CASE STUDY 7
New Hampshire Department of Transportation
(NHDOT)
Environmental Management System for Traffic
Bureau
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CASE STUDY 7
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New
Hampshire Department of Transportation (NHDOT) Environmental Management System for Traffic Bureau |
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EMS STATUS |
Implemented (at least in part). |
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FOCUS |
Pavement marking and sign fabrication operations conducted by the Bureau of Traffic. |
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DOT’s BASIS FOR
SELECTION OF FOCUS |
The NHDOT EMS was developed at the Bureau of Traffic as part of a consent decree. The consent addressed the management of hazardous wastes generated in pavement marking/traffic line painting activities. The EMS lessons learned are being used in other NHDOT units to support continuous improvement efforts. |
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RELEVANCE TO THE
EMS PROCESS ROADMAP |
NHDOT EMS development and implementation efforts reflect virtually all steps presented in the AASHTO EMS Process Roadmap. |
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ACCOMPLISHMENTS AND BENEFITS |
· Evaluated 32 operational activities within the Bureau of Traffic to identify significant aspects of their operations. The resulting “Process Flow Diagrams” have supported development of EMS, job hazard analyses, and NPDES Phase II site evaluations. · The Bureau uses water based pavement marking paints, and cleans its equipment with water. EMS planning, opportunities identification, benefit characterization, and implementation processes supported investment in equipment that separates that removes paint waste from the washwater, and allows the remaining water volume to be lawfully discharged into the municipal sewer system. The removed solids are recycled into plastic products. This has resulted in savings of over $25,000 annually in material disposal fees. · Sheeting materials are hydrostripped from worn aluminum traffic signs by a contractor, and the aluminum sign blanks are returned to the Bureau for reuse. This has resulted in lower resource use, and lower cost to deploy signing, since the reused blanks are 40% less costly than new material. The goal is to steadily increase the use of recycled material as experience is gained with this process (the Bureau is nearing its reutilization target of 95%). · EMS deployment has been combined where possible with health and safety program deployment to minimize the impact on productivity and increase the linkage between the two functions. As a result of these efforts, several important elements of department activities (environment, health, and safety) to be addressed in one operational document. · EMS procedures, processes, and tools have been used to address National Pollutant Discharge Elimination System (NPDES) Phase II compliance at maintenance sites within the Division of Operations to begin the further deployment of the system in the department. |
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IMPLEMENTATION NEEDS |
· Obtained external consulting assistance (approximately $20,000) to initiate and complete the EMS development. The assistance was obtained through a grant program with the US EPA. |
CASE STUDY 7
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New
Hampshire Department of Transportation (NHDOT) Environmental Management System for Traffic Bureau |
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IMPLEMENTATION
NEEDS (cont’d) |
· Bureau of Traffic direct line employees invested many hours as part of an “implementation team” that documented current work practices at the shop floor level. With the templates developed by this team it is expected that subsequent EMS implement efforts will require significantly less time. · Sufficient new staff resources are required to maintain written procedures, support program development, support the internal audit function, and maintain records needed to perform performance measurement and corrective action tasks. |
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KEYS TO SUCCESS |
· Top management “buy-in” to the purpose of EMS and the continuous improvement approach to management. · Sufficient initial training to understand the ISO 14000 standard and principles of continuous improvement management systems. · Appreciation of the cultural changes required to move from a hierarchical “top down” management system to a team driven system using continuous improvement principles. · Minimize the impact of EMS implementation to productivity when possible. · Development of internal performance auditing capability to “find-and-fix” issues that arise within the system, as opposed to traditional compliance audits which assign blame for non-compliance. · Starting the EMS effort in a manageable area to gain experience and to show gains quickly. · Involve staff at all levels in the process of identifying environmental aspects and developing the EMS. |
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BACKGROUND,
ADDITIONAL INFO |
The initial EMS development efforts were limited to the Bureau of Traffic. NHDOT is beginning to expand the use of EMS to address National Pollutant Discharge Elimination System (NPDES) Phase II compliance at maintenance sites within the Division of Operations. We have found that information technology is very important to the development and deployment of the system. The software provides a means to collect documentation of policies and procedures that already exists and organize it for use in the EMS. We recommend that each agency examine commercially available software for ISO 14001 to understand how each of the core requirements of the system must be documented, and to see if the tool will assist in their efforts. The greatest strength of an implementation team is their detailed understanding of how a task is actually performed on a daily basis. We document their work using step by step diagrams. We are using the diagrams as visual aids in training and in the workplace to emphasize the steps required to perform tasks safely and in an environmentally conscious manner. A key to continuous process improvement is performance measurement. We are documenting all EMS work instructions in the format used by our Maintenance Activity Tracking System (MATS) to assure that we have the data to analyze. |
CASE STUDY 7
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New
Hampshire Department of Transportation (NHDOT) Environmental Management System for Traffic Bureau |
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CONTACT(S) |
Mr. Paul Sanderson, Hearing Examiner, Commissioner’s Office. 603/271-1698, psanderson@dot.state.nh.us. |
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EXAMPLE TOOLS,
PROCEDURES |
· Exhibit 1, the NHDOT Environmental Policy, demonstrates the commitment of top management to the EMS. · Exhibit 2 provides an excerpt of the Procedure for Determining Environmental Aspects and Significant Aspects which was used to evaluate operations, identify impacts, and prioritize EMS actions. · Exhibit 3 provides an example of an objectives/target statement that includes responsibility assignments, resource needs, schedule, and approach. NHDOT developed its EMS through the combined efforts of staff, and the second two year project of the US EPA to sponsor the EMS Pilot Project for Local Governments. The products of this effort are available online at the PEER Center, see http://www.peercenter.net. We will provide updated materials to the PEER Center as they are adopted. |
CASE STUDY 7
Exhibit 1
Environmental Policy
Statement:
In the performance of its
portion of the Department's mission, the Bureau of Traffic is committed to the
prevention of pollution. The Bureau will strive to manage its activities to
meet or exceed compliance with applicable laws, regulations and environmental
performance standards. The Bureau commits itself to continual improvement through
regular review of its activities, and the implementation of programs that will,
where possible, reduce or eliminate the negative impacts of those activities
upon the environment.
Comments:
(a)
The purpose of this policy is to establish at the Division of Operations,
Bureau of Traffic, an Environmental Management System designed in conformity
with the ANSI/ISO Standard 14001‑1996, entitled, "Environmental
Management Systems Specification with Guidance for Use".
(b)
This policy applies to the statewide operations of all employees of the Bureau
of Traffic, both as they perform their direct service duties, and in the
management of contracted services.
(c)
These words shall have the following meaning in this policy:
"Environment"
means the air, water, and soil of the State of New Hampshire that is or could
be impacted by the activities of employees of the Bureau of Traffic as they
perform their direct service tasks or manage the activities of contracted
services.
"Environmental
Aspect", or "aspect" means any element of the Bureau of
Traffic's activities, products, or services that can interact with the
environment.
"Environmental
objective", or "objective" means a specific and measurable
operational goal that the Bureau of Traffic commits to achieve as a result of
its implementation of this environmental policy.
"Environmental
Management System" means that portion of the overall management structure
of the Bureau continually devoted to planning, determining responsibilities,
implementing practices, allocating resources, and reviewing attainment of the
environmental objectives set in accordance with this policy.
"Impact"
means any change to the environment, whether adverse or beneficial, wholly or
partially resulting from the Bureau's operational activities or management of
contracted services.
"Pollution
Prevention" means the use of processes, materials, or products that avoid,
reduce, or control adverse impact to the environment, and also result in
improved efficiency and reduced costs.
d)
The Commissioners shall determine, acquire and allocate the resources required
to implement this policy. To support this effort, they shall name a person to
serve as the Environmental Management System Manager. This person is
responsible to:
1.
Assist in the development and implementation of environmental management system
procedures.
2.
Assist staff of the Bureau of Traffic in the identification of environmentally
significant aspects of operations, and identification of the impacts such
activities have or could have upon the environment,
3.
Facilitate the efforts of the Bureau to determine, set and measure objectives,
targets, and management plans arising out of the implementation of this policy.
4.
Develop and distribute materials to make all employees, contractors of the
Bureau, other persons or agencies directly impacted by department activities,
and the general public aware of this policy; and
5.
To perform such other duties as may arise from time to time in furtherance of
this policy, including preparation of such reports as the commissioners may
request to document efforts in the prevention of pollution and continual
improvement of the environmental performance of the Bureau.
(e)
With the assistance of the Environmental Management System Manager, the Bureau Administrator
shall develop a set of written system procedures that:
1.
Identify the legal and other compliance requirements imposed by applicable
laws, regulations, or agreements made by the Bureau;
2.
Identify those aspects of Bureau activities that have or could have a
significant impact upon the environment;
3.
Specify a means to identify, set, implement, and measure achievement of
specific environmental objectives and targets for the Bureau;
4.
Specify a means to document and maintain a record of activities undertaken in
furtherance of this policy;
5.
Specify the means to make all Bureau employees, other persons affected by the
environmental aspects of the bureau, and the general public aware of this
policy; and
6.
Specify accountabilities for compliance with this policy and written system
procedures applicable to the Bureau of Traffic.
(f)
As a condition of employment, all employees of the Bureau are required to
participate actively in environmental management system programs, and follow
policies, procedures, instructions, and/or rules adopted to comply with
applicable laws, regulations, or environmental performance standards imposed by
governmental agencies charged with the enforcement of those laws.
Cooperation
between management and employees is necessary to meet this work standard.
Following completion of training, all employees of the Bureau of Traffic are
responsible to be aware of the existence of this policy, and its principles of
pollution prevention. This level of awareness may be tested at any point in
time. Disciplinary action, up to and including dismissal, will be taken in
cases where it is determined that disregard for environmental responsibilities
has occurred. Disciplinary action will be taken in accordance with the New
Hampshire Division of Personnel Administrative Rules, Chapter
Carol A.
Murray
Commissioner
Adopted:
September 21, 2001 Revised:
CASE STUDY 7
Exhibit 2
Procedure for Determining Environmental Aspects
and Significant Aspects
Number:
EMS–CH500– System – 54 - 02
Title: EMS
Procedure for Determining Environmental Aspects and Significant Aspects Date of Adoption: 12/12/01 Date of Revision: Prepared By: EMS Program Manager Reviewed By: Implementation Team Approved By: Lyle W.
Knowlton
Director of Operations |
Document Control:
_____ The secured hard copy signed,
dated, and stamped “Official Document” shall be the controlled document and
shall be maintained by Hearings Examiner. _____ This document and the on-line
version are copies of the secured hard copy controlled document. _____ Duplicate copies may be made
and distributed, however, users must assure themselves the copied document is
the current controlled copy. _____ Earlier versions of this
document are obsolete and should be removed from points of use. |
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D
Distribution: _ _____
NHDOT
intranet; bulletin boards ___________ _
_____ Administrators:
____________________________
_____ Supervisors: _______________________________
_____ Employees: ________________________________
____ Other: ____________________________________ |
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Amendments: |
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Summary: |
1.0 Purpose
The
Bureau of Traffic will establish and maintain an Environmental Management
System, in accordance with ISO 14001.
Pursuant to ISO 14001 § 4.3.1, the Bureau has established and adopted
the following procedure.
This
procedure is to establish a method to analyze and identify environmental
aspects of the Bureau of Traffic’s activities, products, and services over
which it can control or influence. It also describes the process for
determining aspects that have a significant impact upon the environment.
2.0 Scope and
Applicability
This
procedure applies to the Bureau of Traffic and its statewide operations.
3.0 Reference
This
document utilizes references from the following sources:
Environmental
Policy
EMS
Legal and Other Requirements System Procedure
ISO
14001 § 4.3.1
Significance
Matrix
Significance
Matrix Definitions
EMS
Document Control System Procedure
4.0 Policy
The
Bureau of Traffic shall annually review and analyze its statewide operations to
identify aspects of operations that have a significant impact upon the
environment.
5.0 Definitions
- Implementation
Team: means a team comprising of
the supervisors within the Bureau of Traffic.
- Environmental
Aspect: means any element of the
Bureau’s activities, products or services that can affect the environment.
- Environmental
Impact: means any change in the
environment, whether adverse or beneficial, wholly or partially, resulting
from the Bureau’s activities, products or services.
- Significant
Aspect: means an environmental
aspect that has or can have a significant environmental impact.
- Significance
Matrix: means the matrix developed
by management.
6.0 General
Provisions
6.1 Operational
Procedure
The
Bureau of Traffic Implementation Team shall consider the following in
determining whether an aspect of activities, products, or services constitutes
a significant impact upon the environment:
- Any activity of the
Bureau, which is expressly regulated by Federal or State laws, rules, or
regulations.
- The use of an
unregulated product that exceeds 100 gallons per year, or exceeds $10,000
in annual cost.
- Any operation that
discharges to surface water any material in excess of 25 gallons, that is
not immediately contained and removed within 24 hours, and that has an
adverse impact on surface or groundwater, or
- Any stream of solid
waste that exceeds 2000 pounds a year.
The
Implementation Team shall:
- At least annually,
review and update process flow diagrams illustrating each operation of the
Bureau that generates a significant impact on the environment as defined
in above.
- Review applicable
legal and other requirements, as they apply to identifying significant
aspects.
- Analyze all aspects of
the Bureau’s operations using the process flow diagrams, and other tools
devised by management, such as the Significance Matrix, to assist them in
identifying potential environmental aspects and impacts.
- After reaching a
consensus as to the environmental aspects and impacts of their operations,
and applying the significance aspect criteria, identify significant
aspects of their operations.
- Develop a list of
significant aspects. The list
shall be reviewed at least annually to ensure that they are current and
accurately reflect their operations.
6.2 Required
Employee Training
Implementation
Team training shall be arranged by the Bureau Administrator from the
Department’s Environmental Management System Program Manager.
7.0 Specific
Responsibilities
7.1 Bureau
Administrator
The Bureau Administrator shall be responsible to:
a.
Review the Significant
Aspects identified and developed by the
Implementation Team.
b.
Notify the
Implementation Team when new activities, products, or services will be
integrated into existing traffic operations to enable a review of the aspects
of such changes.
- Communicate to
management, employees, and other interested parties via e-mail, bulletin
boards and/or memoranda when new Significant Aspects have been determined
for Traffic’s activities, products, or services.
- That review of
Environmental Management System compliance is a regular aspect of
supervision of personnel and a factor considered in annual performance
appraisals at the Bureau.
7.2
Implementation Team
Under
the supervision of the Bureau Administrator, the Implementation Team determines
environmental aspects and significant aspects.
7.3 Supervisors
Supervisors are responsible to:
a.
Develop and maintain an
accurate process flow diagram for the activities, products, or services that
falls within his/her sphere of operations.
- Know the substances
used in their operations, and their environmental aspects.
c.
Know their tools and
equipment, and know where environmental problems could arise from their use or
misuse.
7.4 Employee
Each
employee is responsible to be aware of the legal and other requirements
applicable to the performance of work tasks, products, or processes assigned to
them, and to perform the work in accordance with the practices and procedures
approved by the Bureau. Each employee
is responsible to request assistance, supervision, and/or training in the use
of a product, or the performance of a task that is new, unfamiliar, or modified
in order to prevent personal injury or an adverse impact to the environment.
7.5 Environmental
Management System Program Manager
The
EMS Program Manager is responsible to provide support and assistance to the
Bureau of Traffic in the implementation of this procedure, and to audit controlled
documents and records of the Bureau at intervals determined by the
Commissioners.
8.0 Audit and
Review
8.1 Items Subject
to Audit and Review
At
least annually, the Bureau Administrator shall review this procedure to ensure
the purposes for which it was created are being met in an efficient manner.
8.2 Record
Keeping; Format; Destruction
- This procedure shall
be maintained in the records of the Bureau of Traffic and each relevant
unit supervisor.
- This document is a
controlled document. The on-line
version and secured hard copies are the controlled documents.
- The Hearings Examiner
shall maintain the secured hard copy, stamped “Official Document” and
dated.
- Changes and updates to this procedure, and filing and destruction requirements shall be noted on all revisions to the original copy, and all paper copies distributed to the Bureau of Traffic.
8.3
Responsibility for Audit and Review
9.0 Personnel
Actions
9.1 Discipline
As
a condition of employment, all employees of the State of New Hampshire
Department of Transportation are required to participate actively in
environmental management system programs and follows established policies,
procedures, instructions and/or rules.
Cooperation between management and employees is necessary to meet this
work standard. Disciplinary action, up
to and including dismissal, will be taken in cases where it is determined that
disregard for environmental responsibilities has occurred. Disciplinary action will be taken in
accordance with the New Hampshire Division of Personnel Administrative Rules,
Chapter 1000.
10.0 Other
Reserved.
CASE STUDY 7
Exhibit 3
Objective:
Reduce
the amount of solid waste generation during Sign Section activities at the
Bureau of Traffic. To accomplish this
objective, the Sign Section will increase the use of recycled material. The increased use of recycled material will
in turn reduce the amount of resources used to build new signs and will thus
have a positive effect on resource consumption. The hydro stripper – water jet process is the approved method for
the re-furbishing used signs.
Target:
Reduce the use of new sign material in the fabrication process by 15% for fiscal year 2002.
Responsible Personnel:
· The employee responsible for achievement of this objective is the Traffic Maintenance Supervisor.
o
The
employee responsible to assure recycled material is used in the manufacture of
signs is the Sign Shop Manager.
· The employee responsible for distributing recycled sign material for fabrication and for maintaining inventory controls is the Stock Clerk.
· The employees responsible for inventory control and developing the quarterly tracking reports is the Account Technician.
· The employee responsible for the training, awareness, and competence of Sign Section personnel in meeting this EMP is the Sign Shop Manager.
Resources:
Personnel:
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New Full Time
Positions: Environmental/Safety Coordinator Stock Control Supervisor |
Financial:
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Personnel: $70,000.00
Construction: $124,000.00 Total Costs: $194,000.00 |
Other:
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Construct lean-to off
Building D for used sign material storage
Install steel I-beam pallet compatible shelving in lean-to off Building D for recycled material storage. |
Schedule:
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April 1, 2002 July 1, 2003 April 1, 2002 |
Tasks:
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January 1, 2002 January 1, 2002 March 1,2002 April 1, 2002 June 1, 2002 July 1, 2002 January 1, 2002 |
Operational Controls:
1. Sign Fabrication work orders:
· Generated by Bureau of Traffic personnel.
· Field crew requests form for replacement sign.
· Material request form for sign from District, Bureau of Turnpikes, and other state agencies to the Sign Shop Manager.
2. Orders reviewed by Sign Shop Manager and/or Stock Control Supervisor.
3. Material Request submitted to Stock Clerk. Completed signs distributed.
4. If material needed for fabrication, Stock Clerk determines blank material use.
5. Blank material to Sign Shop Manager for sign fabrication or to NH State Prison Sign Shop for sign fabrication.
Training, Awareness, and Competence:
· All Sign Section personnel will be trained in the EMS environmental policy.
· All Sign Section personnel will receive specific training relating to tasks that will aid in meeting the goals of this EMP.
· The Bureau of Human Resources will maintain records of all completed employee orientation and training.
Performance Tracking:
· Baseline data for this EMP includes the average of five years of new sign material. Target goals relate to this five-year average
· Quarterly reports will be prepared to identify progress in meeting the target for this EMP.
· The Sign Section Fabrication EMP will be reviewed at least annually or when the dynamics of the program changes. Such changes may include:
ü Objectives and Targets may be modified,
ü New legal requirements are introduced or added,
ü Progress is not made on the Objectives and Targets,
ü Processes, services or activities have changed.
Approved by____________________________________________________________
William Lambert, Bureau Administrator