The purpose of this procedure is to provide guidance for evaluating the environmental aspects and impacts of your organization’s activities, services, and products.
The evaluation should result in a determination of whether or not a particular aspect has any significant environmental impacts and if so, whether or not the organization can control or influence those impacts.
Those activities, services, and products that are identified through this procedure as having significant and controllable impacts will then be reconsidered in the procedure to determine objectives and targets for controlling the identified impacts.
This procedure has been used to conduct initial aspect / impact assessments and in follow-up assessments at various points in time.
Each of the groups that make up the EMS organization shall identify and document the environmental aspects of the activities, services, and products under their control or influence and identify those that can have a significant impact on the environment.
At a minimum, this procedure will be used once a year to determine if there have been any changes to each of the aspects that have been identified.
This procedure will also be used whenever a new activity, service, or product is being considered by the organization.
Environmental Aspect – element of an organization’s activities, operations, product, or services that can interact with the environment. The environmental aspect of an activity, operation, product, or service is the part of it that creates a possibility for a direct or indirect environmental impact.
Environmental Impact – any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organization’s environmental aspects.
Environmental Objective – overall environmental goal consistent with the environmental policy that the organization sets itself to achieve. Objectives should be measurable so that the organization can verify progress made toward their attainment.
Environmental Target – detailed performance requirement, applicable to the organization or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives.
Significant Environmental Aspect – environmental aspect that has or can have a significant environmental impact.
The EMS group leaders are each responsible for organizing a cross-functional team to perform the evaluation.
When possible, each member of the team should bring a unique perspective to the table.
Consideration shall be given to both normal operating conditions and to emergency operating conditions.
Through a process of brainstorming and information gathering, the cross-functional EMS team shall develop a baseline list of your activities and associated environmental aspects
You should determine significant aspects by applying five criteria to the potential and actual environmental interactions of your activities, products and services.
The criteria shall be used to evaluate the degree and the severity of impacts (either positive or negative) of any interactions on the natural environment, on the organization, and on others.
If, upon applying the criteria, a threshold impact value is exceeded (described below) then the environmental interaction of the specific activity, product or service is considered “significant.”
The criteria for evaluating environmental interactions include:
- Legal and Other Requirements: — is the activity controlled by or otherwise subject to regulations or other requirements to which your organization subscribes?
- Impact to the Environment: — to what degree does the activity potentially alter the natural environment (either positively or negatively)?
- Impact to Mission/Organization: — to what degree does the specified activity potentially disrupt or support operations?
- Financial Impact: — what costs or cost-savings does the activity potentially impose on or provide to the Agency?
- Impact to Community: — to what degree does the activity potentially affect the views of outside interested parties, such as the local community and other federal agencies?
The above criteria (excluding Legal and Other Requirements) are assigned an impact value based on the following scheme.
The impact values include:
- High Impact = 5: The resulting change to the environment, organization, or community is strong and/or has a high likelihood of occurring.
- Medium Impact = 3: The resulting change to the environment, organization, or community is moderate and/or has a moderate likelihood of occurring.
- Low Impact = 1: The resulting change to the environment, organization or community is weak or negligible and/or is unlikely to occur.
For the criterion Legal and Other Requirements, impact values are not assigned. Rather a “Yes” or “No” is assigned reflecting if legal and/ or other requirements apply to this environmental interaction.
Your organisation should assign an impact value (i.e., 1, 2, 3, 4 or 5) to each criterion using the following impact descriptions as general guidelines:
1) Impact to the environment:
- High: Environmental consequences are irreversible or severely disrupting to the ecology or to human health and welfare. Environmental benefits to ecology or to human health and welfare are substantial.
- Medium: Environmental consequences are serious but reversible over time. Environmental benefits to ecology or to human health and welfare are moderate.
- Low: Environmental consequences are noticeable but brief or totally correctable in a relatively short time period. Environmental benefits to ecology or to human health and welfare are minimal.
2) Impact to mission/organization:
- High: Interruption of normal mission operation is likely and severe. Benefit to the organization is mission capability is substantially improved.
- Medium: Interruption of normal mission operation is likely but recoverable without significant repercussions. Benefit to the organization’s mission capability is moderately improved.
- Low: Interruption of normal mission operation is either unlikely or the consequences are very slight or easily corrected. Benefit to the organization is mission capability is minimally improved.
3) Financial impact:
- High: Cost of a fine, control or remediation is over $1 million. Benefit to the organization is over $1 million.
- Medium: Cost of a fine, control or remediation is between $100K and $1 million. Benefit to the organization is less than $1 million and greater than $100K.
- Low: Cost of a fine, control or remediation is less than $100K. Benefit to the organization is less than $100K.
4) Impact to community:
- High: Significant negative (e.g. lawsuit, front-page press coverage) or positive (award) public response is highly likely. Community interest is likely to be persistent and long-term.
- Medium: Public interest is likely to be moderate (e.g. phone-in complaints; back-page press coverage) and not sustained over long-term.
- Low: Public interest is negligible or non-existent.
You should determine the overall impact of each interaction by adding together the scored values of each of the criteria.
You should consider an activity’s potential impact significant if either or all of the following conditions are met:
- The overall impact measures “10” or greater,
- The activity is subject to a legal or other requirement
- Neither of the above conditions is met, but you should nonetheless consider the activity in need of management within the EMS framework.
You should use the relative scores of all significant activities as a basis for prioritization.
“Significant” scores range from 10 to 20.
Higher scored activities indicate that greater resources will be applied to addressing these activities relative to lower scored activities.
The Aspects, Impacts, Objectives, and Targets Identification Form is designed to identify activities and determine the effects of activities and the extent to which the activities will impact the environment.
The form is designed to be completed by a team within each group to determine objective information on the aspects and impacts of the organizational groups’ activities. The details of the form will provide valuable information for prioritizing and determining the order in which allocation of resources will occur.
The form is an on going document what will be reviewed and revised on an annual basis.
The analysis worksheets are designed for you to evaluate operations and rank each identified aspect according to its legal, environmental, financial, organizational, and community impact.
Aspects are determined to be significant aspects and impacts. Although some aspects are not ranked as significant, the teams may develop operational controls as part of our best management practices. Determinations and rankings will be reviewed and revised as needed on an annual basis.
The list of your activities, operations, processes, products, and services and associated aspects and impacts for the EMS groups are updated in the following manner:
- When changes in your activities or operations are proposed (e.g., new activities/operations will be introduced or existing activities/operations will be modified or discontinued), the proponent shall communicate the proposed change to the EMS Management Representatives and Group Leaders in the organization to evaluate potential environmental impacts.
On at least an annual basis, your cross-functional EMS team shall update the list in accordance with any changes in your operations and/or services at facilities and any associated legal or other requirements that may apply to such activities.
On at least an annual basis, the cross-functional EMS team shall review and reevaluate the aspects.
Aspects Identification Procedure:
Significant Aspects Documentation that lists aspects, associated activities, operations, processes, products, and services and EMS group; legal and regulatory requirements, environmental, mission, financial, community, and overall impacts; and a designation of significance.
Identification Form that lists aspects, impacts, objectives, and targets, associated with external and internal activities.
Potential Impacts Effects Analysis (PIEA)
EMS Group Identification Form
EMS Group: _____________________________________
|Aspect||Definition||Examples of Potential Impacts|
|Air emissions||Gas emitted into the air from industrial and chemical processes, such as ODS [CFCs in building chiller systems], VOCs [fugitive emissions from vehicle fueling operations and painting activities], criteria pollutants [facility engine generators], dust, vehicle exhaust, aircraft exhaust, odor.||Air pollution (smog, acid rain, dust, visual impairment)|
Greenhouse gas contribution
|Biological waste generation||Generation/ disposal of biological products that can be infectious or biohazardous, such as sharps, infectious substances and autoclave wastes.||Human health impact|
Biological material dispersal
|Cultural disturbance||An event or circumstance that interrupts the relationship between the environment and cultural resources, such as impacts historic properties, socioeconomic impacts, environmental justice impacts, and visual impacts.||Damage to native American resources|
Damage to archeological resources
Loss of public access to recreational resources
|Ecological disturbance||An event or circumstance that interrupts the relationship between the environment and organisms, such as hydrological alteration, vegetation alteration, habitats, wetlands, threatened and endangered species, invasive species, coastal resources, prime farmlands, soil erosion and food waste.||Migration of indigenous species|
Introduction of non-native species
Species habitat alteration
|Energy consumption||The use of energy as a source of heat or power or as a raw material input to a manufacturing process, including electricity, petroleum products, and alternative fuels.||Greenhouse gas contribution|
|Fuel consumption||The amount of fuel used for gross generation, providing standby service, start-up and/or flame stabilization.||Greenhouse gas contribution|
|Hazardous materials releases||The release of hazardous materials (substances that are harmful to human and environmental health and/or safety in relatively small quantities. Such materials include flammable, combustible, corrosive, reactive, and toxic substances as well as any other substance defined as “hazardous” by the state or federal government) into the environment.||Human health impact|
Hazardous material dispersal
|Hazardous waste generation||The generation of hazardous material (substances that are harmful to human and environmental health and/or safety in relatively small quantities. Such materials include flammable, combustible, corrosive, reactive, and toxic substances as well as any other substance defined as “hazardous” by the state or federal government) into the environment. Examples include degreasing solvents, waste paints, used oil, hazardous batteries [lead-acid, lithium, NiCd], empty chemical containers, fluorescent bulbs.||Hazardous material dispersal|
Human health impact
|Natural resource consumption||The consumption of a natural resource (a naturally occurring material such as coal, wood and minerals that can be exploited by people).||Resource depletion|
|Noise emissions||The emissions of human-created noise harmful to health or welfare such as aircraft operations, vibration, visual impairment, light emissions.||Noise damage|
|Non-hazardous waste generation||The generation of waste that is non-hazardous and does not pose substantial or potential threats to public health or the environment such as (scrap, pallets, cardboard, paper, rags, construction debris||Solid material dispersal|
|Radiation emissions||The emissions of radiation (energy from heat, light, sound) that is emitted from operations such as the use/disposal of sealed sources, use/disposal of isotopic solutions, and generation of ionizing or nonionizing radiation.||Radiation damage|
|Oil spills/releases||The spill or release of oil into the environment.||Species habitat alteration|
Hazardous material dispersal
|Stormwater runoff||Surface water runoff that flows into storm sewers or surface waters.||Surface water contamination|
|Toxics substances releases||The release of poisonous substances known or believed to be harmful to people’s health, often producing chronic, irreversible physical problems and possibly harming subsequent generations including PCBs, asbestos and lead based paint.||Human health impact|
Toxics contamination or addition to air, land, waterway
|Wastewater discharge||The discharge or release of wastewater into the environment from operations including painting operations, metal etching/plating, small photographic activities, vehicle maintenance areas, sewage, and storm water.||Groundwater contamination|
Sedimentation of water courses
|Water consumption||The consumption of water for daily operations.||Resource depletion|
|Water quality||The quality of water provided to staff for drinking.||Human health impact|