EMS, EMIS, and SMS Services

Ashworth Leininger Group routinely develops customized compliance-based Environmental Management Systems (EMS), Environmental Management Information Systems (EMIS), and Safety Management Systems (SMS) for a broad spectrum of our client base - from Fortune 50 companies, to highly specialized manaufacturing operations.  While each EMS project poses unique challenges, we have found that customized computer-based compliance tools are best developed through the following process and guided by the following objectives:

• Working with our client, we establish a clear understanding of applicable compliance requirements, staff and resource availability, existing systems, technical capabilities of the organization, and expectation of stakeholders;

• We provide possible system alternatives that are consistent with all criteria for consideration;

• We focus on using technology and software to support efficient and effective compliance rather than allowing technology and software to dictate the design of the compliance tool.  ALG is a Microsoft Partner and typically utilizes software such as Word, Excel, and Access for system design; however, we often team with software engineers who are experienced in other applications;

• We ensure that systems are usable and understandable to those staff that will be responsible for working with them on a day-to-day basis.  This ensures that the systems are actually used and fulfill their purpose in supporting compliance activities.  ALG supports this outcome through focused training in system use and maintenance.

While each facility is unique, ALG has determined that it is critical to develop facility-specific system using basic templates.  Years of experience and development have gone into producing these templates and making them as user-friendly and complete as possible.  These templates ensure capture of applicable federal, state, local, and company compliance requirements and assign responsibility for performance.

Typically, an EMS system is comprised of five main components:

• Compliance Calendar: The calendar is the main document used by staff to identify what compliance activities need to be performed in a given month, who has been assigend responsibility for each activity, which procedure should be used to perform the activity, and what documentation needs to be prepared and maintained in the site specific filing system.

• Procedures Section: For each activity, the appropriate procedure for completion is developed.

• Process Flow Diagrams:  For each process or regulated unit, a process flow diagram is developed to document design values, usage of chemicals, and releases to the environment.  The PFD documents the baseline for the applicability analysis, which is described further below, and provides a critical baseline for new source review applicability analyses.

• Detailed Regulatory Requirements (DRA): The DRA identifies the compliance requirements for a given facility as well as documenting the exemption status for specific equipment.  The DRA is developed through a review of individual permits and analysis of facility-wide regulatory requirements.  In addition to providing the core applicability analysis, the DRA is extremely helpful for documenting on-going compliance with federal and state/local requirements and is easy to update when permit conditions or regulations change.  In addition to the DRA, a Detailed Company Requirements (DCR) analysis can be performed and documented.  Together, the DRA and the DCR provide a complete identification of all facility requirements.

In our experience, compliance-based management and information systems are typically over-designed, complicated, difficult and time-consuming to use, and therefore are difficult to integrate into existing operations.  The root causes for these outcomes are a lack of understanding of the user interface and the over use of complicated and exotic technical approaches.  ALG has been successful in the past because these issues are addressed early in the process with full involvement of the client, especially those staff members who will be responsible for using the system for day-to-day compliance activities.  The best measure of success has been that where ALG systems have been implemented, overall compliance improves significantly and the systems are used routinely by facility staff.  Some of our EMSs have been in place for over ten years; some of the EMISs have been in place for over twelve years.  In those locations where systems have been implemented, the system is used for performing compliance auditing and eliminates the need for developing separate audit protocols.

Our compliance systems are very effective training tools, as compliance requirements have been clearly and completely delineated.  Also important is the fact that at those locations where staff turnover is high, new staff has a tool available for training and immediate compliance execution.

ALG's onsite compliance assistance experience includes the following:

• Comprehensive EMS:  ALG developed and implemented facility-specific EMSs for an international company with 80+ US and Mexican facilities, which has been in place for over ten years.  The EMS is used by plant staff that has little or no formal environmental training and typically performs other jobs such as maintenance, engineering, quality assurance and human resources.  Overall compliance has improved significantly with little residual compliance exposure.  ALG  has developed similar comprehensive EMS tools for large manufacturing facilities, oil and gas operations, electric power generating facilities, RCRA Part B treatment facilities, and aerospace maintenance operations.

• VOC/HAP Recordkeeping Tools: ALG developed EMIS recordkeeping tools for a company with multiple locations in various jurisdictions to track material usage, and calculate emissions of criteria and toxic air pollutants.  The basic tool was designed for all facilities and then customized for each site to address facility specific regulatory requirements.  Implementation of the tool allowed environmental managers to comply and significantly streamline local recordkeeping requirements, manage and minimize toxic air contaminants, and document significant emission reductions from product substitution.  Similar tools have been developed for aerospace manufacturing and maintenance facilities, paint, adhesive, and solvent manufacturing operations, large coating operations, and electric power generating facilities.

• Title V Compliance Tools: ALG has developed multiple Title V compliance database systems for large, integrated sources.  The database documents all applicable requirements and permit conditions, identifies the specific monitoring, recordkeeping and reporting specified for each such requirements, and documents how these compliance data are managed and by whom.  The database allows managers to track all reporting obligations, streamlines annual compliance certification analyses and allows each of updating and managing the Title V permit itself.  These customized tools have been developed for oil refineries, oil and gas exploration/production operations, electric power generating facilities, large manufacturing operations, and large coating operations.

• Cap-and-Trade Compliance Tools:  ALG has developed customized database systems to help our clients manage compliance with local and regional cap-and-trade programs.  These systems calculate actual emissions, determine "missing data" substitutions (consistent with regulatory requirements), and track total emissions relative to annual allocations.  These tools are essential when reconciling compliance, and to aide corporate and site staff in any enforcement matters.