common environmental management system gaps—and what to do about them

Environmental Quality Management / DOI 10.1002/tqem / Autumn 2011 / 1

© 2011 Wiley Periodicals, Inc.Published online in Wiley Online Library (wileyonlinelibrary.com)DOI: 10.1002/tqem.20304

Over the years, we

have conducted a

fair number of envi-

ronmental manage-

ment system (EMS)

audits and gap anal-

yses. And we have

found many of the

same EMS weak-

nesses over and over again. We have seen these

EMS gaps at facilities within a range of organiza-

tions, in different regions, and across a broad

spectrum of industries.

This article describes some of the common

EMS gaps we have identified and offers sugges-

tions on how to close them. We hope this discus-

sion will help EMS managers assess the complete-

ness and effectiveness of their environmental

management systems, while also providing a few

pointers to organizations that are considering

implementation of an EMS.

About This ArticleThis article is part of an occasional series that

addresses aspects of EMS design and implemen-

tation. It follows prior articles by Franklin Giles

entitled “EMS Improvement Through Effective Del-

egation of Environmental Responsibilities,”1 “Inte-

grating Managers into Environmental Management

Systems,”2 “Adding

Value to Your Or-

ganization Through

EMS Implementa-

tion,”3 and “Assess-

ing the Effectiveness

of Your Environ-

mental Management

System.”4

Some Common EMS Gaps: An OverviewIn this article, we highlight some commonly

observed EMS gaps. Our list is far from exhaus-

tive, but it offers a useful starting point for iden-

tifying and remedying EMS shortfalls.

Many of the gaps we see most frequently

involve environmental impacts, objectives, and

targets. In this context, we have identified three

related areas where management systems often

fall short: identifying environmental aspects

and impacts; setting effective targets and objec-

tives for addressing the environmental impacts

that have been identified; and creating effective

action plans for achieving those targets and

objectives. Gaps in these three areas are often

found together.

Franklin Giles and Kirstin Dolan

Common Environmental Management System Gaps—and What to Do About Them

Enhancing the completeness and

effectiveness of your EMS

• soil and groundwater contamination caused

by leakage from the floors of aboveground

storage tanks;

• noise, light, odors, bad tastes in the water,

and other public nuisances; and

• inefficient energy and resource use.

If a facility relies entirely on regulations to de-

fine environmental aspects and impacts, it risks

overlooking potentially important impacts that

are not subject to specific regulatory standards.

Stakeholders and Their ConcernsFacilities may fail to include some relevant

environmental aspects and impacts because they

have not identified all of their stakeholders or

clarified all of their stakeholders’ concerns. Stake-

holders include all internal or external groups

or individuals who expect your facility and your

EMS to deliver things they value.

For example, banks and other creditors that

hold real estate as collateral for loans will be inter-

ested in any environmental condition that could

impact property values. Thus, in the view of these

stakeholders, any type of soil or groundwater con-

tamination that impacts real estate values could be

a significant environmental impact, even if it does

not happen to be regulated at the site in question.

In this case, the facility’s list of environmental

impacts should include all areas and operations

that involve the potential for soil or groundwater

contamination, such as wastewater sumps and

trenches, containment pits, and outdoor fuel

storage and transfer areas.

Nonproduction and Support OperationsAn effective EMS should address the signifi-

cant environmental impacts associated with all

operations and activities present at a site, not just

the high-profile ones. Facilities often overlook

nonproduction or support operations as sources

of potential environmental impacts.

Another common area of weakness involves

the interaction of environmental and quality

management systems. Although the two systems

can be combined effectively, facilities may fail to

fully consider all EMS elements when integrat-

ing environmental management into an existing

quality management system.

In the sections that follow, we discuss these

gaps in more detail.

Identifying Environmental Aspects and ImpactsSetting and achieving effective EMS objec-

tives and targets is a multistep process that be-

gins with identifying the facility’s environmental

aspects and potential

impacts. It is difficult

for an environmental

management system

to be effective with-

out a complete list of

impacts, and it is im-

possible to prevent or

correct impacts that

are not identified. Any

failure to identify impacts will lead to an incom-

plete list of targets and objectives.

Impacts That Are Not Subject to Specific Regulatory Standards

Facilities in the United States sometimes

focus so completely on regulatory compliance

requirements that they overlook other potential

impacts that are not subject to specific regulatory

standards. Even though certain types of environ-

mental impacts may not be addressed by regula-

tion in a given facility’s community, they can

still degrade the environment, reduce property

values, and displease stakeholders. Examples of

such impacts include:

• soil contamination caused by seepage from

in-ground sumps, trenches, and piping;

Franklin Giles and Kirstin Dolan2 / Autumn 2011 / Environmental Quality Management / DOI 10.1002/tqem

An effective EMS should address the significant environmental impacts associated with all operations and activities present at a site, not just the high-profile ones.

Consider, for example, an objective worded

as follows: “Achieve full compliance with all

environmental permits.” This is a worthy goal,

and one that might well appear in your facil-

ity’s EMS, but it is somewhat vague. This objec-

tive is also so broad that it may be difficult to

figure out exactly what actions you need to take

to meet it.

A more specific objective might be “Submit all

reports required in the facility’s environmental

permits by the specified deadlines.” This target

is specific enough to suggest the steps that you

would need to take in order to reach it.

More specific still would be an objective

stating, “Prepare and

submit all reports as

described in the EMS

Compliance Calen-

dar.” This is a very spe-

cific target, one that

almost anyone would

understand how to

reach. The main chal-

lenge here is that your

facility would need to prepare a compliance cal-

endar listing all the required reports and their due

dates as part of setting this objective.

In general, specific targets and objectives re-

quire more effort and preparation than do broad

and vague ones. But the effort can really pay off.

■■ Measurable Targets and Objectives“Measurable” means that you can clearly per-

ceive progress toward, and achievement of, the

objective. Measuring progress allows facility staff

to experience a feeling of achievement and thus

helps keep motivation at a high level.

Measurability is also key to tracking perfor-

mance. Measuring progress helps you recognize

when you need to improve your game in order

to hit the target. Effective measurement units

include amounts, numbers, and time.

Activities such as maintenance, quality con-

trol, research and development, janitorial ser-

vices, and warehousing may not be seen as

directly related to the facility’s main product or

purpose. Nonetheless, the environmental im-

pacts of these activities can be significant.

Setting Effective Targets and Objectives Facilities often fail to set effective targets and

objectives for addressing the environmental as-

pects and impacts they have identified. Creating

appropriate targets and objectives has long been a

challenge for organizations in many contexts be-

sides EMS development. As a result, quite a bit of

research has been done looking for better ways to

accomplish this task, and some useful approaches

have been proposed.

SMART: A Guide to Creating Goals and Objectives

One effective approach to setting targets

and objectives uses the acronym SMART. The

SMART approach was originally presented by

management writer George T. Doran in an article

entitled, “There’s a S.M.A.R.T. Way to Write Man-

agement’s Goals and Objectives.”5

SMART is intended as an acronym for

the qualities that characterize effective targets

and objectives. Over the years, several com-

mentators have offered variations on these

component attributes. In general, however, it

is accepted that SMART stands for specific, mea-

surable, attainable, relevant, and time-bound.

Let’s see how these qualities apply to EMS tar-

gets and objectives.

■■ Specific Targets and Objectives“Specific” means that targets and objectives

should be clear and unambiguous, with a useful

level of detail. Dr. Doran advised making targets

as specific as possible, since such targets lend

themselves to solution development.

Environmental Quality Management / DOI 10.1002/tqem / Autumn 2011 / 3Common Environmental Management System Gaps

In general, specific targets and objectives require more effort and

preparation than do broad and vague ones. But the effort can

really pay off.

■■ Relevant Targets and ObjectivesIt’s not enough for targets and objectives to

be specific, measurable, and attainable. They

also need to get the job done. This is one key

meaning of “relevant.” If targets are too easy,

or if they do not lead to the needed results,

then you will fail to make actual progress.

The best EMS targets and objectives are clearly

connected to environmental policy and stake-

holder needs.

Another factor that makes targets and objec-

tives relevant involves aspirations. Targets and

objectives are more relevant when they express

your organization’s beliefs and desires.

■■ Time-Bound Targets and Objectives“Time-bound” means that every target and

objective should have associated deadlines and

milestones. Most people need time frames to mo-

tivate action and establish short-term priorities.

Somehow, you never reach objectives that don’t

have deadlines.

In this context, it is crucial to understand

that every stakeholder expectation has a dead-

line, whether explicit or not. That deadline may

be the date on which the stakeholder runs out

of patience with a situation and decides to take

action. Failing to acknowledge a time frame for

stakeholder-related goals and objectives will not

prevent you from crossing those stakeholder

deadlines. It is important to set deadlines and

interim milestones for all targets and objectives

based on your best understanding of your stake-

holders’ needs.

Meeting the ChallengeDeveloping appropriate EMS targets and ob-

jectives can be a challenge for many organi-

zations. Using SMART, or one of the other

approaches that have been described by manage-

ment experts, can help your organization address

this important facet of your EMS.

Consider a goal stated as follows: “Our exter-

nal stakeholders are satisfied with our environ-

mental, health, and safety performance.” This

goal sounds noble, but how will you determine

whether you are meeting it? Checking local court

dockets to make sure there are no lawsuits with

your name on them is not very motivating. A

more measurable indicator, one that you could

track in-house, would be much more useful.

How about this goal? “Reduce the number of

odor complaints to no more than one per quar-

ter.” This is a measurable objective. It has a metric

(the number of odor complaints) that is easy to

understand and simple to track.

Another mea-

surable objective

might be “Reduce the

amount of time that

offgas is being sent to

the flare.” The process

being measured here

is within the facility’s

control, which helps

strengthen the moti-

vational effect.

■■ Attainable Targets and Objectives“Attainable” means that the objective can be

reached in a practical way. Setting unattainable

goals is a recipe for failure.

Some of the targets and objectives included in

your EMS may be mandated by regulatory agen-

cies or corporate stakeholders. Thus, you may

simply have to assume that they are attainable.

Even in the case of objectives imposed by

others, however, it is possible to improve at-

tainability. You can generate significant value

by setting intermediate targets and laying out

the specific steps needed to reach the final ob-

jective. Having a clearly described process can

help your team see how to attain challenging

targets and objectives.


It is important to set deadlines and interim milestones for all targets and objectives based on your best understanding of your stakeholders’ needs.

ers must also give their people encouragement and

permission to pursue the action plan energetically,

with the aim of improving environmental results.

This means that managers must use their influ-

ence actively—through daily conversations, busi-

ness decisions, and even body language.

Information and DocumentationA good action plan will include the informa-

tion or documentation needed to complete the

action, or at least describe where these can be

found. Having the right information is crucial for

completing an action plan. Large or long-term

action plans may need their own records, files,

databases, or even in-

formation technology

support in order to be

completed efficiently.

Clear Roles and Responsibilities

Clearly assigned

roles and responsibili-

ties are crucial to mak-

ing an action plan effective. Even a specific,

measurable, and practical plan will fail if no one

thinks it’s their job to carry it out.

Establishing roles and responsibilities is a

key area where management support will likely

be needed. This is particularly true in the case

of large or long-term action plans. Some people

whose help you need will likely require permis-

sion and encouragement from their managers

to put in the time necessary for completing the

action plan.

A Fair Plan Development ProcessSome interesting research reported in Harvard

Business Review indicates that coworkers will

more readily commit to a decision or an action

plan if they believe that the process used to make

the decision or develop the plan was fair.7

Creating Effective Action Plans EMS facilities often fail to develop solid action

plans for meeting the environmental objectives

and targets they have set. As discussed earlier,

well-developed targets and objectives lend them-

selves to the development of successful action

plans. Some of the same features that make for

effective targets and objectives are also key to ef-

fective action plans.

SMART Action PlansThe SMART attributes discussed earlier with

respect to targets and objectives also apply to ac-

tion plans. Action plans need to be:

• specific about what is to be accomplished, the

sequence of planned actions, and how the tar-

gets and objectives are to be reached;

• measurable, meaning there is a clear way

to tell whether progress is being made (it is

probably best if the progress measurement in

the action plan is consistent with the met-

rics used to track overall progress toward the

planned targets and objectives);

• attainable, meaning that the steps specified in

the plan can be completed in a practical way

with the available resources;

• relevant to the particular targets and objec-

tives that have been set; and

• time-bound, with clear milestones and dead-

lines for each important step in the action

plan.

In addition to these SMART attributes, other el-

ements that are important for effective action plans

are highlighted in the paragraphs that follow.

Management SupportFor an action plan to be successful, you need to

have the organization’s leaders on your side.6 This

involves more than gaining formal management

approval and a budget for the action plan. Manag-


A good action plan will include the information or documentation needed to complete the action, or at least describe where these can

be found.

shortchanged in these kinds of integrated plans

typically include:

• Environmental aspects and impacts: Chal-

lenges not related to product quality or

customer desires usually are excluded from

consideration by quality management sys-

tems. This means that issues such as non-

process-related environmental impacts, envi-

ronmental reporting and recordkeeping, and

the desires of noncommercial stakeholders

may not fit very well into the typical QMS

framework.

• Regulatory compliance: Quality management

systems typically emphasize product quality

and product specifications, so they tend to

focus on commercial or contract require-

ments. Other categories of stakeholder ex-

pectations, such as government regulations,

usually are not addressed. Some companies

have finessed this issue by redefining en-

vironmental compliance as a “product.” It

might make more sense for your organization

to ensure that the integrated management

system includes an effective environmental

compliance program.

• Management of change: Integrated systems

commonly lack a process to assess the envi-

ronmental implications of proposed changes

to facility products and operations. Keeping

up with changes in regulatory requirements

can also be a challenge.

Uncovering Gaps With EMS Audits and Analyses

One approach to uncovering gaps in your

environmental management system is to conduct

a thorough EMS audit that compares your man-

agement system line-by-line against the standard

your EMS was designed to meet. This type of

audit differs from internal audits of environmen-

tal, health, and safety or security compliance.

A fair process is one in which the individu-

als involved know that their input was heard;

the thinking behind the plan is explained; and

expectations, performance standards, and new

responsibilities are clearly defined. A fair process

does not require consensus decision making or

giving everyone a vote. However, it is important

to ensure that everyone involved knows they

have been heard, that the plan is well thought

through, and that the rules going forward have

been clearly laid out.

The last factor is especially important if the

action plan requires

organizational or

work-process changes.

If your action plan is

not perceived as hav-

ing been developed

through a fair process,

the people responsible

for taking the required

action may not be committed enough for the

plan to succeed.

Integrating EMS Elements With a Quality Management System

Many facilities will already have an estab-

lished quality management system (QMS) in

place when they begin to develop an environ-

mental management system. For these facilities,

it can be very practical and efficient to integrate

management systems or leverage the original

QMS to cover EMS components. Some quality

management system elements (such as docu-

ment management and annual performance

review processes) can integrate very readily with

an EMS, as long as environmental issues get ad-

equate attention.

The challenge comes when the integrated

system does not fully incorporate EMS aspects

and elements but remains too quality-focused.

In our experience, the EMS elements that get


Many facilities will already have an established quality management system (QMS) in place when they begin to develop an environmental management system.

some practical tips on making improvements.

We’re confident that the effort invested in iden-

tifying and closing gaps in your EMS will pay off

handsomely.

Notes1. Giles, F. (2004, Winter). EMS improvement through effec-tive delegation of environmental responsibilities. Environ-mental Quality Management, 14(2), 29–37.

2. Giles, F. (2005, Summer). Integrating managers into en-vironmental management systems. Environmental Quality Management, 14(4), 31–38.

3. Giles, F. (2006, Winter). Adding value to your organization through EMS implementation. Environmental Quality Man-agement, 16(2), 1–6.

4. Giles, F. (2008, Winter). Assessing the effectiveness of your environmental management system. Environmental Quality Management, 18(2), 1–6.

5. Doran, G. T. (1981). There’s a S.M.A.R.T. way to write management’s goals and objectives. Management Review, 70(11), 35–36.

6. For more information on this topic, see the article cited in note 2.

7. Kim, W. C., & Mauborgne, R. (2003, January). Fair process: Managing in the knowledge economy. Harvard Business Re-view, 81(1), 127–136.

Whether done in-house or by expert contrac-

tor resources, an EMS audit should identify every

part of your environmental management system

that falls short of your chosen EMS standard.

Outside experts can offer added value by provid-

ing comparisons to best practices as well.

Concluding ThoughtsThis article highlights some gaps we have ob-

served repeatedly in environmental management

systems that we have audited and analyzed at a

wide range of facilities in many different indus-

tries. Our discussion also suggests some ideas for

closing these gaps.

An effective EMS can help your organization

improve environmental performance. It can also

add substantial value. Ensuring that your EMS

meets all your management system expectations

can help maximize the value obtained.

We hope this article gives you some ideas for

points to check in your own EMS, along with


Franklin Giles is a technical manager in the Reston, Virginia, office of WSP Environment & Energy. He has a BS in bio-chemistry from UCLA and an AM in chemistry from Harvard University. He has worked in environmental management, auditing, and management systems implementation since 1990.

Kirstin Dolan is a senior project director in the Reston, Virginia, office of WSP Environment & Energy. She has more than 20 years of experience conducting environmental site assessments; regulatory compliance audits; and environmental, ChemStewards®, and Responsible Care® management system evaluations.

common environmental management system gaps—and what to do about them

Documents