Pollution prevention planning and environmental management systems

Environmental management systems are increasingly being used by organizations to integrate environmental considerations into day-to-day management decisions and practices.

Where an environmental management system (EMS) already exists, a pollution prevention plan (P2 Plan) can be prepared using the EMS framework. Focussing on pollution prevention can improve environmental performance while supporting the environmental objectives and targets already established in the EMS.

The environmental review completed for an environmental management system can be used to provide baseline information for a pollution prevention plan

Developing an environmental management system involves reviewing operations, products and services and identifying aspects with potential to impact the environment. The information gathered during the development of an EMS can also be used to identify pollution prevention (P2) options, and pinpoint substances, processes, products, and services on which to focus P2 efforts.

When developing a P2 plan, build on objectives, targets, and action plans identified in the EMS

Review commitments and action plans within the EMS to ensure they are consistent with P2. Some may serve as the basis for a P2 Plan; others may need to be modified to incorporate P2 and achieve P2 planning goals. In some cases new objectives, targets, and actions will be needed.

Use existing systems for monitoring and reporting on a P2 Plan

An EMS establishes procedures for monitoring and regular reporting to senior management. By incorporating P2 objectives, targets, and action plans into its EMS, an organization can monitor and report on progress towards P2 planning goals through its existing management systems (e.g., corrective action program, regular management reviews).

Step by step

Refer to the table on the next page to learn how a P2 Plan can be developed in conjunction with the EMS elements identified in ISO 14001:2004 - The International Standard on Environmental Management Systems.

Want to know more?

Here are some additional sources of information about P2 and P2 planning:

Table: Developing a P2 plan in conjunction with an EMS framework
ISO 14001 EMS Elements Developing a P2 plan in conjunction with an EMS framework
4.2 Environmental Policy Within the environmental policy, commit to the principle of P2 and to favouring P2 practices where feasible.
4.3.1 Environmental Aspects Use the initial environmental review, conducted as part of EMS development, to identify significant environmental aspects that should be the focus of the P2 Plan. Ensure scope of EMS and scope of P2 Plan are consistent, or document the differences.
4.3.2 Legal and Other Requirements Reference any legal requirement to prepare a P2 plan (e.g., CEPA 1999) if applicable, or state voluntary commitment.
4.3.3 Objectives, Targets, and Programs Revise existing objectives, targets, and management program to emphasize P2 over pollution control; add measurable objectives and targets specific to pollution prevention, if appropriate.
4.4.1 Resources, Roles, Responsibility, and Authority Designate a P2 manager and establish a P2 team to ensure P2 Plan is implemented in accordance with objectives and targets. Team members could overlap with existing EMS team. Clearly assign roles, responsibilities, and accountability.
4.4.2 Competence, Training, and Awareness Ensure appropriate staff receives training on P2 concepts, P2 practices applicable to their duties, and any new or revised targets and operating procedures resulting from the P2 plan.
4.4.3 Communication When communicating progress toward achieving objectives and targets, include progress toward P2 objectives and targets established in the P2 Plan.
4.4.4 Documentation Reference the P2 Plan and associated objectives, targets, procedures, and records within EMS documentation.
4.4.5 Control of Documents Document control procedures should cover the P2 Plan and associated procedures and records.
4.4.6 Operational Control Revise operating procedures to include P2 techniques, as appropriate. Certain P2 targets may require revisions to specific operating procedures or development of new procedures.
4.4.7 Emergency Preparedness and Response Ensure emphasis is placed on preventing emergencies within this procedure and within operational controls.
4.5.1 Monitoring and Measurement Existing monitoring and measurement procedures should be followed (and revised, as required) to monitor progress toward achieving P2 objectives and targets established in the P2 Plan.
4.5.2 Evaluation Compliance Revise procedures to evaluate compliance with any legal requirement to prepare a P2 Plan.
4.5.3 Non-conformity, Corrective Action, and Preventive Action P2 should be an important element of the preventive action process. Establish procedures for correcting non-conformity to any legal requirement to prepare a P2 Plan.
4.5.4 Control of Records Maintain records related to development, implementation, and maintenance of the P2 Plan in accordance with records management procedures.
4.5.5 Internal Audit If the P2 Plan is integrated within the EMS, the scope of the EMS audit will include all elements of the P2 Plan.
4.6 Management Review Management review should include a review of progress toward achieving P2-related objectives and targets, and any factors preventing their achievement (internal and external barriers).

For further information, please contact

Environment Canada
Regulatory Innovation and Management Systems
c/o Innovative Measures Section
351 St. Joseph Blvd.
Gatineau, Quebec K1A 0H3
Phone: 819-994-0186
Fax: 819-953-7970
Email: LCPEPlansP2-CEPAP2Plans@ec.gc.ca

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