Chapter 6: Monitoring Progress

Formulating a Measurement System

The environmental task group should establish a measurement system to regularly measure the characteristics of its operations and activities that have a significant impact on the environment. This includes recording information on performance and whether objectives and targets are being met.

The system will monitor and measure actual performance against the action plan, and should be straightforward, cost-effective and technologically feasible. Indicators should be verifiable and reproducible for practical use and analysis.

The maintenance of records is essential to implementing the EMS. Records show the program's success or otherwise in achieving objectives and targets. The record-keeping process includes identifying, collecting, analyzing and completing information and data.

When keeping records, focus should be placed on environmental information that the company needs to manage effectively.

Generally Measurable Items

• Quantity of raw material or energy used
• Quantity of emissions such as CO2
• Waste produced per quantity of finished product
• Efficiency of material and energy use
• Percentage of waste recycled
• Percentage of recycled material used in packaging
• Specific pollutant quantities, such as NOx, SO2, CO, HC, Pb, CFCs

One way to monitor performance is through a record sheet, such as a Data Structure Model, which should be completed for every activity.

Table 3 Data Structure Model   - Example of pH control in wastewater

Once the Data Structure Model is complete, it should be reviewed and followed-up. Below is an example of follow-ups for various activities comprising of Wastewater Control.

Environmental Indicators and Concepts to Consider in Measurement System Development

• Operational Systems: raw material use, energy use, waste generation, waste disposal and controlling environmental aspects (such as the number of days without incidents).
• Environment Area indicators: natural resources, water quality and air quality.

Suggestions for Developing and Using Measurement Systems

• Examine existing regulatory compliance (e.g. quality, safety) and environmental programs. Could they be adapted to serve the EMS purpose? How effective have they been? How might they be improved?
• Define the factors to be measured to determine a project's outcome, and collect only the information that is relevant and valuable. More than one measurement may be needed to inform the management of a company how it is doing in the environmental area.
• Specify the frequency and method of monitoring EMS implementation (procedures and changes), and compare it against the environmental targets and objectives previously established in the EMS action plan.
• Identify the process equipment and activities that affect environmental performance. Some companies put key monitoring equipment under a special calibration and preventive maintenance program. This can help to ensure accurate monitoring and informs employees which instruments are most critical for environmental monitoring purposes. In some cases, it may be more cost-effective to subcontract, rent or share calibration and maintenance of monitoring equipment, or the equipment itself, rather than performing these functions internally.
• Equipment used for monitoring and measuring must be accurate and calibrated on a regular basis, but the company does not have to own all the equipment. As previously mentioned, it may be shared, rented or leased.
• Quantify the financial implications and results of environmental protection using a standard accounting system.
• Link the measurement program with the communication program.
• Do not tolerate excuses for failure to meet compliance. For example, delaying corrective action for internal assessment discrepancies should be considered negligent.
• It is acceptable to start small and build up over time as the company gains experience in evaluating its performance.
• Record the quantity of waste (liquid, solid and gaseous) produced by each process the company is engaged in.

Benchmark Technique

The environmental task group may consider using benchmarking, a well-established practice that can be used to identify improvement options.

In benchmarking, managers first identify the "best in class" companies, i.e. companies that have developed excellent practices which might pertain to customer service, inventory accuracy or environmental practices. Management may then visit these companies to learn, exchange ideas and build cooperative alliances.

The company then sets standards to meet or exceed the achievements of the best practice company. Benchmarking is one way whereby managers can become aware of the different approaches of companies in other industries, as well as other unique or effective solutions for handling environmental issues. Trade associations are often able to assist with benchmarking initiatives.

Assessing the EMS

The information gathered during an EMS assessment will be used to determine if the company is on the right track with its action plan and to identify areas for potential improvement of the EMS. Assessment should be used as a vehicle for making changes for continual improvement and for revising and updating the EMS.

Steps for Assessing the EMS

• Assigning and training personnel. An EMS assessment can be undertaken by the company personnel, external parties, action team and/or environmental task group. The composition of an assessment team will vary from company to company. Often the original environment task group takes over the functions of the assessment group, however participation of new members can enhance the assessment and bring new inputs. The team should include, whenever possible, personnel involved in each stage of business operations.  Even those employees who are not directly involved in processing or production may have helpful suggestions. Familiarity with environmental regulations, the company's EMS objectives and targets, facility operations, and auditing techniques are helpful skills. Auditor training materials are available through a number of organizations, but it may be more cost-effective to link up with other local organizations (perhaps through a trade association) to sponsor an auditor training course.
   
• Selecting procedures. The environmental task group and the assessment team will create an assessment plan and an internal EMS checklist, including the EMS action plan targets, for use as a guide. These documents should cover all areas of the business, examining particular areas of the company (such as manufacturing, transportation and receiving), environmental issues (such as water, waste and energy) or individual operation sites. Assessment forms and checklists can facilitate gathering and recording information.
   
• Establishing frequency. An EMS assessment should be conducted regularly to evaluate the status of the  EMS and to determine whether the system has been properly implemented and maintained. The frequency may vary according to the process, although an assessment should be conducted at least once a year. The assessment team should schedule meetings weekly, monthly or quarterly to discuss the investigations and share new ideas and information.
   
• Documenting findings. Identify relevant problems, solutions, costs and opportunities and record all recommendations throughout the assessment procedures. Remember to keep it all well documented. An effective environmental assessment should generate sufficient information to enable the company to develop its next action plan. The main objective is not only to locate weaknesses and deficiencies in the implementation, but also to highlight achievements and compliance.

Assessment Procedures

Processes Products

Identify

Assessment/ Evaluation

Verify

Improve

• Make a preliminary investigation to identify irregularities and non-compliance with the EMS action plan.
• Conduct a facility walk-through to verify the information and observe the processes and operations.
• Document the findings and disclose the information .
• Assist the environmental task group in writing an new action plan.

Considerations for the Assessment Team

• Information can be obtained from various sources, such as document review. For instance, a comparison could be done between the total raw material purchased from year to year, or the total volume of wastewater from month to month. There are improvements that may be impossible or difficult to quantify, therefore, the company should utilize alternative methods to measure its improvement. Interviews and observations of working practices are further sources of evidence.
• The assessment team must have someone in charge and accountable for carrying out the procedure. 
• A timetable should be established for completing the tasks outlined.
• The appraisal should be conducted during normal business hours, so the assessment team can talk to employees and observe processes in operation.
• The appraisal should follow the product life cycle from receiving raw material to delivery of the final product or service. One option is to break down the assessment process into sectors, since some areas may require more frequent monitoring.
• The assessment team should evaluate the strengths as well as weaknesses in the process.
• The report should be written in a non-technical style since its readers will likely have a range of expertise.
• Specific attention should be given to corrective actions for discrepancy findings from previous appraisals.
• Discuss the report with personnel affected by the issues reviewed prior to its release to ensure that data are not distorted.

Considerations if Results Show Difficulties or Shortfalls in Target Attainment

• Is the measurement system consistent?
• Are there missing or faulty procedures?
• Is equipment working?
• Has there been sufficient training?
• Are the requirements not properly understood?
• Have the rules been enforced?
• Is the communication process working?