Preparing to Develop a Firm Enviromental Management Systems Plan
February 19, 2021
- So I'm gonna talk about preparing to develop environmental management systems plan for higher manure application firms. So the goal for an EMS plan, an environmental management systems plan is to help you identify risks and challenges that could be reduced by implementing standardized training procedures and documentation resulting in improved profitability and diminished environmental risk. An EMS plan does not ignore business management. As a good citizen, you should be concerned how your firm affects others. You are the face of your client on the road and in the field. As a good business person, you are also concerned about productivity, input costs and other costs. In a world of ever shrinking margins, agriculture simply cannot afford pollution or its liability. Incorporating environmental stewardship in a profitable business management plan is the goal of an EMS plan. An EMS plan can be developed by the entire staff or just the crew supervisors or just key personnel. Once developed, the document should be reviewed on an annual basis with all employees for their review, comment, and signature. Employees need to see the commitment of management to the plan and buy into the plan themselves. An EMS plan has the following sections; scope, environmental issues, environmental policy statement, standard operating procedures, EMS plan documentation, employee training, communication plan, document control, management reviews, signature page, and appendix. Now this might sound like a lot, but some sections, they're gonna require less stuff, documentation than others. Instructions for completing each section are provided in a workbook that can be downloaded from the Michigan Manure Haulers Certification Program website. Use the workbook as a template to help you develop your EMS plan. Type in the required information for each section and be as thorough and clear as possible. You read the instructions for each section so they could aim just your information. When all the sections are completed, you'll have an EMS plan. Questions about and assistance with developing an EMS plan will be provided by Michigan State University Extension educators. Our contact information is on the last slide of this presentation, and on the Michigan Manure Haulers Certification Program website. I'm gonna now briefly explain each one of those sections. So let's talk about scope first. Your EMS plan can be very specific, meaning only focused on a work site or very broad, which can include a website depending on scale, shop, or office. At a minimum, an EMS plan that meets the level three certification standards must include equipment transport to work sites, equipment set up and startup, agitation, pumping, and transportation, application, shut down, cleanup procedures, spill response, and B-A-S Security. So let's talk about environmental issues. Land application of manure presents a unique set of environmental challenges and circumstances. This exercise in thinking through the environmental issues is associated with the equipment that you operate and also the conditions you are presented with when applying manure. Some examples of potential environmental issues associated with equipment and operating conditions include; equipment tip over, vehicle accident caused by an employee, and manure spilled on the road, as well as dragline failure. And I wanted to make a point here. This is a road where there was an oil spill, and you notice in this next slide because of the procedures that were followed because of an EMS plan, this is the picture after the cleanup took place. So an environmental policy statement establishes the stewardship commitments that are important to your firm. Future manure application activities will be evaluated by asking what does our policy statement say that we will do. Your policy statement needs to include a brief description of your operation and commitments to regulatory compliance, pollution prevention, and continual improvement. Continual improvement is vital and often overlooked. It means that even if you are good, you keep on trying to get better. While you could write a policy statement using generic statements like we are committed to preventing pollution. Your policy will be more meaningful if you personalize it. Your policy statement should really reflect your unique beliefs and intentions. So let's talk about standard operating procedures. This is really gets at the heart of an EMS plan. Standard operating procedures help address the risks that you identify in the environmental issue section. Standard operating procedures are written instructions for completing a specific activity. They can be developed for anything done on a regular basis, but are especially important for taking samples, calibrating equipment, completing complicated inspections or maintenance, or any place where the integrity of your product could be compromised. Non-critical simple activities that are common knowledge don't require this formality, but you should consider developing a written standard operating procedure if there could be serious environmental, legal or safety consequences rather if the procedure is done incorrectly. A procedure is done infrequently cannot be easily memorized, must be done the same way each time or maybe done by several different people. Someone else may need to complete the task in the absence of a person who usually completes that procedure. And finally, it will speed up orientation of newly hired employees or those who work on a seasonal or infrequent basis. Standard operating procedures do not have to be elaborate, and that's a really important point, but it needs to be understandable and if possible, translated into another language. A rule of thumb is that someone who has never been on your operation should be able to understand and follow the standard operation procedure and correctly perform the task. You can use an extension publication, you can copy an owner's manual page, or you can take a series of photos showing the procedure. And you'll recall from yesterday, that was one of the things that Allan pointed out. Some examples of tasks that could be written as standard operating procedures are; manure spreader calibration, equipment transport to a site, equipment set up and startup, and pit agitation. At a minimum, standard operating procedures are reviewed annually during the management review. Employees need to be made aware of any changes to a standard operating procedure. As soon as possible, after the date of hire, new and returning seasonal employees should be informed and trained on standard operating procedures that are relevant to their job responsibilities. Next is plan documentation. Doing business today requires sophisticated knowledge of your system and the interactions between system components. Increasing regulations and a demanding public means greater scrutiny of many of your practices. Accurate and organized records will help you document compliance with regulations, track progress toward achieving your objectives and identify improvements. Records also provide proof you're implementing your environmental policy statement. Employee training. A record of employee training and orientation should be maintained as part of an EMS plan. You should spell out how you ensure that every employee is adequately trained to do their job, meet environmental responsibilities and follow the EMS plan. Every employee needs to understand the overall environmental policy of your firm. They also need to know all the environmental aspects and responsibilities of their particular job. Keeping records of who has been trained on what and when they got the training is a best management practice. Also think about whether refresher training will ever be needed. And here's the key point. If an OSHA or state investigator happens after an accident, the first thing they will want to see is your training records. So accurate training records are your defense. A communications plan. Lora talked about that yesterday and much of the great points that she brought out can be incorporated within your communication plan. So your firm should have a plan for what you communicate, who you communicate with and when. The plan should also cover how you listen. Keep your communication plan simple. A plan should also designate a single point of contact who will respond to external questions. Employees need to know what information they can share with the public versus what the crew supervisor or the designated point of contact should communicate to the public. Document control. That just simply means that you have a system in place that you can make sure that you remove outdated documents. So they're not accidentally used and result in some kind of manure spill or other kind of issue. Management review. This is a part that often is overlooked, but was also mentioned during Allan's presentation yesterday. So really on a regular schedule, at least annually, top management should review the EMS plan to see that it's working as it's intended and decide whether it needs to be revised or corrected or improved in any way. Signature page. That means that employees have reviewed the EMS plan, they sign it and they sign it within 48 hours of hire or if this is their first day on the job or returning to the job. And then you have the appendix. This is where standard operating procedures and other documents go that support your EMS plan. Really no limit on how big your appendix can be, but that's where you put in documents that support your EMS plan. So the EMS plan template can be used as a guide to develop a functional EMS plan. This approach builds on the risk identification and priority setting the process of an assessment by adding in critical management functions to assure that environmental plans are developed, implemented and regularly implemented. Some of the benefits that may be realized through a functional EMS plan include; stewardship plan that targets the firm's most significant environmental issues and risks, a proactive commitment to improvement, improvements in employee training, knowledge and morale. And that really allows the manager to be able to take a vacation or give more responsibility to others. A mechanism for finding cost savings and or improving efficiencies. Identifying and controlling potential sources of error, which means that those in management can spend less time putting out fires and more time managing the operation. And then finally, improved relationship with neighbors, the community and regulators. The very type of thing that Leslie has been talking about. So a functional EMS plan needs to be robust enough to allow those internal to the firm to develop, implement, maintain, and improve the plan. The complexity of the records and documentation will largely reflect the complexity of the stewardship plan or the complexity of the business structure. A firm operated mostly by a single person is not gonna have or need the level of complexity as with an EMS plan for a larger firm that has lots of employees or more levels of management. So in summary, the goal is to help you identify risks and challenges that could be reduced by implementing standard training procedures and documentation resulting in improved profitability and diminished environmental risk. Incorporating environmental stewardship into profitable business management is the goal of an EMS plan. An EMS plan can be developed by the entire staff or just by the crew supervisors or just key personnel. Once it's developed though, the document should be reviewed on a regular basis with all employees. And employees need to see that the commitment of management to the plan and they need to buy in themselves. An EMS plan has 11 sections. Each section are provided in a workbook found in the Manure Hauler Certification Program website. So use it as a template to develop your plan. And finally, MSU Extension educators are there to help you put your EMS plan together. We're not expecting you to do it on your own. We will help you in reviewing and developing your EMS plan. If you want to get started on your EMS plan, there's three of us that are available and here's our contact information. You can also go to the Manure Hauler Certification website and find our contact information there. Let's see. No questions in the chat box and it looks like we are going back to the Q & A session. So Shelby, if you wanna move us back into the main room will be appreciated. - [Shelby] I'm going to quick check on the farm room to make sure they're ready to be pulled back, and then I'll pull everyone back into the main room. - All right. That will probably just take her a minute to do. Rather than have some silence here. Any questions or comments? All right, Laura, for the EMS plan, how would a hauler distinguish between for instance a hauling for permitted versus non-permitted farm or others? That's gonna have to be designated in the EMS plan, and somewhere in that plan, that point will be made whether it's a permitted farm or a non-permitted farm. - So Charles, a lot of that goes back to the individual farm's nutrient management plan and the setbacks they have to follow. And so in other states, the custom applicators are very succinct in that they say in the plan the minimum setbacks, whatever the minimums are will be followed and then any additional setbacks will come directly from the farm's nutrient management plan. - All right. Thank you, Kevin. Any other questions or comments for that matter? - [Laura] Charles, is an EMS plan gonna be something that is gonna be kept in the office or in the truck. Where's the ideal point at which employees as well as leadership in a company should be able to access it. - Okay, Laura, I think that was you, and I could barely hear you. - [Laura] Let me try that again. Where's the best place to keep that EMS plan where everybody can access it? - Well, we've talked about that and we certainly need to have a copy of it in the office, but it would not hurt to have a copy in the cab of a tractor, in a place where it's readily available. It may be that just sections of that EMS plan are pulled out as is appropriate for the job that's being done. Like the standard operating procedures, for example. Oh, Kevin, that's a really good point on Google Docs. So it can be pulled up when they're out in the field. So the standard operating procedures are individual and pertain to a task. For example, the Allan had those videos on YouTube and the employee was able just to pull that video up and just look at it if they needed to. The whole plan should reside either on a Google Drive site, in Google Docs, or a hard copy in the office. But then it can be broken down and accessed when it's needed. Kevin, you want to add anything else to that? - Nope. I know that there's a number of folks that will put them in Google Docs or on a website and just provide a private link to their employees and say, put this in your context, since in the context area of your phone, you can have additional information. And so they'll just have a boss or a farm, or whatever contacted the phone, it's right there along with the boss's cell phone number, the cell hotline number. Everything that they might need is under one contact in their cell phone contacts. - When this plan is put together, it's reviewed every year. The EMS plan combined with the manure application equipment inspection. Just as a reminder of that for those who are Farm Bureau Insurance policy holders is a 10% reduction in their environmental policy. To get it to where it works is applicable to the operation is critical.