•      

Plan - Phase II

Identifying the Environmental Hotspots (Significance Criteria)

After your organization has gone through the environmental aspect identification process you will need to identify the hot spots or those that have significant impacts. You may find yourself faced with a large list of aspects. The application of significance criteria will potentially reduce the size of the list - it's an opportunity to prioritize your environmental issues based on criteria generated by your organization. The aspects that have an associated significant impact are then considered significant aspects. The EMS is structured to address the organization’s significant environmental aspects. It’s the significant environmental aspects that you will manage in order to control or limit the associated environmental impacts.

Significant environmental aspect - an environmental aspect that has or can have a significant environmental impact.

  • Note:   each organization defines its own criteria to determine which impacts are potentially “significant” and which are not             
  • Each Organization has Flexibility in Determining Criteria for Significance  
    • Subjective - Not an exact science  
    • Not based on a complex formula  
    • What you determine as significant may not be significant in another organization
  • Significant aspects are the basis for building all of the other elements of the EMS

Significance criteria to consider:

  • Natural Resources Impact             
  • Cost             
  • Probability of Occurrence             
  • Volume             
  • Toxicity             
  • Regulated*             
  • Adverse Publicity             
  • Nuisance             
  • Human Health Impacts             
  • Frequency

*Regulated – it’s recommended that regulated impacts be significant by default. State and Federal regulations require that certain control measures be established for activities with varying degress of environmental impact. In a sense certain impacts associated with your organization’s activities or operations have been predetermined as significant by these regulations. By labeling them as significant you ensure they will be addressed by the EMS.

Identifying Significant Environmental Aspect – Getting Started

1.  Process Flow Diagrams - A map of aspects

2. EMR delegates responsibility for aspect identification and sets a completion schedule

                        - Core Team/Shop Manager/Floor Personnel

3.  Compile aspect identification results

4.  The Core Team develops significance criteria

5. Apply significance criteria

              –        Cross-functional representation

6. EMR report findings to top-management

             –        Promotes management involvement/understanding/buy-in

Lessons Learned

  • The aspects identification process is the driver behind the EMS and requires a substantial effort, but………            
  • Start small….. keep it simple, and….            
  • Be sure there is an established aspects review schedule   
    • a minimum of annually  
    • when upgrades or modifications occur  
    • especially on capital improvement projects
  • People in the public sector are parochial. Bring in other/outside experts from similar plants (may be from another town, within the same agency,etc) to assist in identifying the significant aspects            
  • Do not focus solely on the significant aspects as they relate to the environment. Keep in mind other aspects (such  as employee safety, energy efficiency) of a given function.            
  • There should be a procedure in place directing the process.            
  • This is not a secret; involve a cross section of employees.            
  • Aspects identification should include positive as well as negative aspects.            
  • Consider documenting "Control Methods" for managing the significant aspects.  This can be plans, procedures, processes, etc.            
  • Those significant aspects that may not be well managed are the starting point for developing objectives, targets and associated improvement programs.     

Checklist

Have we

  • evaluated products, activities, and services?            
  • documented criteria for significance?            
  • determined which aspects are significant?            
  • documented a procedure?            
  • involved a cross-functional team?

Next - Identifying Legal and Other Requirements