This
document, Elements of an Environmental Management System for Biosolids (EMS
Elements) establish management system requirements for effectively managing
biosolids activities at all critical control points. These elements cover
management commitments, planning processes, organizational development,
operating procedures, documentation requirements, monitoring and review
processes.
For guidance in developing an
effective EMS to meet NBP's requirements click here.
POLICY
Element 1 – Documentation of Environmental
Management System For Biosolids
The
EMS Elements describe an organization’s requirements for establishing
and maintaining a comprehensive Environmental Management System (EMS) for
Biosolids that covers its biosolids management activities at all critical
control points throughout the biosolids value chain.
The
Environmental Management System for Biosolids (including the other 16 EMS
Elements) shall be documented in an EMS Manual or equivalent set of program
documents that describe, at least at a general level, the applicable policies,
programs, plans, procedures and management practices in the EMS. The EMS Manual
shall:
-
Be approved by a
level of the organization’s management with the authority to commit people
and resources to biosolids management activities;
-
Contain the
organization’s Biosolids Management Policy and EMS Procedures required by
the EMS Elements;
-
Contain or
cross-reference Public Participation, Communications and Emergency
Preparedness and or Response Programs and Plans required by the EMS
Elements;
-
Cover all critical
control points for its biosolids management activities throughout the
biosolids value chain;
-
Include or
cross-reference all operational controls, procedures, processes and other
management methods used to achieve and maintain compliance with legal and
other requirements; and
-
Describe those
biosolids management activities assigned to and performed by contractors.
Element 2 – Biosolids Management Policy
The
organization shall establish a Biosolids Management Policy (Biosolids Policy)
that commits the organization to following the principles of conduct set forth
in the National Biosolids Code of Good Practice and may include other biosolids
commitments the organization voluntarily chooses to adopt.
The
organization’s Biosolids Management Policy shall be communicated to employees,
contractors and all interested parties and incorporated into the
organization’s biosolids programs, procedures and practices.
PLANNING
Element
3 – Critical Control Points
The
organization shall identify and document the critical control points its
biosolids management activities throughout the biosolids value chain. The
organization shall also identify potential or actual environmental impacts at
each critical control point. The organization's critical control points shall be
consistent with those identified in the NBP's Manual of Good Practice and other
authoritative sources on biosolids management. The information on the
organization’s critical control points shall be kept up to date and the
records shall link each critical control point and its potential environmental
impacts with the corresponding operational control(s).
Organizations
that have successfully completed a third party verification audit shall provide
notification to the NBP (and assigned third-party verification auditor)
following any operational change that requires a change to the identified
critical control points or environmental impacts associated with the critical
control points.
Element 4 – Legal and Other Requirements
The
organization shall establish a procedure for identifying and tracking legal
(federal, state, and local) and other requirements applicable to its biosolids
management activities. The procedure shall include a management process for
incorporating changes and new requirements into the elements of its EMS. The
organization shall establish and maintain records of applicable legal and other
requirements.
Element 5 – Goals and Objectives for Continual
Improvement
In
order to continually improve the environmental performance of its biosolids
management program, the organization shall establish and periodically review
measurable biosolids program goals and objectives for its biosolids management
activities. The organization’s goals and objectives shall reflect identified
priorities for improving the environmental performance of its biosolids
management activities based on its critical control points, identified or
potential environmental impacts, legal and other requirements and applicable
best management practices as defined in the NBP’s National Manual of Good
Practice and various authoritative information sources on biosolids management
(e.g., Water Environment Federation Manuals of Practice). The biosolids program
goals and objectives shall also consider input from interested parties developed
through proactive public participation.
The
biosolids program goals and objectives shall be integrated with other elements
of its EMS and its biosolids management activities, developed and documented
using SMART criteria (i.e., be Specific, Measurable, Achievable , Relevant, and
Time-bounded), and updated on a regular basis.
The
organization shall establish an action plan that describes those improvement
activities it is pursuing to achieve its biosolids program goals and objectives.
The action plan shall designate schedules, milestones, resources, and
responsibilities for achieving its biosolids program goals and objectives.
Element 6 – Public Participation in Planning
The
organization shall select and implement a proactive public participation
approach to involve interested parties in its Biosolids Management Program and
EMS planning process. The approach selected for public participation shall
reflect the organization’s commitments to ten (10) principles in the NBP’s
Code of Practice, including its plan for independent third-party verification of
conformance with the EMS Elements. The public participation approach shall be
consistent with degree of current public interest, the history of public
involvement, the method of biosolids management and related local circumstances.
The
approach selected for public participation shall also provide interested parties
with meaningful opportunities to express their views and perspectives relative
to the organization’s biosolids management activities, including concerns
about environmental impacts, biosolids program performance, and potential areas
for improvement. The organization shall consider input from interested parties
in initially developing its biosolids program goals and objectives during its
EMS implementation and in updating them as part of its periodic review of
biosolids management program performance.
IMPLEMENTATION
Element
7 – Roles and Responsibilities
The
organization shall establish and maintain records of the assigned roles and
responsibilities for its biosolids management program and activities. To assure
these assigned roles and responsibilities are effectively performed, the
organization shall:
-
Appoint an
individual with overall responsibility for ensuring that its biosolids
management program and EMS are implemented and maintained;
-
Define and document
roles and responsibilities of its employees for performing its biosolids
management activities and EMS functions;
-
Provide the human,
technical, and financial resources necessary to effectively execute these
responsibilities; and
-
Define and document
the roles and responsibilities of contractor(s) retained to perform various
biosolids management activities and EMS functions through Service
Agreements.
Element 8 - Training
The
organization shall establish and maintain a training program to ensure that its
employees responsible for specific biosolids management activities and for the
implementation of various EMS functions are competent in performing their
assigned tasks and duties.
The
training program shall provide general awareness of the EMS and how each
employees’ assigned roles and responsibilities relate to the entire biosolids
value chain. The training program shall address new or reassigned employees. The
organization shall maintain records of individual employee training delivered
and completed.
The
organization shall require that their contractors establish their own training
programs consistent with their roles and responsibilities in biosolids
management activities as defined through Service Agreements.
Element 9 - Communication
The
organization shall establish and maintain a proactive Communications Program
that provides ongoing information about its Biosolids Management Program and its
EMS to interested parties and the public, consistent with local circumstances,
the method of biosolids management, its public communications history and
degree of current interest in its biosolids management activities. The
organization’s Communication Program shall make available a summary of its
independent, third party EMS verification audit results to the public. The
organization shall define the roles and responsibilities of outside contractors
in its Communications Program.
The
Communications Program shall include a procedure for receiving inquires and
requests for information from interested parties about its biosolids management
activities and EMS. The procedure shall define a process for assuring a timely
and complete response to inquiries by interested parties. At a minimum, the
organization’s Communications Program shall make the following information
about the organization’s biosolids management program and activities available
to interested parties:
-
The Biosolids
Management Policy;
-
The applicable
legal and other requirements;
-
The biosolids
program goals and objectives for continual improvement;
-
The periodic
Biosolids Management Program Performance Report; and
-
A
detailed report of its independent, third party EMS verification audit
results
The
organization’s Communications Program shall also communicate relevant
information about its biosolids management activities and its Biosolids
Management Policy and all seventeen (17) elements of its EMS to its employees
and outside contractors, consistent with their assigned biosolids management
roles and responsibilities.
Element 10 – Operational Control of Critical Control Points
The
organization shall develop and implement standard operating procedures, work
management practices or other appropriate methods at all critical control points
throughout the biosolids value chain to effectively manage potential
environmental impacts. Operational controls at critical control points shall
incorporate all legal and other adopted requirements and shall consider
applicable best management practices as defined in various authoritative
information sources on biosolids management (e.g. NBP National Manual of Good
Practice, Water Environment Federation Manuals of Practice, etc.).
Operational
controls shall include appropriate preventive maintenance procedures and work
management systems for maintaining equipment, instrumentation, vehicles, and
other treatment technology and process control systems associated with its
biosolids management activities.
The
organization shall require that their contractors establish their own
operational controls consistent with their roles and responsibilities in
biosolids management activities.
Element 11 – Emergency Preparedness and Response
The
organization shall establish and maintain Emergency Preparedness and Response
Plans and Procedures to assure effective response to accidents and emergency
situations associated with its biosolids management activities.
The
organization shall review and evaluate the effectiveness of its emergency
preparedness and response procedures, including communications systems, and
revise them as necessary. All emergency response equipment shall be on site or
readily available within a minimum response time.
The
organization shall require its contractors to establish and maintain Emergency
Preparedness and Response Plans and Procedures to assure effective response to
accidents and emergency situations associated with its biosolids management
activities.
Element 12 – Documentation, Document Control and
Recordkeeping
The
organization shall establish and maintain documentation, documents and records
for its Biosolids Management program including the 17 elements of its EMS.
The
organization shall establish and maintain document control procedures and
practices to ensure that its Biosolids Management program documentation and
documents are:
-
Available and can
be easily located;
-
Created following
established document creation protocols;
-
Kept up to date
through periodic reviews and revisions (if applicable);
-
Properly marked
with version number, effective date(s), and references to replaced or
superceded versions; and
-
Approved
by authorized personnel.
The
organization shall establish and maintain records of its biosolids management
activities and ensure that they are:
-
Available and can
be easily located; and
-
Retained
for the specified period of time
The
organization shall establish EMS documentation, document control and records
requirements for biosolids management activities conducted by its contractors in
Service Agreements, and incorporate these requirements into its EMS for
biosolids.
MEASUREMENT
AND CORRECTIVE ACTION
Element
13 – Monitoring and Measurement
The
organization shall establish and maintain regular monitoring and measurement
procedures and practices for all of its biosolids management activities to:
-
Assure its
compliance with applicable legal and other requirements,
-
Measure biosolids
program performance at critical control points, and
-
Track
progress toward achieving its biosolids program goals and objectives as
required under Element 4.
Monitoring
and measurement results shall be recorded and the records maintained as
established in the recordkeeping procedures under Element 12.
The
organization shall require its contractors to establish and maintain regular
monitoring and measurement procedures and practices for all their assigned
biosolids management activities, as defined in their Service Agreements.
Element 14 – Nonconformances: Preventive and
Corrective Action
Procedures
for Investigation and Taking Correction Action for Nonconformances
The organization shall develop
and implement a procedure to:
-
Investigate any
noncompliance with applicable regulatory requirements and/or nonconformance
with internal EMS procedures identified during routine monitoring and
measurement or periodic internal EMS audits;
-
Identify the cause
and take actions to correct the non-conformance; and
-
Document the
necessary corrective actions taken to prevent a recurrence.
Corrective
Action Plans for Nonconformances
Corrective
action plans shall be developed to address non-conformances identified during
routine monitoring and measurement. Such plans may be as brief as is appropriate
to the situation, but at a minimum, shall identify the nonconformance, the root
cause(s) and the corrective action being taken. The corrective action plan shall
identify changes to policies, programs, plans, operational controls and
monitoring/measurement procedures to prevent future nonconformances.
Corrective
Action Plans for EMS Audits
Formal
corrective action plans shall be established to address the findings of internal
EMS Audits under Element 16, and EMS verification audits conducted by third
parties. The corrective action plan shall be documented, and describe what
actions will be taken to address the audit findings, the individual(s)
responsible, the estimated completion date and required resources to develop and
implement corrective and preventive action. Progress in completing the
corrective actions shall be tracked and periodically updated to reflect
completion. The corrective action plan shall include recommended changes to
policies, programs, plans, operational controls and monitoring / measurement
procedures to prevent future nonconformances. These changes shall be documented
in the corrective action plan, and in the EMS Manual and other relevant EMS
documentation.
Element 15 – Biosolids Management Program
Performance Report
The
organization shall complete a periodic, written Biosolids Management Program
Performance Report (at least annually) summarizing the performance of its
biosolids management program. The report shall contain appropriate summaries of
monitoring, measurements and other results that demonstrate the performance of
the biosolids program relative its goals, objectives and legal requirements,
including those biosolids management activities conducted by contractors. The
report shall also provide summaries of performance relative to other voluntarily
adopted requirements, the organization’s progress toward achieving its
biosolids program goals and objectives, and a summary of its independent third
party EMS verification audit results.
The
periodic Biosolids Management Program Report shall be available to the public.
The organization shall have the flexibility of using other methods, including
electronic methods such as a biosolids program web page in addition to or in
lieu of a written periodic performance report.
Element 16 – Internal EMS Audit
The
organization shall establish and maintain an internal audit program to
periodically analyze the EMS for biosolids and determine whether it is
effectively meeting its biosolids management policy, program requirements and
biosolids program goals and objectives.
The
internal EMS audit program shall define the scope, frequency, and methodology of
the audits, assign responsibility for conducting the audits and communicating
their findings, and designate individuals to whom these findings are to be
conveyed. The internal audit shall also evaluate the organization’s
performance relative to established biosolids program goals, objectives and
performance measures. The internal EMS audit program shall cover all the
organization’s biosolids management program activities including those
performed by contractor.
Internal
EMS audit results shall be reported to the organization’s management in a way
that they can take action to make necessary modifications to the EMS and
biosolids management program. The person responsible for the biosolids
management program shall develop, or delegate the development of, a
comprehensive corrective action plan addressing each nonconformance identified
by the internal audit.
At
a minimum, the organization shall maintain the following documents and records,
as applicable, relating to its audit program:
-
Description of
audit methodology, protocol, scope, and schedule;
-
Identification of
lead auditor(s), qualifications, and description of roles and
responsibilities of auditor(s), management representatives, and others that
may participate in, review, or be expected to act upon the audit; and
-
Corrective
and/or preventive action plans prepared resulting from an audit, and any related
changes made to policies, plans, procedures, and work practices that occur as a
result of an audit’s findings, evaluation, or follow-up actions.
MANAGEMENT
REVIEW
Element
17 – Periodic Management Review of Performance
The
organization’s management shall, at intervals that it determines appropriate,
review the biosolids environmental management system and its performance
relative to policy commitments, goals, objectives and established performance
measures to ensure its continuing suitability, adequacy, and effectiveness. A
lead person or persons shall be responsible for organizing and conducting the
review. The management review shall address the possible need for changes to
policy, the goals and objectives, the biosolids management program and other EMS
elements based on internal EMS audit results, external verification EMS audits
by third parties, changing circumstances, and the commitment to continual
improvement. The management review shall be documented. Any changes to policies,
plans, procedures and work practices that are made as a result of the review
shall also be documented.
At
a minimum, the organization shall maintain the following related to its
management reviews:
-
Schedule and scope
for review(s);
-
Documentation of
findings, evaluation, and follow-up actions; and
-
Documentation of
changes made to policies, plans, procedures, practices and other EMS
elements that occur as a result of the management review findings,
evaluation, or follow-up actions.
END
For guidance in developing an
effective EMS to meet NBP's requirements click here.