generally, a telephone interview with 20 airports, and a follow- up web-based survey completed by 19 of these airports. The airports that were interviewed and then surveyed had experi- ence with or knowledge of EMS, with two case studies con- ducted of select airports that participated in the survey. Literature Review An initial literature review was undertaken to help shape the survey. After the survey, the literature review was expanded to supplement the survey findings. Relevant information from the literature survey is included here and referenced in this report. All documents reviewed in the literature search, whether refer- enced or not, are listed in the Annotated Bibliography. Environmental Management System Background The concept of an EMS is coming into widespread use. EMS is a structure that organizes and ensures that an organization man- ages its operations that have potential environmental effects and its regulatory compliance obligations (ISO 14001 2004). The managed effects can be negative, such as air emissions; or positive, such as elimination of greenhouse gas emissions. EMS models are typically based on the plan-do-check-act (PDCA) model (Figure 1). The PDCA model is a management system concept that proposes that through continual cycles of planning, implementation, re-checking the plan, and adjust- ments based on the checks, will lead to continual improve- ment for any area of management focus (EPA 2011). Any organization in any sector can implement an EMS. In 2007, President George W. Bush issued Executive Order (E.O.) 13423, “Strengthening Federal Environmental, Energy and Transportation Management,” which requires all federal agencies to establish an EMS as the framework to manage and continually improve sustainability practices. In October 2009, President Barack Obama issued E.O. 13514, “Federal Leader- ship in Environmental, Energy and Economic Performance,” reiterating the EMS requirement. In response, all federal agencies, including the FAA, have implemented EMS. Environmental Management System Models Overview “ISO 14001: Environmental management system— Requirements and guidance for use” (ISO 14001 Standard), developed internationally, is the best known model for an EMS and is generally considered a best practice. In the ISO development process, once a standard is requested by stake- holders, and if the technical committee members from par- ticipating nations agree, the standard is developed by a panel of international experts using a consensus process (www.iso. org 2011). ISO 14001 was first published in 1996 and revised in 2004. It is currently undergoing a third revision process. Organizations that implement an EMS consistent with the ISO 14001 Standard can choose to be audited and certified by an independent accredited certification body (CB), also known as a registrar. The accreditation of CBs is overseen by national accreditation bodies (ABs) (see Figure 2). As of December 2010, more than 250,000 ISO 14001:2004 cer- tificates had been issued in 155 countries and economies, a growth of 12% since 2009 (www.iso.org 2011). The EPA has developed a basic EMS structure that focuses primarily on setting objectives and targets, developing pro- grams to achieve them, and monitoring the programs’ effec- tiveness. While not so robust as ISO 14001, the EPA EMS is structured in the PDCA format. EPA also recognizes ISO 14001 as a standard which meets its definitions of an EMS. No third-party certification is included as a requirement of the EPA (www.epa.gov 2011). The FAA issued an agency-wide requirement, “Order 1050.21,” for the development of an EMS at all of its oper- ations (FAA 2007). The order was issued in response to Executive Order 13423. To support this directive, the FAA developed “Key Elements of an EMS,” that identifies ele- ments that it expects for FAA operations (FAA n.d.). The FAA guidance closely follows the elements included in the ISO 14001 Standard but does not include many of the specific chapter one INTRODUCTION

4 requirements. For example, the FAA does not require third- party certification. In 2007, FAA issued “Advisory Circular (AC) No 150/5050-8” to provide guidance on developing EMS to airport sponsors using federal money. It directs airport spon- sors to use an existing standard and refers to the EPA and ISO 14001 Standards, specifically. The “Eco-Management and Audit Scheme (EMAS) Stan- dard” is another EMS standard that is broadly used in Europe. It was developed by the European Commission in 1995 and has a heavy focus on monitoring and reporting of environ- mental performance. EMAS includes a third-party registra- tion scheme similar to ISO 14001. Originally open only to organizations with operations in European Union countries, registration has since been opened to all organizations regard- less of location. EMAS registrations are reported at more than 8,000 by the end of 2011 (http://ec.europa.eu/environment/ emas/2012). ISO 14001 Overview This study was not focused on a particular EMS model, but was instead based on the broader concept of systems that are used to manage environmental performance. However, to pro- vide a better understanding of a typical structure of an EMS, an abbreviated explanation of the ISO 14001 EMS require- ments has been provided here (see Figure 3). It should be understood that this is an example and that airports may have EMS structures that differ from this or that do not include all of the elements in ISO 14001 Standard. Scope As part of the general requirements, organizations need to define the scope of their EMS. Since an EMS can apply to a single operation, a single facility, multiple facilities, or even an entire organization, it is necessary to define exactly what operations are and are not included in the EMS. Commitment and Policy Development of an EMS starts with an environmental policy. The organization must define and commit to a policy that is relevant to the nature, scale, and environmental impacts of the activities it conducts, the products it supplies, and/or the ser- vices that it renders. To conform to the ISO 14001 Standard, the policy, at a minimum, needs to include commitments to prevention of pollution, compliance with environmental laws and regulations, and continual improvement of the EMS. The environmental policy establishes an overall sense of direction. Planning Information and data gathered during the planning components feed into the rest of the EMS. For example, one of the initial efforts for the organization is the identification of any environ- mental aspects associated with the organization’s activities, products, or services that can interact with the environment, and the differentiation of those that are potentially significant. The organization must also identify any potential environmen- tal impacts—that is, is any change in the environment, wholly or partially resulting from the organization’s activities, prod- ucts, or services—whether positive or negative. During this stage, any legal or other requirements to which the organization is bound are identified. Other requirements FIGURE 1 Plan-do-check-act model. FIGURE 2 ISO 14001 registration scheme. Some industries set up industry-specific EMS Standards. Examples of these are the Responsible Care Standard for the chemical industry and the Recycling Industry Operat- ing Standard. These are both based on the PDCA model and have a great deal of similarity to ISO 14001 with industry-specific issues added.

5 for training, awareness and competence training. Procedures are implemented for communication, both internally and exter- nally, related to the environmental activities of the organiza- tion; to demonstrate management commitment; and to address concerns and questions, raise awareness, and provide informa- tion about the organization’s environmental performance. Documentation of EMS elements, in the form of a manual or a set of linked procedures, documents, and records, is out- lined. Document control procedures ensure that documents can be located, periodically reviewed, and kept current; are under- standable, dated, and readily identifiable, and maintained in an orderly manner. Following identification of the operations and activities at the organization that are associated with sig- nificant environmental aspects, operational control ensures the may include internal commitments, such as a green purchas- ing requirement; or external commitments, such as a commit- ment to report on environmental performance using the Global Reporting Initiative (GRI) Framework, a comprehensive set of sustainability measures (GRI 2006). Objectives and targets consistent with the environmental policy are then developed to address significant impacts on the environment, followed by plans and associated schedules, resources, and responsibilities to achieve the environmental objectives and targets (see Figure 4). Implementation and Operation As part of this element, resources, roles, responsibilities, and authorities for the EMS are defined, along with requirements FIGURE 3 Typical components of an EMS based on the ISO 14001 elements. FIGURE 4 Relationship of ISO 14001 components.

6 organization carries out its operations and activities (includ- ing maintenance) under specified conditions. Documentation procedures are developed if their absence could lead to devia- tions from the environmental policy and the objectives and tar- gets. Emergency preparedness and response planning ensures appropriate reaction to unexpected incidents or accidents. Checking and Corrective Action The monitoring and measurement element requires that the organization measure, monitor, and evaluate its environmen- tal performance and the functioning of the EMS, and is used to ensure the reliability of equipment or systems providing the data. Evaluation of compliance requires that the orga- nization periodically evaluate and/or audit compliance with relevant environmental legislation and regulations and other requirements to which the organization subscribes. Critical to ensuring the continual improvement of the EMS is what is termed the nonconformance and corrective and preventive action process, which investigates and corrects potential and actual deviations from the requirements of the management system as well as correcting and addressing the underlying or root cause of the nonconformance. The organization also develops procedures for the identification, maintenance, and disposition of environmental records. The requirement to establish and maintain a program for periodic internal audits serves as a check on the entire EMS. Management Review Management review closes the continual improvement loop by requiring that top managers periodically review the EMS to ensure its continuing suitability, adequacy, and effectiveness. SURVEY METHODOLOGY With assistance and guidance from the Topic Panel, 20 United States and Canadian airports with experience and/or knowl- edge of EMS were identified for possible participation. Effort was also made to include a variety of types of airports. The identified airports were asked to participate in a telephone interview during the months of June and July 2012 to deter- mine if they had considered developing an EMS and if they would be willing to participate in an electronic survey. The electronic survey, developed based on the results of the lit- erature review, was not designed to reflect a particular EMS standard but instead took a more generic approach, reflect- ing commonalities among the various standards. Topic Panel members responded to the telephone interview and the elec- tronic survey/questionnaire, and their comments were incorpo- rated prior to distribution. (Appendix A contains the telephone survey and the electronic survey/questionnaire and results.) Nineteen of the 20 airports completed the follow-up electronic survey in July and August 2012. (Appendix B lists participating airports.) The answers were self-reported and no independent verification of the answers was under- taken. The survey was “tiered” and the airports answered only those questions that applied based on their preceding answers. Questions asked for both qualitative and quantita- tive data. Owing to the sample size, responses are shown by the number of airports that responded and not percentages. A few airports asked to see the survey in its entirety before responding so that their answers could be compiled, if neces- sary, with other management or other parts of the organiza- tion. Hard copies of the electronic survey were provided as requested, and the airports responded electronically. In one case, the airport was in its initial phase of considering an EMS and requested to supply a limited response identifying only the drivers for considering an EMS. This was accepted as it provided substantive information for the synthesis. Some follow-up with individual airports was undertaken in August 2012 to clarify answers and develop the two case studies. Analysis of Questionnaire The results of the airports survey were aggregated for analy- sis purposes. Some survey questions required a qualitative ranking of the respondents perceived degree of importance. To Several types of audits can be used to monitor manage- ment system and performance: Compliance Audits are used to check compliance with regu- latory and other requirements. Management System Audits are used to check conformance either to the relevant standard or to the defined require- ments of the management system. Audits are also classified by who performs them. First Party Audits are audits that are performed by the organization on itself. Second Party Audits are those performed by a party with an interest in the audited organization, such as a customer or regulator. Third Party Audits are those performed by an independent organization such as a CB (registrar). Transforming the qualitative ranking into a quantitative ranking was done by assigning numerical values to indicate varying degrees in the qualitative response. For example, a question on benefits was scored as followed: • No benefit = 1 • Moderate benefit = 2 • Significant benefit = 3

7 • Chapter Four—Environmental Management System Framework • Chapter Five—Similarities and Differences in Approach and Content • Chapter Six—Lessons Learned • Chapter Seven—Conclusions and Knowledge Gaps. These chapters provide practical information from their peers that airports can consider in making the decision to develop an EMS. better assess the collective responses to these types of ques- tions, those survey results were translated into quantitative measures. In some cases, question results were compared to others to test possible relationships. Where correlations were identified, elaboration is provided. The results of the surveys and case studies have been syn- thesized in this report in the following chapters: • Chapter Two—Survey Respondents • Chapter Three—Current Practices and Challenges