A guideline for initiating an environmental management system in academia

Managing environmental concerns in an academic environment poses unique challenges to colleges and universities. Many college EHS professionals face an uphill battle to promote environmental improvement in an organized, systematic, and sustainable fashion - an Environmental Management System (EMS) is designed to do just that. Some inherent difficulties encountered in an academic setting include 1) lack of management support and 2) the perception that colleges do not have major environmental compliance issues (contributing factor to #1). By identifying issues unique to academia and differences in perception between EHS professionals and academic senior management, chances for successfully initiating/implementing an EMS are improved. Environmental Management Systems (EMSs) are being promoted as the method to effectively manage environmental issues on college campuses in the US. The Environmental Protection Agency (EPA) has made it clear that they expect colleges and universities to maintain compliance with environmental regulations and they feel an EMS is the preferred method for long-term, sustainable environmental compliance. Although there are several guidelines/models (see references & attachment #2 ) for implementing an EMS, many colleges never make it to the planning stage of an EMS. There is no guideline for getting an EMS off the ground - or, initiating an EMS. The key element to successfully initiating an EMS is management support and this paper will attempt to identify relevant perceptions of academic senior management on the topic of environmental management. The methodology involves surveying academic EHS professionals and senior managers on a variety of issues related to management support and environmental performance. It is intended to identify unique characteristics of academia, allowing EHS professionals to better prepare for successfully initiating an EMS in their respective institutions. The survey was structured to ask the same questions of academic EHS professionals and senior management in order to identify gaps in opinions/perceptions relative to each question category. The detailed survey questionnaire analysis, including the gap analysis is provided in Attachment 1. An ISO 14001 EMS basic model is provided as a basic reference in Attachment 2. A comparison, contrast chart between academia and industry is provided as Attachment 3 and Opportunities/Tips for Initiating an EMS is provided as Attachment 4. The actual questionnaires used in the survey for EHS professional and senior management are provided in Attachments 5 & 6. The survey results indicate some interesting differences in perceptions between EHS professionals and senior management in the academic setting. The largest gap in opinion dealt with the question of How much of a challenge to implementing an EMS is lack of commitment among. The response of top-level management created the largest discrepancy or gap between EHS professionals and senior management with EHS professionals perceiving top-level commitment as a much larger challenge than senior management. These results beg the question: why the big difference in response? Is senior management naturally biased on this question or do they perceive themselves as being committed to environmental management issues? This is an important issue that must be approached by each individual college/university implementing an EMS is the goal. Informed management is a key element and many senior managers expressed the opinion that they weren\u27t aware of the potential environmental impacts of their campuses. The survey also indicated that managers are aware of environmental concerns but expressed the opinion that limited resources, lack of enforcement and environmental issues not being related to the core mission of the college as important factors in not giving environmental issues a high priority. A clear result of the survey indicates that both EHS professionals and senior management consider government (EPA) regulations to be an important motivator for implementing an EMS and improving environmental performance. It would be admirable if the culture and climate of academia would inherently embrace environmental issues based on ethical and morale grounds or doing the right thing. However, it is clear that academic senior administration is most motivated by the threat of government regulatory actions and potential for negative impact on their image. This should not surprise anyone in the academic field of EHS, but it is important that EHS professionals not underestimate the power of regulatory pressures. The threat of fines, bad press and potential legal actions genuinely concern senior managers in the academic sector. EHS professionals can and should use this insight, knowing the window of opportunity created by EPA will not last forever. It can be used as leverage to initiate environmental improvements, as needed, including the implementation of an EMS. It is an interesting difference to note: cost effectiveness was not considered an important factor, while limited resource \u27s was considered an important factor by senior management. This indicates the need to justify an EMS based on its own merit or relative importance within the institution, rather than justifying it on a cost effective basis. Any proposal to initiate an EMS must compete for the limited resources available to academic management. Justification of an EMS based on cost effectiveness may not be as effective as it is in the industrial setting. The survey also indicates (from the senior management perspective) that integrating environmental issues into the culture and mission of an educational institution is an important factor in sustaining an EMS. A significant discrepancy was found in the responses to the question of how much of a challenge to implementing an EMS is. The response of staffing resources and time clearly demonstrates EHS professional\u27s perception that they are inadequately staffed, funded, and resourced as compared to the senior management response. It may be apparent to EHS professionals (and EPA) that adequate resources are not being provided, but it is abundantly clear that management does not agree with this perception. A key factor for EHS professionals - has the point been made to document and communicate this information to management? EPA has specifically cited colleges for inadequate EHS resources and they may hold senior management accountable for not providing adequate staffing/resources. A key element of any effective EMS is providing adequate resources to do the job. Management and EHS professionals need to evaluate staffing and resources dedicated to EHS in an effective, meaningful manner. Benchmark results of the Campus Safety, Health & Environmental Management Association (CSHEMA), indicate an average EHS staffing level of 1 FTE per 2000 faculty, staff and students. Other suggestions for documenting staffing needs include an environmental audit (including staffing levels) by an outside consultant, an internal audit of the EHS program to document resource needs or a review of the program by environmentally experienced legal counsel. The issue of accountability is a primary concern in initiating or implementing an EMS. Lines of communication with faculty, staff and students need to be established in order to assure the transition to an EMS has buy-in from stakeholders who are most effected. Both EHS professionals and management strongly agree on the importance of this issue. The difficult issue: establishing effective methods of accountability for tenured faculty. Professors have historically retained a degree of autonomy as part of the culture of higher education and the premise of academic freedom. Realizing this, successfully approaching faculty and getting buy-in, to some degree, is crucial. Performance measurement and accountability are integrally linked within the EMS. If faculty/staff are not accountable for performing, it will not happen. Management support is a key factor in this area; meaningful and consistent management review of the EMS (including feedback to stakeholders) is essential. Finally, this thesis has been a work of both passion and frustration. For those in the field of EHS, I don\u27t need to explain. EHS, in most cases, is not given the priority it deserves in the academic world - simply put, it is not perceived as critical to the mission of higher education. EPA has found substantial environmental problems in academia, but they are only concerned with environmental issues (the E in EHS). EHS professionals are also responsible for the H&S (Health & Safety) in EHS and those issues, although not discussed in this paper, creates another set of questions/concerns that should be addressed on college campuses. The bottom line for successful EHS programs: someone fairly high up in the organization needs to CARE about EHS