MARCH 2021

FTA GUIDEBOOK OF
BEST MANAGEMENT PRACTICES
FOR THE DEVELOPMENT OF AN

Environmental and Sustainability

Management System (ESMS)

FTA GUIDEBOOK OF BEST MANAGEMENT PRACTICES

This guidance document does not have the force and effect of law and is not meant to 1
bind the public in any way. The document is intended only to provide clarity to the public

FTA ESMS RESOURCE SERIES

FOR THE DEVELOPMENT OF AN ESMS
regarding existing requirements under the law or agency policies. Recipients or sub -
recipients should refer to FTA’s statutes and regulations for applicable requirements.
TABLE OF CONTENTS
1. Introduction ........................................................................................................................................................ 3
1.1 ESMS Online Program .......................................................................................................................................... 3
1.2 ESMS Institute....................................................................................................................................................... 3

2. Resources ............................................................................................................................................................ 3
2.1 Whitepapers/PowerPoints/Webinars ................................................................................................................ 3
2.1.1 “What” and “Why” of an ESMS ........................................................................................................... 3
2.1.2 Nine Steps to Developing a Foundation for a Successful ESMS ..................................................... 3
2.1.3 Sustaining Your ESMS......................................................................................................................... 4
2.1.4 Root Cause/5 Whys ............................................................................................................................. 4

3. Best Management Practices

3.1 Development (Planning) ...................................................................................................................................... 4
3.1.1 Benefits of Adopting an ESMS — MTA, TriMet .................................................................................. 5
3.1.2 Framework of Organization — LA Metro............................................................................................ 6
3.1.3 Issues Inside and Outside your Organization — LA Metro ............................................................... 7
3.1.4 Senior Management — Leadership and Commitment Pledge – SORTA......................................... 7
3.1.5 Senior Management — Mission/Vision Policy Statement — LA Metro........................................... 9
3.1.6 Senior Management Commitment — MTA, LA Metro .................................................................... 10
3.1.7 Contributions, Obligations and Authorities — LA Metro, MTA ....................................................... 11
3.1.8 Developing Environmental Characteristics and Influences – MTA ............................................... 20
3.1.9 Legal Requirements — LA Metro...................................................................................................... 21
3.1.10 Integrating ESMS into Agency Strategic Planning and Goals and Funding — LA Metro ............. 22
3.1.11 Developing Goals and Targets — MTA, TriMet, BART, MARTA....................................................... 23

3.2 Implementation (Doing) .................................................................................................................................... 26

3.2.1 Providing Competent, Knowledgeable Staff with the Tools to Develop, Implement and
Maintain an ESMS – SEPTA, SORTA................................................................................................ 26
3.2.2 Effective System for Communicating — MTA, SORTA.................................................................... 32
3.2.3 Planning and Managing Emergencies — PAAC .............................................................................. 34

3.3 Maintenance (Checking/Acting) ..................................................................................................................... 35

3.3.1 Examination, Investigation, Evaluation — CapMetro, MTA ............................................................. 35
3.3.2 Examination, Investigation, Evaluation/Calibration — BART, MTA ................................................ 37
3.3.3 Appraisal of the ESMS — SORTA...................................................................................................... 40
3.3.4 ESMS Review by Management — MTA ............................................................................................ 41
3.3.5 Nonconforming Practices and Remedial Action — MTA................................................................ 43
3.3.6 Enhancement of the ESMS — SEPTA............................................................................................... 45

4. Closing — Living Document ................................................................................................................. 45

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FOR THE DEVELOPMENT OF AN ESMS
 The purpose of this Guidebook is to provide you with a single source reference to learn about
the important elements for developing, implementing and maintaining an Environmental and
Sustainability Management System (ESMS).
This Guidebook acts as a library access point for you to retrieve, study and implement
“Best Practices” associated with developing, implementing and maintaining a successful ESMS.
These examples represent a small sample, and in many cases, only provide a small portion of the
full documentation needed so that you can see what is expected to meet the ESMS requirements.
To fully understand how the “best practices” work in an ESMS, FTA and Virginia Tech recommend
you access ESMS development program information available online.

1. Introduction
1.1 ESMS Online Program
For more comprehensive information on the components of an ESMS, it is recommended you take the FTA
online Introductory ESMS course available through the National Transit Institute.
https://www.ntionline.com/environmental-and-sustainability-management-systems-esms-introductory-
online-course/

1.2 ESMS Institute

The ESMS institute, when offered, provides guidance and tools to successfully develop, implement, maintain
and sustain an ESMS for your organization. Virginia Tech Institute Website: http://www.cpe.vt.edu/esms/

2. Resources
2.1 The following whitepapers have been developed and are available on the
FTA website
https://www.transit.dot.gov/regulations-and-programs/environmental-programs/environmental-and-
sustainability-management-systems

2.1.1 “What” and Why” of an ESMS

You may be considering activities needed to develop an ESMS but you are not sure where to start. The
whitepaper summarizes information on the foundation associated with the development of an effective
environmental and sustainability system. This information will serve as a helpful guide in your decision to
move forward.

2.1.2 Nine Steps to Developing a Foundation for a Successful ESMS

Building an ESMS might seem like a daunting endeavor, but it need not be. Taken in steps, it is a journey that
can be successful for any organization. The whitepaper summarizes the steps that are important for building a
strong foundation needed for the successful development of an effective ESMS.

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2.1.3 Sustaining your ESMS
Once an ESMS is developed and implemented, organizations need to sustain and maintain their ESMS. Tools
and information to keep the ESMS functioning in operations as the organization moves forward though time are
essential. This information is not only useful to organizations that have an existing ESMS program, but may also be
beneficial for those in the early stages of establishing an ESMS. The whitepaper is useful for organizations that have
existing or nascent ESMS programs.

2.1.4 Root Cause/5 Whys

Five whys (or 5 Whys) is an iterative, interrogative technique used to explore the cause-and-effect relationships
underlying a particular problem. The primary goal of the technique is to determine the root cause of a defect or
problem by repeating the question “Why?” Each answer forms the basis of the next question. The “five” in the name
derives from an anecdotal observation on the number of iterations needed to resolve the problem. The whitepaper
provides information to assist in identifying root causes associated with nonconforming practices identified within
your ESMS.

3. Best Management Practices

The remainder of this Guidebook provides examples and excerpts of transit-oriented ESMS best practices provided
by existing transit organizations. The best practices are divided into three sections:
• DEVELOPMENT which corresponds to the planning phase of getting organized and ready to start.
• IMPLEMENTATION which corresponds to the doing phase by performing the tasks necessary to
build your ESMS.
• MAINTENANCE which corresponds to the checking and acting phase where the actions implemented
are reviewed for effectiveness and actions are taken to improve ESMS performance.

Please note that in some cases document examples may contain items related to ISO 14001:2015 which are
copyrighted in association with FTA/VT ESMS Institutes and may not be reproduced without the consent of the
International Organization for Standardization www.iso.org OR without the consent of the respective organizations
identified in this Guidebook.

3.1 Development (Planning)

As with most sound management activities, it is best to have a plan for developing, implementing and revising your
ESMS so that you can maximize your efficiency in carrying out the functions while improving morale, strengthening
organizational performance, meeting the needs of customers, saving money and improving the environment.

In many cases it is best to identify the benefits of a program so that you can increase understanding of the purpose
of the program and obtain buy-in from members of your organization. Two examples are provided below which
represent documented benefits from the Maryland Transit Administration (MTA) and the Tri-County Metropolitan
Transportation District of Oregon (TriMet).

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3.1.1 Benefits of Adopting an ESMS

MTA
There are many potential benefits associated with adopting an ESMS at the Cromwell facility.
Benefits that are or may be significant to MTA include:
Integrated Environmental Policy into the MTA Mission
Reduced environmental compliance incidents
Improved state and federal regulator relationships
Reduced waste and pollution
Increased fuel economy
Enhanced public image
Improved internal and external communications
Improved employee awareness of potential environmental impacts of work activities
Sustainable transportation service and business practices that reduce costs and resource usage
Increased staff productivity and safety
Transit and Regional Leadership
Compliance monitoring through use of the MTA Geographic Information System (GIS)

Source: MTA, FTA FINAL REPORT, Page 29, 2017

Contact: Robert Frazier, Environmental Manager
1515 Washington Boulevard, Baltimore, MD 21230
Phone: 410-454-7317
Email: [email protected]

TriMet

Cost savings from reduced energy/gas use

Resource conservation
Improved environmental compliance
Increased awareness of chemical use
Created a framework to be implemented at other facilities
Increased operating efficiency
Employee collaboration across agency divisions
Reduced operating costs
Enhanced document controls and document management
Reinforced image with the public
Employee awareness of environmental issues and responsibilities
Ensures that all local, state and federal regulations are met

Source: FTA Final Report, TriMet section, Page 58, 2017

Contact: Kimberley Angove [email protected]
4012 SE 17th Ave, Portland, OR 97202
Phone: 503-962-4831
Email: [email protected]

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3.1.2 Framework of Organization – LA Metro
One of the first items to understand is the framework in which your organization is operating. This includes
understanding what issues affect your organization in a good or bad way. These issues can include environmental
factors, physical location factors that affect how you do business, the culture of the community which you serve, and
specific needs of those interested in your organization based on location, age or physical condition.

Below is an excerpt from LA Metro based on initial Virginia Tech Institute work in 2016 that identifies the fence line,
issues and those interested in their ESMS.

5.3.1 Metro maintains a multi-site Environmental Management System (EMS) which follows
the ISO 14001:2015 standard. Multi-site facilities can include physical sites or the
overall implementation of EMS for construction projects.
5.3.2 The Scope of Metro’s EMS includes the environmental activities and supporting
processes associated with the environmental and sustainability commitments as
mentioned in the scope. More detail follows. Refer to 4.0-1 ED Attachment A and 5.0-2
EP Roles and Responsibilities for further description of the boundaries and applicability
of the environmental management system.
• Bus Maintenance Facilities. Facilities are between 3 to 28 acres of land and typically
include a maintenance building, fuel and vacuum building, bus wash, paint booth and a
transportation operations building. The activities and equipment located on site are used
to maintain and repair buses.
• Rail Maintenance Facilities. Facilities are between 9 to 40 acres of land and typically
include a multi-story maintenance building, blow-down building, train wash building and
storage building. The activities and equipment located onsite are used to maintain and
repair rail cars.
• Capital Project Construction. The processes related to the overall agency-wide
Capital Project Construction elements (vs, per individual project) are monitored for
conformance to the ISO 14001:2015 standard. However, implementation of the EMS
still considers the environmental and compliance obligations of each construction facility.
Construction facilities can range in size from structural updates, upgrades, or
renovations to highway, busway, or rail construction on new rights-of-way.
• The EMS Scope can be expanded as determined by the EMS Administrator to include
other LA Metro business units. Under such conditions, appropriate changes to the LA
Metro EMS will be conducted with the changes approved by the EMS Administrative
Team.

Source: FTA/VT ESMS Institute Homework, LA Metro, 2016

Contact: Dr. Cris B. Liban, P.E., ENV SP Executive Officer, Environmental Compliance and Sustainability
One Gateway Plaza, Los Angeles, CA
Phone: 213/922-2471
Email: [email protected]

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3.1.3 Issues Inside and Outside Your Organization — LA Metro
LA Metro outlined, in a very practical approach, the challenges it faced by describing the issues as “What’s
happening?” and “What needs to happen.” This approach might help you and your colleagues get started.
You should “go big” when you identify issues inside and outside your organization and then begin to focus on
how those issues directly affect your organization.

Source: LA Metro — PPT Presentation, May 27, 2016

Contact: Dr. Cris B. Liban, P.E., ENV SP Executive Officer, Environmental Compliance and Sustainability
One Gateway Plaza, Los Angeles, CA
Phone: 213/922-2471
Email: [email protected]

3.1.4 Senior Management-Leadership and Commitment Pledge — Metro-Southeastern Ohio

Transit Authority (SORTA)

Environmental/Sustainability Policy
Environmental policies, mission statements and visons are established to demonstrate commitment from top
management to support its environmental performance.

An example from SORTA follows.

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Source: FTA Final Report, SORTA section, Page 49, 2017
Contact: T J Thorn, OHST, TSSP Vice President, Safety and Security/Chief Safety Officer
1401 Bank Street, Cincinnati, OH 45214-1737
Phone: 513-632-7651
Email: [email protected]

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3.1.5 Senior Management — Mission/Vision — LA Metro Policy Statement
Los Angeles County Metropolitan Transportation
Authority Environmental Management System Policy
POLICY STATEMENT
Los Angeles County Metropolitan Transportation Authority (Metro) will be a leader in maximizing the environmental
effort and its benefits for Los Angeles County through our core mission of moving people efficiently and effectively
using an Environmental Management System (EMS) as its primary tool in applying sustainable principles and practices
in our planning, construction, operations, and procurement to protect the environment for present and future
generations.

PURPOSE
The purpose of this policy is to provide guidance for continual improvement in reducing environmental impacts through
the following, 1) identifying potential environmental impacts generated by our development activities and developing
mitigation measures to address those impacts; 2) operating and maintaining Metro vehicles and facilities to minimize
negative impacts on the environment; 3) reducing our consumption of natural resources; 4) reducing or eliminating the
use of hazardous materials; 5) increasing the amount of recycling and use of recycled products; and 6) reducing and/or
diverting the amount of solid waste going to landfills.

COMMITMENT
Metro provides multi-modal public transit services that greatly improve the quality of the environment in the
communities it serves. We are committed to planning and constructing our projects, operating and maintaining our
facilities and vehicles, and procuring products and services consistent with State and federal laws and regulations and
in a manner that protects human health and the environment but not neglecting the efficient delivery of quality public
transit services within our financial ability.

To demonstrate our commitment, we will:

• Comply with all environmental, federal, State, and local laws and regulations, and other requirements;

• Restore the environment by providing mitigation and corrective action and by monitoring to ensure that
environmental commitments are implemented;

• Improve our ability to manage and account for environmental liabilities and risk;

• Avoid environmental degradation by minimizing releases to air, water, and land;

• Prevent pollution and conserve resources by reducing waste, reusing materials, recycling, and preferentially
procuring for environmentally-friendly products and materials;

• Encourage and support the development of standards that encourage public transit use and environmental
protection;

• Conduct training to raise awareness among employees and the general public regarding environmental
protection and sustainable practices;

• Ensure that the planning, design, construction, and operation of our facilities and services consider
environmental protection and sustainable features;

• Periodically review and implement updated environmental protection procedures and practices to ensure that
they provide effective solutions for the problems they are designed to prevent or correct;

• Recognize and encourage citizen awareness and involvement in our efforts to protect the environment and
educate the public about the environmental benefits of our transit system;

• Build relationships with our contractors, vendors, consultants, and transit partners during planning, design,
construction, operation and procurement to protect and enhance the environment;

• Consider alternative solutions such as promoting and tapping renewable energy sources to address energy and
environmental challenges;

• Maintain an EMS with environmental objectives and targets that are measurable, meaningful, understandable,
and support continual improvement; and

• Communicate the goals and progress of this Policy and the EMS to Board Members, officers, employees and
the public.

Source: LA Metro CEMS 5.0-1 ED Attachment A Version: 3/26/13

Contact: Dr. Cris B. Liban, P.E., ENV SP Executive Officer, Environmental Compliance and Sustainability
One Gateway Plaza, Los Angeles, CA
Phone: 213/922-2471
Email: [email protected]

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3.1.6 Senior Management Commitment

MTA

The Maryland Department of Transportation Maryland Transit Administration (MDOT MTA) is

a customer-driven organization that delivers safe, efficient and reliable transit solutions with
world-class customer service. MDOT MTA’s policy is to conduct our mission in a manner that is
protective of human health, safety and the environment, while efficiently managing the public
resources that support our operations.

Through its Environmental Policy and Environmental and Sustainability Management System
(ESMS), MDOT MTA commits to:
Promote and support innovative solutions, including public-private efforts that protect the
environment and maintain sustainable process improvement.
Introduce environmental protection, pollution prevention and sustainable processes in the
early planning stages of new programs, transit facilities and in all work conducted on MDOT
MTA properties.
Comply with applicable federal, state, and local environmental regulations and policies with
regularly scheduled internal assessments.
Evaluate the effectiveness of MDOT MTA’s environmental management program through
application and review of the ESMS to ensure that established objectives and targets are
met.
Promote a spirit of collaboration, cooperation and responsiveness both internally and with
federal, state and local regulators.
Implement and maintain MDOT MTA’s environmental policy through effective
communication with our employees and stakeholders.
Implement proactive, sound and fiscally responsible environmental stewardship and
sustainable practices.

“We at MDOT MTA have a responsibility to preserve our environment for future generations.
The Environmental and Sustainability Management System will be a powerful tool in moving
our agency forward in a holistic manner and is aligned with the Hogan Administration’s
directive of making Maryland the national leader in environmental protection and sustainability
practices.”
– Mr. Kevin B. Quinn, Administrator, MDOT Maryland Transit Administration

Source: FTA Final Report, MTA section, Page 29, 2017

Contact: Robert Frazier, Environmental Manager
1515 Washington Boulevard, Baltimore, MD 21230
Phone: 410-454-7317.
Email: [email protected]

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 LA Metro

On April 16, 2009, the Metro Board approved the Environmental Policy which formalizes
Metro’s “commitment to protecting the environment using sustainable principles and
practices in our Planning, Construction, Operations, and Procurement Departments”.
This policy illustrates our leadership in maximizing our environmental efforts and its
benefits for Los Angeles County through transportation.
LA Metro has an Executive Officer, Environmental Compliance and Sustainability, who
ensures the uniform implementation of the Environmental Management System and its
principles across the agency.

Source: LA Metro CEMS 5.0-1 ED Attachment A Version: 3/26/13

Contact: Dr. Cris B. Liban, P.E., ENV SP Executive Officer, Environmental Compliance and Sustainability
One Gateway Plaza, Los Angeles, CA
Phone: 213/922-2471
email: [email protected]

3.1.7 Contributions, Obligations and Authorities

Personnel involved in the organization’s environmental management system need to understand their
contributions, obligations and authorities as they pertain to the system.

Below are examples of contributions, obligations and authorities. LA Metro and MTA refer to them as roles,
responsibilities and authorities (ISO 14001:2015 terminology).

LA Metro Roles and Responsibilities CEMS 5.0-2 ED Roles and Responsibilities Matrix

Role Description of EMS Responsibilities

EXECUTIVE MANAGEMENT

Chief Executive Endorses the Metro EMS Policy to the Metro Board.
Officer
Assures commitment to continual improvement in environmental performance.
Supports the development and continued implementation of the overall EMS program
to achieve its intended outcome.

Chief Operations Assures commitment to continual improvement in environmental performance.

Officer
Supports the development and continued implementation of the overall EMS program
within the Metro operations to achieve its intended outcome.
Works together with EMS Administrator in ensuring the EMS SOPs at facilities are
established, maintained, and followed.

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 Role Description of EMS Responsibilities

Executive Officer, Acts as EMS Administrator and is responsible for agency-wide implementation of EMS
Environmental (i.e., Executive Sponsor)
Compliance and
Assures commitment to continual improvement in environmental performance.
Sustainability
Supports the development and continued implementation of the overall EMS program
to achieve its intended outcome.
Ensures Metro activities meet the environmental obligations and policy standards.
Ensures the EMS SOPs at Metro facilities are established, maintained, and followed.
Ensures integration of the EMS program into Metro’s business processes as applicable

Chief Project Supports the development and continued implementation of the overall EMS program
Management Officer to achieve its intended outcome.
Assures commitment to continual improvement in environmental performance.
Works together with EMS Administrator in ensuring that construction activities meet the
environmental obligations and policy standards.

STAFF WITH CENTRALIZED FUNCTIONS

Talent and Maintains centralized training record database.

Development

Risk, Safety and Asset Maintains centralized emergency response plans pertaining to hazardous materials and
Management – hazardous materials business plans, as needed.
Corporate Safety
Documents procedures and SOPs pertaining to agency wide safety.
Coordinate Metro’s response to regulatory agencies compliance inspection regarding
hazardous materials and Air Quality
Conducts hazardous material training.
Member of the EMS Administrative Team.

Quality Assurance/ Maintains centralized records pertaining to compliance with hazardous waste
Environmental management.
Compliance and
Documents procedures and SOPs pertaining to agency wide environmental compliance
Services
and hazardous waste management.
(AKA Quality
Assurance) Member of the EMS Administrative Team.

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 Role Description of EMS Responsibilities

Procurement and Maintains centralized contracts for Metro contractors, suppliers and vendors.
Material Management
Member of the EMS Administrative Team.

Information Maintains centralized electronic access to all EMS documents.

Technology Systems
Provides overall electronic data management support of the EMS.

Emergency Maintains Emergency Response Drill After Action Reports.

Management and
Add references to EP 8.2
Homeland Security
Department Maintain Evacuation Plans and Emergency Site Plans
Member of the EMS Administrative Team.

FACILITYLEVEL PERSONNEL

Facility Manager (EX: Maintains facility records pertaining to compliance, training, calibration logs, and
Maintenance Manager, emergency response.
Transportation
Documents EMS SOPs pertaining to their department.
Manager,
Environmental Implements and verifies corrective and preventative action plans when required.
Construction
Maintains facility-specific emergency and safety plans.
Compliance Manager)
Communicates facility-level feedback on EMS to the Core Team.
Member of EMS Facility Core Team.
Ensures compliance with contract specifications and local, state, federal and other
regulations

Supervisor Communicate employee feedback on EMS to the facility manager.

Communicate EMS SOPs to the employees of their respective areas.
Ensure that employees in their respective areas have the training and tools to meet the
requirements of the procedures.
May be a member of EMS Facility Core Team.

Hazardous Materials Employee/Contractor designated by Metro to assist with managing hazardous waste on
Coordinator site.
Coordinates with Quality Assurance/ ECSD to document periodic review of hazardous
waste management and follows up to indicate necessary corrective actions occur

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 Role Description of EMS Responsibilities

Local Site Safety Accessing and maintaining the Emergency Site Plan listed above, and revision of the
Committees site-specific sections following the occurrence of a reportable spill or emergency
situation or other, as needed.
Maintaining the site specific appendices of the Emergency Site Plan.
Coordinating site emergency drills and completing documentation of site emergency
drills.

Employee/Contractor Perform assigned tasks in accordance with regulations, EMS standards, and EMS
SOPs.
Communicate concerns to the supervisor regarding the performance of tasks, in
accordance to the above listed requirements.

EMS SPECIFIC ROLES

EMS Administrator Provides overall oversight of the EMS in coordination with executives of participating
LA Metro business units.
Develops, implements, and maintains Metro’s EMS.
Assigns, manages and participates on the EMS Administrative Team.
Ensures activities meet the environmental regulations, permit conditions, terms, and
policy standards.
Ensures EMS Procedures and SOPs are established and maintained.
Represents the Environmental Compliance and Sustainability Department.
Ensures overall maintenance of the Metro’s EMS, including the update and
maintenance of:
EMS Policy
EMS Administrative Environmental Procedures
EMS Administrative Environmental Documents and Forms
Environmental Aspects and Significant Aspects
Evidence of progress towards environmental objectives
Environmental Management Programs
Environmental Department SOPs
Reviews non-conformances generated by the internal audit process.
Implements and verifies corrective and preventive action plans when required.
Participates in EMS Administrative Team meetings, internal audits and surveillance
audits.
Communicates the status of the EMS to the Top Management for the purposes of
improvement.

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 Role Description of EMS Responsibilities

EMS Administrative Develops, implements, and maintains Metro’s EMS.

Team (AKA Admin
Determines external and internal issues that relevant to achieve Metro’s intended
Team)
outcome
Determine Metro’s Interested parties, needs and expectation, and compliance
obligations
Ensures activities meet the compliance obligations, and policy standards.
Participates in maintaining EMS Administrative Procedures, Documents and Forms.
Assists in identifying and ranking Environmental Aspects and Significant Aspects.
Participates in developing and implementing centrally managed environmental
objectives and action plans.
Maintains Monitoring and Measurement tracking for centrally managed action plans.
Implementing and verifying corrective and preventative actions when required.
Participates in EMS Administrative Team meetings, internal audits and surveillance
audits.
Communicating the status of the EMS to Top Management for the purpose of continual
improvement.
The team includes:
Environmental Compliance and Sustainability Department
Corporate Safety
Quality Assurance
Rail Operations
Bus Maintenance
Bus and Rail Transportation
Homeland Security
Procurement and Material Management
Facilities Management
EMS Implementation Assists Metro facilities with implementing Metro EMS
Coordinator
Coordinates with the EMS Administrator and the EMS Administrative Team; operates
as designee for both.
As EMS Administrator and Administrative Team designee, acts as liaison between
Facility Core Team and the Administrative Team.
Develops and utilizes Metro EMS implementation strategy and materials.
(depending on the size, there may be more than one EMS implementation coordinator)

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 Role Description of EMS Responsibilities

EMS Facility Core Develops, implements, and maintains Metro’s EMS at the facility level.
Team (AKA Core
Ensures facility activities meet the environmental commitment, environmental
Team, a Core Team
regulations, permit conditions, terms, and policy standards.
can be formed in
either Operations EMS Participates in maintaining EMS facility specific forms and records.
or Construction EMS)
Assists in identifying and ranking Environmental Aspects and Significant Aspects.
Participates in developing and implementing facility specific environmental objectives, if
appropriate, and action plans.
Maintains Monitoring and Measurement tracking for facility specific action plan and
other action item progress on significant aspect controls.
Implementing and verifying corrective and preventative actions when required.
Participates in EMS Administrative Team meetings, internal audits and surveillance
audits, when appropriate.

GENERAL ROLES

Top Management Consists of Executive Officers and above who will be coordinating with the EMS
Administrator in the participation of their staff for the implementation of the LA Metro
EMS

Contract Consist of personnel that review external provider contract and services in coordination
Administrator
with Metro’s EMS

Source:
LA Metro Roles and Responsibilities CEMS 5.0-2 ED Roles and Responsibilities Matrix
Contact: Dr. Cris B. Liban, P.E., ENV SP Executive Officer, Environmental Compliance and Sustainability
One Gateway Plaza, Los Angeles, CA
Phone: 213/922-2471
Email: [email protected]

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MTA Cromwell Light Rail Station Facility ED-1-5.3-2 Organizational Roles, Responsibilities and Authorities
(RRA) Matrix

Title/Position/Role/
Job Description RRA in the ESMS

• Responsible for approving and endorsing the MTA Environmental Policy.

• Responsible for assuring all department areas are committed to continual
MTA
improvement in environmental performance.
ADMINISTRATOR
• Responsible for support of the development and continued implementation of the
overall ESMS program.
• Participation in Management Reviews of the ESMS.
• Serves as the senior management representative on the ESMS Team.
• Responsible for communicating ongoing status of the ESMS to the MTA
Administrator.
• Responsible for supporting all departmental areas in their commitment to continual
improvement in environmental performance.
CHIEF SAFETY • Participation in Management Reviews of the ESMS.
OFFICER, OFFICE OF • Responsible for overseeing the development and implementation of the ESMS. This
SAFETY, QUALITY includes the update and maintenance of:
ASSURANCE AND (1) The Environmental Policy
RISK MANAGEMENT (2) Environmental Aspects and Significant Aspects
(3) Maintenance of Compliance Obligations
(4) Evidence of progress towards Objectives
(5) Environmental Actions
(6) Environmental Department Procedures
(7) Environmental Compliance Manual
(8) Pollution Prevention Plan
(9) Forms and Environmental Records

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Title/Position/Role/
Job Description RRA in the ESMS

MTA • Responsible for administering the ESMS at the operational level on a day-to-day
ENVIRONMENTAL basis.
MANAGER • Responsible for supporting all departments in their commitment to continual
improvement in environmental performance.
• Responsible for supporting the development and continued implementation of the
overall ESMS program within the Cromwell Facility’s Operations.
• Participation in Management Reviews of the ESMS.
• Responsible for ensuring the MTA Environmental Group’s activities comply with
applicable EPA and MDE regulations.
• Responsible for compliance and administering and maintaining the ESMS long-term.
• Responsible for ensuring ESMS Procedures are developed, maintained, and followed.
• Responsible for reviewing non-conformances generated by the internal audit process.
Responsible for implementing and verifying corrective and preventive action plans
when required.
• Responsible for communicating the operational status of compliance efforts and the
ESMS to the Chief Safety Officer, Office of Safety, Quality Assurance, and Risk
Management.
• Responsible for assigning tasks to the Environmental Analysts and ensuring
performance.
• Responsible for developing, reviewing, and updating environmental training
materials.
• Responsible for ensuring complete training of employees in the environmental policy,
procedures and SOPs as specified in the training procedures.
• Responsible for conducting site visits to ensure operational and ESMS compliance.
• Responsible for communicating MTA’s Environmental Policies to other MTA
Divisions and for ensuring that MTA Divisions make contract personnel aware of
MTA’s Environmental Policies.
MANAGER • Responsible for ensuring personnel attend training in MTA environmental policies
INTERNAL and Standard Operational Procedures (SOPs) pertaining to maintenance activities
COMPLIANCE (handling, shipping and receiving, and hazardous waste handling).
DEPARTEMENT • Responsible for assuring delivery, transport, handling and storage of all materials on-
SERVICE QUAILITY site is done accordingly to regulatory guidelines, MTA policies/procedures, and
DIVISION ESMS requirements.
• Responsible for incorporation of regulatory requirements, MDOT directives and
MANAGER, ESMS requirements into the planning phase of projects at MTA facilities.
ENVIRONMENTAL • Facilitates internal communication of ESMS elements in accordance with the Internal
PLANNING and External Communication Procedures.
• Communicates new sustainability initiatives, and provides updates on current
initiatives to the Environmental Manager for incorporation into the ESMS.
DIRECTOR, • Responsible for ensuring the Facility Engineering and Maintenance department
OPERATIONS activities are consistent with environmental regulations.
SUPPORT • Responsible to ensure the ESMS procedures and SOPs are established, maintained,
and followed.
• Responsible for reporting on the administrative status of the ESMS to the Chief
ESMS
Safety Officer, Office of Safety, Quality Assurance, and Risk Management.
COORDINATOR(S)
• Technical QA/QC review of documents supporting the ESMS.
• Responsible for coordinating resources for contractor/consultant
inspection/assessment efforts.

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Title/Position/Role/
Job Description
RRA in the ESMS

• Collaborates with the Chief Safety Officer and Environmental Manager regarding the
content of environmental-specific training needs and programs.
• Maintains the integrity of the ESMS documents on the MTA Intranet site.
• Responsible for the document control of the ESMS documents, forms and records on
the Website.
• Liaison with other regulatory agencies as necessary on ESMS-related subject matter.
• Responsible for representing the Office of Safety, Quality Assurance, and Risk
Management during environmental and ESMS Team Meetings.
• Responsible for facilitating the initial drafts of MTA’s procedures, SOPs and other
OSQARM elements of the ESMS for review/comment.
Technical Support • Responsible for regulatory consulting support for day-to-day operations and the
ESMS Development and Implementation.
• Responsible for generating ESMS Team meeting minutes.
• Responsible for monitoring the ESMS development and implementation schedule.
CROMWELL LIGHT • Responsible for communicating employee feedback on the Environmental Policy and
RAIL MAINTENANCE Training; and communicating pertinent procedures and SOPs to the employees of
FACILITY their respective area.
SUPERVISORS • Responsible for ensuring employees in their respective areas have the training and
tools to meet the requirements of the procedures and SOPs.

CROMWELL LIGHT • Responsible for performing their tasks in accordance with the regulations, the
RAIL MAINTENANCE Environmental Policy, procedures and SOPs.
FACILITY • Responsible for communicating their concerns to the Supervisor regarding the
EMPLOYEES performance of tasks, in accordance to the above listed requirements.

INTERNAL • Responsible for following audit plans / schedules.

AUDITORS / AUDIT • Responsible for conducting internal audits of the MTA against procedural
TEAM requirements and the ISO 14001:2015 standard.
• Responsible for reporting the results of the audits to the Chief Safety Officer, Office
of Safety, Quality Assurance, and Risk Management.
• Responsible for developing / implementing the ESMS.
• Responsible for representing each operational area during the ESMS Core Team
Meetings.
ESMS CORE TEAM
• Responsible for facilitating the initial drafts of Cromwell procedures, SOPs and other
elements of the ESMS.
• Responsible for promoting the ESMS at Cromwell and as appropriate, agency-wide.
• Responsible for implementing the ESMS.
• Responsible for representing each operational area during the ESMS Workgroup
ESMS WORKGROUP
Meetings.
• Responsible for promoting the ESMS at Cromwell.

Source: MTA, ED-10-5.3-2 Organizational Roles, Responsibilities and Authorities (RRA) Matrix
Contact: Robert Frazier, Environmental Manager
1515 Washington Boulevard, Baltimore, MD 21230
Phone: 410-454-7317
Email: [email protected]

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3.1.8 Developing Environmental Characteristics and Influences— MTA
Your organization will need to look at the environmental characteristics and influences specific to your
operations. Consider a life cycle approach which will incorporate elements of your operations as inputs,
throughputs, and outputs as they reflect environmental conditions such as affecting air quality or water quality,
and quality of life for your community.

MTA provides an example for listing your environmental characteristics and MTA refers to them as aspects
and impacts (ISO 14001:2015 terminology).

Significant Aspects and Impacts

The ESMS Core Team in conjunction with Cromwell
supervisors and staff conducted a site survey of operations,
reviewed work activities and identified and ranked
environmental aspects at Cromwell. The team generated
a list of 51 environmental aspects and performed a rating
based on the criteria below:
Frequency/probability of occurrence
Regulatory requirements
Severity of environmental effect of aspect
Community concerns
Operational controls

Aspects rated 12 or above (out of 20) were considered

significant. A total of 25 aspects were deemed significant.
However, based on existing on-going efforts, regulatory risk
factors, and available funding, only the five (5) significant
aspects listed below are being addressed in the first
phase. The other significant aspects will be addressed in
subsequent phases.

Aspect Process/Activity Impact

AST Management Exterior stationary; Waste management (SW/ Soil, groundwater,
exterior mobile UW/HW) surface water

Stormwater management
Exterior Materials Exterior storage of Stormwater management Soil, groundwater,
Storage materials for routine surface water
activities, exterior bulk
storage of fluids/oils
Fuel Dispensing Exterior stationary; Waste management Soil, groundwater,
exterior mobile (SW/UW/HW) surface water

Stormwater management
Spills/Releases Equipment storage Stormwater Soils, groundwater,
surface water
Water Consumption Routine facility Water treatment, Safe Groundwater, surface
activities/operations Drinking Water Act water

Source: FTA Final Report, MTA section, Page 25, 2017

Contact: Robert Frazier, Environmental Manager
1515 Washington Boulevard, Baltimore, MD 21230
Phone: 410-454-7317
Email: [email protected]

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3.1.9 Legal Requirements — LA Metro
Transit organizations are subject to a multitude of laws, regulations (including federal, state, regional and local
rules) as well as international agreements that affect its operations.

Below is a homework excerpt from LA Metro from the 2016 ESMS Institute that provides an example of a
good way to list requirements (only federal requirements are shown in the excerpt), determine what your
organization must do, and track the reporting.

Source: LA Metro CEMS 4.0-1 ED Attachment B Version: 7/19/16

Contact: Dr. Cris B. Liban, P.E., ENV SP Executive Officer, Environmental Compliance and Sustainability
One Gateway Plaza, Los Angeles, CA
Phone: 213/922-2471
Email: [email protected]

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3.1.10 Integrating ESMS into Agency Strategic Planning and Goals and Funding — LA Metro
A key element of making sure that your ESMS is contributing to the success of your organization is to ensure
that the ESMS is aligned with your organization’s strategic plan and your mission. LA Metro developed a
diagram to describe its processes and as a result was able to consider an integrated approach to link funding
to planning, construction and operations.

Source: LA Metro, PPT Presentation, 5/27/16

Contact: Dr. Cris B. Liban, P.E., ENV SP Executive Officer, Environmental Compliance and Sustainability
One Gateway Plaza, Los Angeles, CA
Phone: 213/922-2471
Email: [email protected]

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3.1.11 Developing Goals and Targets
After you have developed a list of the characteristics and influences of your organization that you want to
address, you need to establish goals and targets. An action plan needs to be developed for each goal and
target to monitor that they will be achieved.

Examples related to developing goals, targets and action plans are provided below from MTA, TriMet, Bay Area
Rapid Transit (BART) and Metropolitan Atlanta Rapid Transit Authority (MARTA). MTA, TriMet and MARTA
refer to them as objectives (ISO 14001:2015 terminology).

MTA
Aspect Objective Tasks
ASTs Establish a tank Perform ASTs Baseline Assessment.
Management management program to Prioritize ASTs repairs.
address all deficiencies
Review and update current standard operating procedures
and ensure compliance
(SOPs).
with newly enacted
regulations. Review training procedures.
Establish a routine inspection, testing and routine preventative
maintenance (PM) program.
Exterior Materials Establish internal Review and update current standard operating procedures
Storage procedures to avoid (SOPs).
deficiencies in regards to Review training procedures.
all applicable compliance
Review facility operations for additional items which require
obligations
control.
Review applicable compliance obligations and infrastructure for
adequate control measures and additional operational BMPs.
Fuel Dispensing Prevent the spill and Review and update current standard operating procedures
release of fuels from (SOPs).
dispensing activities into Review training procedures.
the surrounding soil,
Establish a routine inspection and routine preventative
groundwater and surface
maintenance (PM) program.
water.
Review facility infrastructure for adequate control measures.
Spills and Prevent spills and Review and update current standard operating procedures
Releases releases of oils, (SOPs).
fuels, and hazardous Review training procedures.
substances into the
Review facility infrastructure for adequate control measures
surrounding soil,
and availability and adequacy of spill kits/equipment and if
groundwater and surface
equipment is adequately sized to handle the quantity and types
water.
of material stored at the facility.
Water Reduce water Review water consumption documentation.
Consumption consumption from Evaluate facility functions for water saving opportunities.
domestic, industrial and
MTA is developing a water consumption reduction goal based
landscaping activities.
out of their energy consumption plan

Source: FTA Final Report, MTA section, Page 28, 2017

Contact: Robert Frazier, Environmental Manager
1515 Washington Boulevard, Baltimore, MD 21230
Phone: 410-454-7317
Email: [email protected]

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Objectives
TriMet
Aspect Objectives Tasks
Chemicals • Update internal online SDS • Review online SDS database
database to comply with OSHA • Inventory chemicals to identify those that
requirements regarding SDS, July have not been through review
2019 • Implement pilot project to test new products
• Identity chemicals that have not for effectiveness
been through the environmental • Implement staff training by January 2018
and safety review, July 2019 • Maintenance to include chemical action
• Identify which chemicals have items or corrective actions( e.g. training,
environmentally responsible storage, spills, handling, use and disposal)
alternatives, July 2019 on the staff meetings template
• Confirm standard operating
procedures regarding chemical
procurement and handling are in
place, January 2018
Electricity • Conduct audit to identify potential • Procure energy auditor
building systems improvements at • Design and implement the conservation plan
Elmonica by November 2017 that will reduce electricity usage
• Create an energy conservation • Define baseline electricity consumption
action plan to reduce electricity data for gross meter and sub-meters
usage measurement on a quarterly basis
• Conduct isolated monitoring of • Analyze energy use projections with actual
consumption for Elmonica building ‘before and after’ consumption to determine
• Implement staff training by June change/progress toward Objective. Create
2018 and display YTD usage trending graph
• Update the staff of the conservation action
plan at monthly meetings
Natural Gas • Conduct audit to identify potential • Procure energy auditor
building systems improvements at • Design and implement the conservation plan
Elmonica by November 2017 that will reduce natural gas usage
• Create an energy conservation • Define baseline electricity consumption
action plan to reduce natural gas data for gross meter and sub-meters
usage measurement on a quarterly basis
• Conduct isolated monitoring of • Analyze natural gas use projections with
consumption for Elmonica building actual “before and after” consumption
• Implement staff training by June to determine change/progress toward
2018 Objective. Create and display YTD usage
trending graph
• Update the staff of the conservation action
plan at monthly meetings

Source: FTA Final Report, TriMet section, Page 57, 2017

Contact: Kimberley Angove [email protected]
4012 SE 17th Ave, Portland, OR 97202
Phone: 503-962-4831
Email: [email protected]

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Once you have determined your important environmental characteristics and influences, it is important to set
specific targets to meet your ESMS goals. These need to be consistent with your ESMS goals, and you need to
be able to measure them, assign staff to monitor them, communicate progress and update them as needed.
Goals need to have some target or measure such as a percent reduction in fuel use by a specific time period.
In some cases, it may take some time to determine the actual target numbers because you need to establish
how and when you will measure (baseline).

After identifying general categories, as shown above, you can then develop a more comprehensive tool that
identifies the measure, target, baseline and data source. Bay Area Rapid Transit (BART) has developed a tool
that provides this information as it relates to its identified targets.

BART DRAFT Environmental Objectives 7/6/16

Measure Target Baseline (2013) Data Source

Water Consumption 25% normalized 59,142,116 Gal Consumption analysis,

Reduction by 2020? Water Invoices
0.877 Gal/mile

Energy Use 4% normalized 1,393,221 GJ, CAPTAC Model ,

reduction by 2020 Electricity Bills, Natural
0.0207 GJ/mile Gas Bills, Diesel and
Gasoline Receipts

GHG Emissions 70% normalized 152,979 MT CO2e, CAPTAC Model,

reduction by 2020 Electricity Bills, Natural
2.27 kg-CO2e/mile Gas Bills, Diesel and
Gasoline Receipts

GHG Displacement N/A 1,294,306 MT CO2e APTA, TCRP-174

Solid Waste Diversion TBD 10% diversion* Big Belly Pilot data,
Rate Waste Service
agreements

*Based on waste service agreements

Source: FTA/VT ESMS Institute Homework, BART, 2016

Contact: Bob Powers, General Manager, San Francisco BART
300 Lakeside Drive, Oakland, CA 94612
Phone: 510-464-6060
Email: [email protected]

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 MARTA chose to set objectives and targets for each significant aspect. These are described in the following
table. Please note that in some cases training targets are set for subsequent/multiple dates as time is needed
to rotate staff through training.

Objective Target
Reduce the amount of phosphorus that is Maintain concentration of phosphorus in effluent to
discharged from the facility to the IWTP. IWTP at seven (7) milligrams per liter (mg/L) of
phosphorus or less by September 2012.

Reduce chemical usage and total petroleum Reduce the use of Metro Track Bed cleaner by 5%
hydrocarbon (TPH) levels in IWTP. by January 2012. Maintain total petroleum
hydrocarbon (TPH) in effluent less than 20 mg/L by
January 2012.

Minimize waste generation and attain RCRA Minimize hazardous waste generation from process
Conditionally Exempt Small Quantity Generator by 5% by March 2012. Attain CESQG status by
(CESQG) status for the facility. December 2012.

Comply with motor vehicle air conditioning (MVAC) Attain 90% training for HVAC technicians by March
Ozone Depleting Substances (ODS) requirements. 2012. Have fewer than five compliance findings for
MVAC ODS requirements under 40 CFR 82 by
March 2012. Attain 95% training for HVAC
technicians by September 2012.

Comply with fluorescent universal waste Attain 80% completion of training for Railcar
requirements. Maintenance personnel by July 2012. Have 5 or
fewer compliance findings for universal waste
requirements under 40 CFR 273 / GA 391-3-11-.18
during March 2012 audit. Attain 100% completion of
training for active staff of Rail Car Maintenance
personnel by September 2012.

Source: FTA Final Report, MARTA section, Page 91, 2012

Contact: Reginald James, Director of Safety, Office of Safety
2424 Piedmont Road, NE, Atlanta, GA 30324-3311

3.2 IMPLEMENTATION (DOING)

3.2.1 Providing Competent, Knowledgeable Staff with the Tools to Develop, Implement and
Maintain an ESMS
Well-trained staff is a hallmark of excellent organizations. Trained employees have higher morale levels, are
more efficient and are less likely to make errors. For the purposes of an ESMS, it is important to train staff
not only on their specific job tasks, but to ensure that they understand how their work and what they do fits
into the ESMS program, or in other words, they are knowledgeable. Several examples are provided below by
Southeastern Pennsylvania Transportation Authority (SEPTA) and SORTA.

The SEPTA example demonstrates the organization’s approach to training its employees. Please note that
different types of training are identified as each has its own relevant focus.

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Source: SEPTA – FTA/VT ESMS Institute Philadelphia - Presentation To the 2011 FTA ESMS Training
Program November 2011
Contact: Erik Johanson, Sustainability Program Director, SEPTA
Jim Fox, Director of System Safety & Risk Management
SEPTA, 1234 Market Street, 4th Floor, Philadelphia, PA 19107
Phone: 215-580-8113
Email: [email protected]

The SORTA example below demonstrates the organization’s approach to training its employees. Please note
that different types of training are identified as each has its own relevant focus.

5.1 The Annual ESMS Training Plan will be divided into four categories:

5.1.1 General ESMS Awareness - basic EMS training including New Employee Orientation;

5.1.2 Job -Specific ESMS Training - Significant Aspects & Operational Control(Work
Instructions);
5.1.3 Emergency and Regulatory-Required Training - Responders or apt to be exposed to an
emergency situation
5.1.4 Contractor ESMS Training – for approved Contractors/Suppliers/Vendors.

5.2 General ESMS Awareness

5.2.1 The initial EMS General ESMS Awareness training is given to all employees of the
Queensgate Facility. The EMS Management Representative and the HR department will
coordinate and conduct the training.
5.2.2 New employees of the Queensgate Facility are given General ESMS Awareness training
as part of the new employee orientation.

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 par ployee
5.2.3 Ongoing General ESMS Awareness training will be conducted according to the Annual
EMS Training Plan and will include training on the Queensgate Facility 's:
a) Environmental Policy;
b) significant Aspects and environmental impacts of work activities;
c) relevant Objectives, Targets and Programs;
d) roles and responsibilities;
e) general EMS performance;
f) environmental benefits of improved personal performance;
g) potential consequences of departure from operating procedures;
h) emergency preparedness and response requirements.
5.3 Job-Specific ESMS Training

5.3.1 All employees whose work may create a significant impact on the environment must have
the necessary skills, experience, and awareness to perform their duties in a manner that
conforms to the Environmental Policy, Procedures and Work Instructions, under normal,
abnormal and emergency working conditions.
5.3.2 Job-Specific ESMS Training for Operational Control (Work Instructions) is monitored and
tracked by the EMS Management Representative and coordinated with the HR department.
5.3.3 Supervisors will conduct Job-Specific ESMS Training on the Work Instructions for the
employees under their supervision. The Supervisors will train their employees using training
subject matter and material approved and/or provided by the EMS Management
Representative. Supervisors will ensure that Job-Specific ESMS Training is effective and
relevant for employees whose work may create a significant environmental impact.

5.3.4 Supervisors shall determine and schedule Job-Specific ESMS Training for their
employees upon initial assignment, reassignment to new duties and responsibilities,
assignment of new tasks, or annually as appropriate.
5.4 Emergency and Regulatory-Required Training

5.4.1 All employees who are directly involved in responding to an emergency situation or require
regulatory training must have the necessary skills, experience, and awareness to carry out
the environmental activity.
5.4.2 Employees who are directly involved in responding to an emergency situation or who are
more apt to be exposed to an emergency situation, as identified in the EP-8.2-1 Emergency
Preparedness and Response Procedure, will receive the necessary and required training
per the specific emergency plans.
5.5 Contractor ESMS Training

5.5.1 Approved contractors, suppliers and vendors working on projects that involve significant
environmental aspects on behalf of the Queensgate Facility will be briefed on theSORTA
Metro ESMS; Environmental Policy; relevant Objectives and planning to achieve them; and
appropriate Work Instructions. Contractor communication, briefings and training will be
documented.

Source: FTA/VT ESMS Institute Homework, SORTA, 2017

Contact: T J Thorn, OHST, TSSP, Vice President, Safety and Security/Chief Safety Officer
1401 Bank Street, Cincinnati, OH 45214-1737
Phone: 513-632-7651
Email: [email protected]

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In order to ensure that training is documented and management has evidence that staff have been trained,
recordkeeping is essential to your system. SORTA provides an excellent example below of a record to
document training.

Verification Originator Revised Approved Issued

Initials
Date

Environmental Document

ED-7-2 (F) Training Sign-in Sheet

Refer to EP-7 (7.1, 7.2, and 7.3) Support: Resources, Competence & Awareness Procedure for detailed instructions
regarding this ESMS form/record.

Training Class Subject:

Instructor / Supervisor:

Date and Time:

Print Name Initials Department Signature

10

11

12

13

14

Completed forms and related attachments are records maintained in the ESMS; route to the ESMS Designated
Personnel

Source: FTA/VT ESMS Institute Homework, SORTA, 2017 — Excerpt from procedure EP-7 (7.1, 7.2, 7.3)
Support: Resources, Competence, Awareness dated 8/21/16
Contact: T J Thorn, OHST, TSSP Vice President, Safety and Security/Chief Safety Officer
1401 Bank Street Cincinnati, OH 45214-1737
Phone:513-632-7651
Email: [email protected]

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SORTA also provides an excellent example of a training matrix. As you can see the Training Categories
(Awareness/Job Specific) are listed in the left-hand column and the Personnel/Timing (Schedule) and
documentation appear in the top rows. The matrix also includes a risk assessment associated with the training.

Training Personnel Timing Records

Admin. Facilities Maint. Mechanic Janitorial Contract
General EMS Risks to achieving training: Indicate identified risks to achieving training and risk level
Awareness
1 3 3 3 2 2 Personnel
Initial records, Sign-in
1 EMS requirements implementation of sheets,
refer to EP-7 (7.1, 7.2, EMS. Determine Agenda, Trainers
7.3) Training need for re- notes, Meeting
Procedure in sec. 5.2.3 fresher annually. minutes
2 Significant Aspects 1 3 3 3 2 2 Same as above Same as above
New Employee 1 1 1 1 1 1 When person is
3 Orientation initially hired Same as above
Contingency
Plan/Risk
4 Risk Level 1 2 3 management
5 Probability Low Medium High
6 Severity Low Medium High
Job-Specific EMS Risks to achieving training: Indicate identified risks to achieving training and risk level
Training
1 2 2 2 2 2 Personnel
Prior to assuming records, Sign-in
job sheets,
7 responsibilities; Agenda, Trainers
Shipment Hazardous then periodically notes, Meeting
Waste Off Site minutes
8 Handling and Disposal 1 3 3 3 3 3
of Hazardous Waste Same as above Same as above
9 Removing Gasoline 1 3 3 3 2 2
from Vehicles for Same as above Same as above
Maintenance
10 Disposal of Fuel Filters 1 3 3 3 1 2 Same as above Same as above

11 Maintenance of Vehicle 1 2 2 3 2 2
Air Conditioners Same as above Same as above
Training Personnel Timing Records
Admin. Facilities Maint. Mechanic Janitorial Contract
12 Maintenance of Facility 1 3 2 2 1 1
Air Conditioners Same as above Same as above
2 2 2 2 2 2 Personnel
records, Sign-in
Prior to assuming sheets,
job Agenda, Trainers
Paper and Cardboard responsibilities; notes, Meeting
13
Recycling then periodically minutes
14 EMS Electronic Access 1 1 1 1 1 1 Same as above Same as above
15 Train-the Trainer 1 1 1 1 1 1 Same as above Same as above
Contingency
Plan/ risk
16 Risk Level 1 2 3 Management
17 Probability Low Medium High

18 Severity Low Medium High

Emergency and Risks to achieving training: Indicate identified risks to achieving training and risk level
Regulatory-Required
Training
1 3 3 3 1 2 Statement of
Prior to assuming training,
job Personnel
19 Hazardous Waste responsibilities; records, Sign-in
Management annual update sheets
20 Transportation of 1 3 3 3 1 3 Same as above Same as above
Hazardous Materials
21 Others (TBD) Same as above Same as above

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 Contingency
22 Risk Level 1 2 3 Plan/Risk
management
23 Probability Low Medium High

24 Severity Low Medium High

Training Personnel Timing Records

Admin. Facilities Maint. Mechanic Janitorial Contract
Contractor EMS Risks to achieving training: Indicate identified risks to achieving training and risk level
Training
EMS Requirements: 1 2 2 2 2 2
Env. Policy; Refer to
25 Objectives & Targets; ED-4.4.6-3
Work Instructions. Evaluate training Checklist, and
Refer to Contractor needs based on ED-4.4.6-4
Management activities Activities
Procedure statement
26 Risk Level 1 2 3 Contingency
Plan/Risk
management
27 Probability Low Medium High

28 Severity Low Medium High

Source: FTA/VT ESMS Institute Homework, SORTA, 2017

Contact: T J Thorn, OHST, TSSP, Vice President, Safety and Security/Chief Safety Officer
1401 Bank Street, Cincinnati, OH 45214-1737
Phone: 513-632-7651
Email: [email protected]

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3.2.2 Effective System for Communicating
An effective system of communicating consists of the methods that an organization can use to both obtain and
disseminate information about its performance, ensure compliance with regulatory requirements, and notify top
management as well as employees regarding the status of the organization’s operations. An effective system
of communicating includes, and is not limited to, multiple forms and may include meetings, written instructions
and reports, e-mail, text, training, standard operating procedures (SOPs), posters, banners, websites, and
conferences. MTA and SORTA provide some examples of effective communication systems below.

MTA documents the procedures in which the ESMS will be communicated to those inside and outside the
organization.

Communication Product Examples:

EP 7.4-1 documents the procedures in which communication of the Environmental and Sustainability
Management System (ESMS) will be communicated to internal and external parties. The following are
examples of products that will be tailored for the Cromwell Light Rail Maintenance Facility.

Posters (see attached for example):

- Posters will be posted throughout the facility to highlight what ESMS is and what are the
significant aspects for the facility.

Letters to contractors (sample letter attached):

- The attached sample letter will be sent to contractors to inform them of the ESMS and that they
are to comply with all federal, state and local regulations.

Toolbox Meetings:

- To effectively communicate with staff, the Core Team will relay topics to be discussed at
Toolbox meetings that are held at the beginning of each shift. The topics will highlight various
ESMS elements and aspects. Attendance is taken at these meetings and the roster will be
documented according to EP 7.4-1.

Safety Meetings:

- Core Team members will attend monthly safety meetings with light rail staff to continue the
ESMS messaging. The Safety meetings will also be used as way to receive input on
communication materials to see if they are effective for staff. Attendance is taken at these
meetings and the roster will be documented according to EP 7.4-1.

Intranet (See attached for example):

- ESMS information will be posted on the MTA intranet on the TIGERS page. The page will include
the Environmental Procedures, work products, and educational material.

Source: FTA/VT ESMS Institute Homework, MTA, 2017 - 7.4-1 Communication Process
Contact: Robert Frazier, Environmental Manager
1515 Washington Boulevard, Baltimore, MD 21230
Phone: 410-454-7317
Email: [email protected]

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The following are examples of communication products that SORTA identified that are used within its ESMS.

External

• Vehicle Decals
• Place legal ad
• Go Info newsletter
• Website
• Green Umbrella post
• Social media, PR
• Media event – EPA, FTA, city officials
• Small placard signs for garages in yards

Internal

• “Metro Express” employee newsletter

• “Drive” employee newsletter
• “The Recycler” employee e-news
• Ridership partners monthly announcement
• Quarterly sustainability outreach and education events
• Counter signs at clerks and receptionists areas
• Screen savers
• Posters
• Framed 11 X 17 hung with official documents
• Videos

Source: FTA/VT ESMS Institute Homework, SORTA, 2017

Contact: T J Thorn, OHST, TSSP, Vice President, Safety and Security/Chief Safety Officer
1401 Bank Street, Cincinnati, OH 45214
Phone: 513-632-7651
Email: [email protected]

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3.2.3 Planning and Managing Emergencies — PAAC
Organizations must have an Emergency Response Plan to protect against adverse environmental impacts. In most
cases, existing emergency plans may be used with slight modification to meet the requirements of an ESMS. The
organization’s staff needs to be well trained and the organization needs to conduct periodic tests to assure that the
system is working and that any shortcomings identified as a result of the test are addressed. In some cases, the
plan will need to be revised, SOPs changed, and additional staff training provided to affected personnel. The Port
Authority of Allegheny County (PAAC) provides an excellent example of a hypothetical, yet possible, emergency
event at a Light Rail Transit station that includes an evaluation of the event and recommendations for improvements.

Emergency Response – PAAC Emergency Preparedness & Response Test Trials (and Tribulations)
Light Rail Transit

Source: FTA/VT ESMS Institute, 2016, PAAC Emergency Response Drill 2.pdf
Contact: 345 Sixth Ave, 3rd Floor, Pittsburgh, PA 15222

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3.3 MAINTENANCE (CHECKING/ACTING)

3.3.1 Examination, Investigation, Evaluation

The organization is responsible for tracking the effectiveness of implementation and this can best be achieved by
examining, investigating and evaluating what is taking place. Once goals and targets are set, monitoring progress
tells you how effective you are in meeting those goals and targets. Be sure to include calibration of equipment
as properly calibrated equipment will accurately reflect your progress and ensure that there will be no regulatory
violations. Examination, investigation, and evaluation information also allows you to adjust the resources allocated to
the goal in order to meet your targets. This could include more money, staff or materials.

CapMetro
Capital Metro provides an example of how to set up your examination, investigation and evaluation program to
ensure that staff are trained on their roles to achieve the targets set in the organization’s goals. Note, the process
involves the identification of calibration needs. Capital Metro refers to objectives, aspects, and monitoring and
measurements (ISO 14001:2015 terminology).

SOURCE: FTA/VT ESMS Institute Homework, Capital Metro, 2012

Contact: 2910 E. 5th St., Austin, TX. 78702
Phone: Customer Service GO Line: 512-474-1200
Website: www.capmetro.org

MTA Cromwell Light Rail Station Facility

MTA provides an example for evaluating how your examination, investigation and evaluation program is
working. The primary goal here is to identify what is working and what is not working. Next, corrective action
steps need to be established as well as assignments and resources made available to accomplish the tasks.
Recordkeeping is emphasized because it is the primary means by which an organization can provide evidence
of action. MTA refers to significant aspects and monitoring and measurement (ISO 14001:2015 terminology).

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 ED-10-9.1 Monitoring and Measurement Annual Evaluation Form

Evaluation Question Yes/No Comments

General

1. Have all of the operations and activities, compliance

obligations, and objectives for each significant aspect been
identified?

2. Were monitoring and measurement types effective for

ensuring SOPs were implemented? If not, identify issues in
the Comments section.

3. Were monitoring and measurement types effective for

ensuring compliance obligations were met? If not, identify
issues in the Comments section.

4. Are additional monitoring and measurement types needed?

If yes, describe in the Comments section.

5. Have there been any operational or equipment changes

that affect the monitoring and measurement or calibration
for significant aspects? If yes, describe in the Comments
section.
6. Have there been any equipment or operational changes
which would require updates to the SOPs? If yes, describe
in the Comments section.

7. Has senior management been made aware of needs,

resources, etc.?

Significant Aspect: Tank Management

1. Have all records and information been retained in order to

effectively and accurately evaluate the criteria established
in Section 9.1 Monitoring and Measurement??

2.

3.

Significant Aspect: Water Conservation

1. Have all records and information been retained in order to

effectively and accurately evaluate the criteria established
in Section 9.1 Monitoring and Measurement??

2.

3.

Significant Aspect: Compressed Gas Storage

1. Have all records and information been retained in order to

effectively and accurately evaluate the criteria established
in Section 9.1 Monitoring and Measurement??

2.

3.

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 Evaluation Question Yes/No Comments

3.

Significant Aspect: Fuel Dispensing

Significant Aspect: Spills and Leaks

Source: FTA/VT ESMS Institute Homework, MTA, 2016

Contact: Robert Frazier, Environmental Manager,
1515 Washington Boulevard, Baltimore, MD 21230
Phone: 410-454-7317
Email: [email protected]

3.3.2 Examination, Investigation, Evaluation — Calibration

BART
BART provides an example to show its steps for conducting the calibration process including the calibration of
equipment, responsibilities and recordkeeping.

9.1 Calibration/Preventative Maintenance Log Template

Process for calibration of equipment, responsibilities and record keeping-

Competent 1.0 Per Strategic Maintenance Program (SMP), calibration requirements at the (Facility Name), schedule calibration for the environmental
Person monitoring equipment.
2.0 Schedule Approved by the Competent Person.

Supervisor 3.0 Delegate calibration to outside vendors or qualified personnel, as described in the SMP.

4.0 For calibration by outside vendor:

• Submit requisition for calibration to the Purchasing Department.
• Coordinate the release of the device to the vendor.
• Upon eventual return of the calibration device and associated paper work, go to step 8 of this outline.
5.0 For in-house calibration: assign calibration job to qualified personnel

Qualified 6.0 Calibrate device. Fill in requested information of the calibration record form. (Organization and equipment specific form)
Personnel
7.0 Return calibrated device and completed form to the Competent Person.

Competent 8.0 Review the calibration record form and other documents, as appropriate, and then sign approval on the form. If calibration was not achieved or
Person was not adequate, suspend reinstallation or reuse of the device until the situation is resolved.
9.0 If a piece of test equipment is found to be out of calibration, review the calibration records. Schedule recalibration of any instruments
calibrated using the test unit in question.

Administrative 10.0 File and maintain calibration record forms. Retain records in accordance with 7.5.3 Control of Documented information

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 Equipment Calibration/Preventative Maintenance Log
Location of Brand Name Model or Calibration/Preventative Method of Calibration
Equipment Name Comments
Equipment or Make Serial # Maintenance Frequency
PG&E Electricity Standards for Meter
Last tested on 1/12/2014;
M90 Meter at 421 John Installation, Maintenance, Calibration conducted by
Unk Unk Will be scheduled this
(Example) Daly Blvd, Daly Testing and Calibration PG&E as responsible party
year 2017.
City 94014
PG&E Electricity Standards for Meter
Last tested on 1/12/2014;
Meter at 421 John Installation, Maintenance, Calibration conducted by
M90 Unk Unk Will be scheduled this
Daly Blvd, Daly Testing and Calibration PG&E as responsible party
year 2017.
City 94014

Source: FTA/VT ESMS Institute Homework, BART, 2016

Contact: Bob Powers, General Manager, San Francisco BART
300 Lakeside Drive, Oakland, CA 94612
Phone: 510-464-6060
Email: [email protected]

MTA
MTA provides an excellent example of what a tracking matrix might look like to establish clear evidence that
your calibration program is effective. Please note that the rows and columns are very specific — each piece
of equipment is identified by brand and serial number, as well as the frequency of calibration needed and the
person responsible. Finally, the last date of calibration is listed so that the responsible person can determine
the schedule to make sure the equipment is ready for service.

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 Equipment Calibration Log
Equipment ID
Brand Name Model or Date of Most Recent
or Location of Equipment Name Calibration Frequency Calibration Responsibility
or Make Serial No. Calibration
Equipment

Overfill
prevention All equipped ASTs Multiple Multiple Annual MTA Environmental Manager
devices

6,000 gallon
Diesel Dispenser Gasboy 9852AXD Annual MTA Environmental Manager
AST

6,000 gallon Diesel Dispenser Leak

Gasboy Unknown Annual MTA Environmental Manager
AST Detection

C-3, C-4, C-5,

C-6, C-7, C-8, Warrick Control Alarm Warrick Controls
7880087 Annual MTA Environmental Manager
C-9, C-10, C-11, Panel (Gems Sensors)
C-12
C-3, C-4, C-5,
C-6, C-7, C-8, Warrick Controls
Liquid Level Sensor Multiple Annual MTA Environmental Manager
C-9, C-10, C-11, (Gems Sensors)
C-12

Interstitial Leak Warrick Controls

C-4, C-7, C-10 DLP-1 Annual MTA Environmental Manager
Detection Sensor (Gems Sensors)

Pneumatic Level
C-4, C-6 Control Valve (Overfill Balcrank 4520-001 Annual MTA Environmental Manager
Prevention)

C-25, C-26, C-
Level Sensor Multiple Multiple Annual MTA Environmental Manager
27, C-28

C-19 Low Fuel Level Sensor Kohler Unknown Annual MTA Environmental Manager

Interstitial Leak
C-19 Kohler Unknown Annual MTA Environmental Manager
Detection Sensor

Emergency Shut-Off
C-19 Unknown Unknown Annual MTA Environmental Manager
Switch

Rochester
C-19 Liquid Level Gauge 6500 Series Annual MTA Environmental Manager
Gauges

Liquid Level Clock

C-13 Morrison Brothers Figure 818 Annual MTA Environmental Manager
Gauge

C-13 Liquid Level Sensor Veeder-Root Unknown Annual MTA Environmental Manager

Interstitial Leak
C-13 Veeder-Root 794390 Annual MTA Environmental Manager
Detection Sensor

Source: FTA/VT ESMS Institute Homework, MTA, 2016

Contact: Robert Frazier, Environmental Manager
1515 Washington Boulevard, Baltimore, MD 21230
Phone: 410-454-7317
Email: [email protected]

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3.3.3 Appraisal of the ESMS — SORTA
In order to improve operations, it is important to conduct internal assessments to independently evaluate the
performance of your ESMS. An internal assessment team needs to be created that will consist of members of your
own organization. This team will check to see that what has been stated in your ESMS is, in fact, being done. A
phrase often stated in many organizations is “Trust, But Verify.” One of the more difficult elements of conducting an
internal assessment involves what to do when the assessment is completed. You must define the steps needed to
convey the findings and what is done with the findings afterwards.

SORTA’s ESMS document provides an example of procedural items to address when conducting an internal
assessment.
4.0 Process
4.1 The ESMS designated auditor receives internal ESMS auditor training. The auditors
will carry out audits and report the results to the Core Team and management
personnel responsible for the area being audited.
4.2 The intention or notification to perform an internal ESMS audit is coordinated and
communicated by the ESMS Core Team to the affected departments.
4.3 Based on environmental importance, an audit of the ESMS will be conducted
annually. Areas of concern from previous audits (e.g. major nonconformance
findings) will be documented and routinely audited.
4.4 Prior to the initiation of the internal ESMS audit, the auditor will conduct a brief
opening meeting with individuals from the affected areas.
4.5 The ESMS auditor is provided a checklist, EP 9.2-1FB Internal ESMS Auditing
Checklist, which will assist in the basis of the audit. These checklists will be
relevant to the department areas. The auditor may review and amend the audit
questions and use other types of appropriate auditing documentation.
4.6 During the internal ESMS audit, the auditor will record audit observations on the
checklists and other designated working papers only. These documents will be
returned at the end of the audit and become records of the audit observations.
4.7 Nonconformance findings requiring corrective action are documented on EP 10.1-
1FA Corrective Action Request (CAR) forms. The CARs will be compiled into a list
and documented on EP 10.1-1FB Corrective Action Log / Report form. These forms
follow the EP 10.1-1 Nonconformity and Corrective Action procedure.
4.8 The ESMS auditor will evaluate CARs for completion and effectiveness.
4.9 All observations and recommendations for improvement are documented on
checklists, CARs and/or other appropriate documentation.
4.10 The ESMS auditor will present the relevant CARs to the department manager
responsible for the area of the nonconformance. A copy of the documents will be
kept and forwarded to the ESMS Core Team with the checklists and other
appropriate documentation at the end of the audit.
4.11 All nonconformance items documented by the ESMS auditor during the internal
audit are to receive timely and thorough corrective and preventive actions, as
appropriate by the management of the area responsible, per the EP 10.1-1
Nonconformity and Corrective Action procedure.
4.12 Upon the close of the audit, the auditor will conduct a closing meeting to present a
summary of the internal ESMS audit findings to the relevant personnel.
4.13 Results of the internal ESMS audits are formally communicated to Senior
Management on an annual basis during the Management Review Meeting as per
the EP 9.3-1 Management Review procedure.

Source: FTA/VT ESMS Institute Homework, SORTA, 2017

Contact: T J Thorn, OHST, TSSP, Vice President, Safety and Security/Chief Safety Officer
1401 Bank Street, Cincinnati, OH 45214-1737
Phone: 513-632-7651
Email: [email protected]

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3.3.4 ESMS Review by Management — MTA
Evaluation of performance of your ESMS includes a very important step, and that is – review by management.
Review by top management is critical to the success of the ESMS by assuring that top management is
knowledgeable of the impacts of the program and the progress the organization is making. It demonstrates
top management’s commitment to the ESMS and allows them to direct needed changes in resources to
improve their organization’s performance. To properly assess the status of the ESMS by top management,
a detailed agenda ensures that all needed components of review are identified, addressed and documented
through a written record. Activities that are implemented as a result of this review are further indications to the
staff that top management is involved and committed.

One area of particular concern is that the ESMS review by management process meets the requirements of
your ESMS. Frequently organizations miss reportable items and senior management’s documented decisions.
A well-designed agenda will ensure that all items are addressed. MTA has provided an example of an ESMS
Review by Management Meeting Agenda. This example contains ISO 14001:2015 terminology.

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 ESMS Management Review Meeting

Date: December XX, 2016

Time: ?

Location: ?

I. Opening Remarks

II. ESMS Overall Description

III. What are:

a. External and internal issues that are relevant to the ESMS

b. Compliance obligations
c. Significant environmental aspects and risks and opportunities

IV. Information on MTA’s environmental performance, including trends in:

a. Extent to which the objectives and targets have been met

b. Nonconformities and corrective actions
c. Monitoring and measurement results
d. Conformity to our obligations
e. Audit Results

V. Recommendations for improvement (Actions, if need when objectives have not been)
met

VI. The adequacy of resources required for maintaining an effective ESMS

VII. Communications from external interested parties, including complaints

VIII. Decisions related to continual improvement opportunities

IX. Conclusions on the continuing suitability, adequacy and effectiveness of the ESMS

X. Opportunities to improve integration of the ESMS with other business processes

XI. Any implications for the strategic direction of the organization

XII. Next Steps

Source: FTA/VT ESMS Institute Homework, MTA, 2016

Contact: Robert Frazier, Environmental Manager
1515 Washington Boulevard, Baltimore, MD 21230
Phone: 410-454-7317
Email: [email protected]

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3.3.5 Nonconforming Practices and Remedial Action — MTA
The nonconforming practices and remedial action process are essential for ensuring that your ESMS remains
on track and is consistent with your ESMS goals and targets. MTA provides an excellent example of a
Corrective Action request form that defines all of the steps needed to address identified problems within your
ESMS.

Please note that the process includes a root cause assessment step to find the true cause of the defect,
not just a symptom. Also, Section F. requires a verification step to ensure that the remedial action taken is
effective. MTA’s example contains ISO 14001:2015 terminology.

Maryland Transit Administration Person resp Prepared by Reviewed by Approved by

Page 1 of 2
Cromwell Light Rail Station facility

ESMS – Nonconformity and Corrective Action

EP-10-10.2-1FB Corrective Action Request (CAR)

DEPARTMENT: CAR REPORT #:

(Section A. - B. to be completed by Originator)

A. Audit Area Location:

B. Description of Issue: Nonconformance: Opportunity for Improvement:

ISO Clause Reference:

Issued to Area Rep.: Originator:

Date: Date:

(Section C. - E. to be completed by EMS Team or Area Representative)

C. Root Cause:
Identify and list Root Cause(s) using the Root Cause matrix (EP-10-10.2-1A Nonconformity Procedure Attachment)

Describe the contributing causes:

D. Short Term Corrective Action: (Containment)

Target Date: Project Manager:

E. Long Term Corrective Action:

Ensure compliance obligations for this clause are reviewed and updated annually.

Target Date: Project Manager:

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Maryland Transit Administration Person resp Prepared by Reviewed by Approved by
Page 2 of 2
Cromwell Light Rail Station facility

ESMS – Nonconformity and Corrective Action

EP-10-10.2-1FB Corrective Action Request (CAR)

(Section F. to be completed and signed by the EMS Management Representative and the core EMS Team)

F. Verification:
Date of Completion:
EMS
EMS Team Member:
Man. Rep.
Signature: Signature:

Date: Date:

Source: FTA/VT ESMS Institute Homework, MTA, 2016

Contact: Robert Frazier, Environmental Manager
1515 Washington Boulevard, Baltimore, MD 21230
Phone: 410-454-7317
Email: [email protected]

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3.3.6 Enhancement of the ESMS — SEPTA
A key activity for maintaining your ESMS is the requirement for constant enhancement of your ESMS and
thus your program to enhance your efforts to protect the environment and improve efficiency. SEPTA has
demonstrated this commitment through its efforts to enhance by implementing its second-generation
Sustainability Program, SEP-TAINABLE 2020, and integrates multiple programs including recycling, renewable
energy, stormwater management, and an expansion of their ISO-Certified ESMS — see details below.

The proposed second-generation Sustainability Program, SEP-TAINABLE 2020, aims

to build on these successes, and adopts aggressive performance targets. Plans include:

• A Recycling Program refresh, in which SEPTA has begun to strategically install

recycling receptacles at employee facilities and passenger stations to increase
waste diversion rates and reduce costs associated with a multi-year hauling
contract.

• A Renewable Energy Plan, building off an existing solar proposal to explore

budget-neutral opportunities for adoption of renewable energy to reduce
greenhouse gas (GHG) emissions.

• A Stormwater Management Plan, which would seek cost-effective opportunities

to reduce fees associated with impervious surfaces through a partnership with
the Philadelphia Water Department and strategic implementation of green
infrastructure.

• An expanded ISO-Certified ESMS program to include the Wayne Shop as well

as implementation of an "ISO Lite" program to introduce environmental
management best practices at all SEPTA facilities.

As with the first-generation plan, the SEP-TAINABLE 2020 program plan has been
developed through extensive input, including stakeholder roundtables, a public open
house, peer agency benchmarking through APTA, and collaboration with key regional
planning partners from the Delaware Valley Regional Planning Commission, City of
Philadelphia and Bucks, Chester, Delaware, and Montgomery Counties.

Source: SEPTA – WEBSITE http://www.septa.org/strategic-plan/updates/sep-tainable-2020-report.html

NOVEMBER 12, 2020
Contact: Erik Johanson, Sustainability Program Director, SEPTA
1234 Market Street, 4th Floor, Philadelphia, PA 19107
Phone: 215-580-8113
Email: [email protected]

4. Closing — Living Document

This ESMS Best Management Practices Guidebook is a living document and will be updated periodically to
reflect new transit organization or industry best management practices. Please check our website periodically
at https://www.transit.dot.gov/regulations-and-guidance/environmental-programs/environmental-programs

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