Gabriele Crognale

Seeing the photographs streaming in from the Red Planet, Mars, I was awestruck by the strides science and technology have made over the years to allow such a feat that combines various manufactured machine parts and gizmos with appropriately choreographed software to allow these gizmos to relay photos back to earth many millions of miles away. It still astounds me!

What does this have in common with an environmental management system? Plenty. Just as the flawless execution of the duties of the two Mars rovers required years of preparation and planning on the part of an entire team of scientists, engineers and their specialty contractors, the effective execution of an EMS requires the dedication not only of the team empowered to execute and maintain the EMS, but also of other employees who have a vested interest in the operation of the facility. Often times, the effectiveness of a facility’s EMS can be traced back to the levels of responsibility and dedication of various employees within certain critical work stations whose work may have an effect upon the environment.

For this, we need to take a closer look at the main components of a typical EMS:

its structure
responsibilities
focus
ultimate goal

Each of these key components, in turn, come into play in some fashion when training needs arise requiring an effective solution.

While ISO 14001:1996 is an international standard, training — or more specifically environmental training — is nothing new to the regulated community in the US. Many US laws and regulations require specific training ranging from hazards in the workplace, such as Right-To-Know and other OSHA requirements specifically aimed at worker health and safety, to the many regulations administered by the US Environmental Protection Agency (EPA), such as the detailed hazardous waste requirements of the Resource Conservation and Recovery Act.

The most specific of these requirements can be found in 40 CFR 265.16: Personnel Training that states in part “… personnel must success-fully complete a program of classroom instruction or on-the-job training … that insures the facility’s compliance with the requirements …” There is also additional specific training that some employees need to take relative to their specific job duties, the absence of which could provide business issues for their employers.

I have seen first hand examples of both a lack of specific training or inappropriate/ineffective training and the consequences of each in the work place, and I cannot stress enough the importance of effective and well-placed training. For this reason, it is not surprising to see a specific reference to employee Training, Awareness and Competence within Section 4.4.2 of ISO 14001:1996.

That section refers to training that reinforces the importance of an organization’s responsibility to identify training needs and to ensure that all employees whose work may have a significant impact upon the environment have been trained.

Let’s return to our Mars rovers analogy: the structure of staff that make up the facility is not just the EMS team, but all the ancillary personnel in various business units who make up the whole organization, as well as any of their contractors or other service providers, just like the personnel from NASA and those responsible for the mission’s success, along with their specialty contractors who designed and made the components and software to make it all possible.

Once an organization’s structure has been completely catalogued or diagramed in some fashion, we can move on to the next step: responsibility. The cornerstone of an EMS sits upon employee responsibility, which is really the EMS broken down into its simplest element. In organizations, this responsibility is usually described in a job description; the more responsible the position, the more detailed the job description.

Oftentimes, some organizations overlook the importance of ensuring that all employees who require some form of specialized or required training do in fact, receive that training, or if they do, neglect to do current such training.

Other organizations take the extra effort to develop training matrices that not only schedule training for each affected employee, but also keep track of each employee trained with documented training records. Then, there are those organizations that do all the right things, but do not follow through with tracking the training’s effectiveness by checking on employees’ awareness levels or reviewing the evaluation sheets of the trainer.

Also, training can take on many forms, from the onsite training of specific equipment or software that a vendor usually provides, to specialized required training deal-in with environmental regulations or specific training related to ISO 14001:1996 from implementation “boot camps” as some providers call them to the fundamental and more advanced auditor courses that are prolific in both quantity and cost.

What, then, is the practicality and added value that such training can provide to the regulated organization? To address this question, let us look in greater detail at the organization’s focus and it’s ultimate goal, which are usually interrelated. An organization can have more than one focus and ultimate goal, although in the ISO-arena it usually boils down to a customer-driven requirement, such as with the Big Three automotive companies and with some large electronic manufacturers, where certification to the ISO family is simply part of doing business.

Also, training can take on many forms, from the on-site training of specific equipment or software that a vendor usually provides, to specialized required training dealing with environmental regulations or specific training related to ISO 14001:1996 from implementation “boot camps” as some providers call them to the fundamental and more advanced auditor courses that are prolific in both quantity and cost. What, then, is the practicality and added value that such training can provide to the regulated organization?

To address this question, let us look in greater detail at the organization’s focus and it’s ultimate goal, which are usually interrelated. An organization can have more than one focus and ultimate goal, although in the ISO-arena it usually boils down to a customer-driven requirement, such as with the Big Three auto-motive companies and with some large electronic manufacturers, where certification to the ISO family is simply part of doing business.

For other companies, the focus could be related to decreasing one’s environmental footprint and being perceived as a good neighbor, one aspect of the American Chemical Society’s Responsible Care® ISO 14001 certification program, which is more robust than ISO 14001:1996 alone.

How organizations achieve either focus or ultimate goal or both, rests heavily upon how effectively training has been provided to those employees who are an integral part of the organization's’s overall mission. The key here is that the responsible facility official needs to ensure that tailored and/or specific training is provided to all those individuals within the organization whose job descriptions are critical to the success of the EMS and, hence, the overall focus and ultimate goal of the organization.

Key individuals could include all or some of the following areas:

EHS group
maintenance
supplies/stores
shipping and receiving
human resources,
manufacturing
engineering
marketing
public relations

Training, in turn, comes in many forms, although it can be broken down into two main components: formal and informal. Each has its own merits, and it is wise to meld the best of both for optimal lesson plan effectiveness.

For example, some employees may be hesitant to share their thoughts or questions in a formal training session for whatever reason, but may be more apt to revisit their thoughts in an informal setting with their supervisors and diffuse a potential environmental issue down the road. The use of specific tools or other appurtenances that require specialized training, such as forklift operators, also cannot be overlooked.

Similarly, facility personnel often times fail to include in their EMS planning process the many outsourced service providers who may be in need of some form of special-i zed training .

In either situation, the absence of specialized training could trigger environmental impacts. In short, effective employee training is one crucial element of maintaining an effective and robust EMS, but the caveat here is that, such training is not per -formed in a time warp — it needs constant attention, tracking and checking to ensure it is being effective. Otherwise it becomes just as useful as the once-used training manuals that gather dust in an employee’s cubicle, which has no value to the organization.