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FLEXO Magazine : March 2009
PLANTS & PROCESSES 10 KEY ELEMENTS The 10 key elements of a SMS are: Sustainability Policy. The core activity of the SMS is the sustain- ability policy. A sustain ability policy is top management's declaration of commitment to being sustainable. The written policy is clearly understood by all employees within the facility and provides clear direction to managers and employees on all issues. A sustain ability policy is simple and easy to understand and appropriate to the ac- tivities, products, and services offered by a facility. Additionally, the policy is clearly communicated to all customers and suppliers. The policy sets the tone for the direction of the company. It must be signed by a responsible party (e.g. owner, CEO, President) and made publicly available, (for example, having policy posted on a website or in a reception area, published or available upon request). The Sustain ability Policy should set out the organization's com- mitment toward adoption of sustainable business practices and include the following commitments: . Compliance with environmental, health and safety requirements. . Continuous improvement, including areas not subject to regulation. . Pollution prevention that emphasizes source reduction, re- use and recycling. . Sharing information on sustainability performance with ex- ternal stakeholders. Regulatory Requirements and Voluntary Undertakings. The organization must provide a means to identify, explain, and com- municate all regulatory requirements and voluntary actions to all employees, on-site service providers, contractors, and anyone else whose work could affect the organization's ability to meet those requirements and actions. Regulatory requirements include statutes, regulations, permits, and legally enforceable agreements made with organizations such as the Occupational Safety and Health Administration (OSHA), U.S. Environmental Protection Agency (U.S. EPA) and U.S. Department of Labor (DOL). The SMS should include procedures for ensuring the organiza- tion meets these requirements and any voluntary undertakings. The SMS should also specify procedures for anticipating changes to regulatory requirements-including new requirements that may apply as a result of changes in operations or changes to the regula- tions themselves-and incorporating these changes into the SMS. Objectives and Targets. The SMS needs to establish specific objectives and targets. Targets may include: · Achieving and maintaining compliance with EHS requirements. · Environmental performance demonstrating continuous im- provement in regulated and non-regulated areas. · Pollution prevention that emphasizes source reduction. · Sharing information with external stakeholders on environ- mental performance against all SMS objectives and targets. · Reducing the impact of support functions, such as transpor- tation and office waste. · Fair labor practices. The SMS should establish appropriate timeframes to meet these objectives. These should be documented and updated as technology and requirements change or as modifications oc- cur in activities and structures within organizations. The SGP Partnership requires this be done annually. Structure and Responsibility. The organization should ensure it is equipped with sufficient personnel and other resources to meet the objectives and targets of its SMS and spell out proce- dures and steps for achieving those objective and targets. For example, it should define the compliance roles and responsibili- ties of personnel, specify how they and management will be held accountable for achieving and maintaining compliance, and de- scribe how sustainability performance and compliance informa- tion will be communicated to relevant employees, onsite service providers, contractors, and other external stakeholders. Operational Control. The SMS should identify and provide for the planning and management of all the organization's operations and activities with a view to achieving the SMS objectives and tar- gets. For example, a facility's preventative maintenance program plays an important role in demonstrating compliance with air regu- lations by showing the required maintenance activities are com- pleted in a timely manner. Preventative maintenance also extends the life of the equipment, which minimizes operating downtime. Corrective and Preventive Action and Emergency Procedures. The organization, through its SMS, should establish and maintain documented procedures for preventing, detecting, investigating, promptly initiating corrective action, and reporting any occur- rence that may affect the organization's ability to achieve the SMS objectives and targets. Such measures should pay particular atten- tion to incidents that may have an effect on compliance with EHS regulations and labor requirements. Examples of such situations include equipment malfunctions, operator errors, and accidental releases of hazardous substances. The SMS should also establish procedures for mitigating any adverse impacts that may be as- sociated with accidents or emergency situations and for ensuring similar incidents are avoided. The SMS should include procedures for tracking any preventive and corrective actions that are taken. If the violation or incident resulted from a weakness in the system, the root cause should be identified and the SMS should be updated and refined to minimize the likelihood of such problems recurring in the future. Although not required by the SGP Partnership, the SMS should also, to the extent possible, provide for the testing of emergency procedures. Training, Awareness, and Competence. The SMS should estab- lish procedures to ensure that all personnel (including employees, The concept of a SMS is similar to an Environmental Management System (EMS) except it is more encompassing than addressing just Hgreen" issues. _ FLEXO MARCH 2009 www.flexography.org
Sustainable Winter 2009