An EMS can and should be designed with pollution prevention in mind; i.e., eliminating pollution at the source. This means incorporating practical tools into the elements of the EMS, as is described in the table below from Research Triangle Institute found at Pollution Prevention Connection with ISO 14001. RTI has made available online the Environmental Management Systems Evaluation Tool, an interactive guide to integrating P2 into an EMS. It provides a thorough review with a report indicating how well P2 integration is in place, along with recommendations for improvement of an EMS to achieve results beyond what is required by ISO 14001.

The basic principles of an EMS are described in Improving Environmental Performance and Compliance: 10 Elements of Effective Environmental Management Systems. The following list identifies suggested P2 strategies for each element:

1. Environmental Policy

• Involve all staff at all levels in practical solutions for process and environmental improvement.
• Constantly improve resource efficiency and EMS performance.
• Account for all the costs of waste and pollution and assign them to their sources.
• Design products that minimize environmental impacts throughout their life cycle.
• Purchase environmentally preferable products and services when practical, especially less-toxic and recyclable materials.
  

2. Environmental Requirements and Voluntary Undertakings

• Link all identified environmental aspects to the internal sources or activities that affect them.
• Forecast environmental regulations and other external requirements and brainstorm P2 solutions that can mitigate or avoid them.
• Identify process and product improvement requirements that will be necessary for competitiveness and develop environmental performance goals for them.
• Identify regulatory and other programs that encourage pollution prevention and learn how to cooperate with them for business and environmental advantage.
• Ensure all plans for compliance support also include components for pollution prevention related to compliance.
  

3. Objectives and Targets

• Establish quantifiable and readily-measured goals for resource efficiency, toxics reduction and waste reduction at the process level. Have process workers design indicators that they can measure and manage themselves in real time.
• Establish objectives and targets for improving the management accounting process for assigning all compliance and environmental costs to responsible activities.
• Develop an index for the environmental impact of products and services and establish goals for improving the index performance.
• Create knowledge improvement targets to ensure that effective P2 solutions from around the world are not overlooked.
  

4. Structure, Responsibilities and Resources

• Make all process supervisors and department managers responsible for the environmental performance of their units. Minimize the number of dedicated environmental staff.
• Use full-cost accounting to link P2 performance to the budget and to employee compensation rules.
• Include P2 performance in job descriptions and employee evaluations.
• If feasible, rotate staff between compliance and production responsibilities.
• Give highest decision-making priority to projects with potentially significant P2 benefits.
  

5. Operational Control

• Have activity workers produce simple process diagrams that are readily available and have basic statistics on wastes and emissions at every step.
• Provide simple procedures for measuring and reporting on process or product environmental impact that give the employees feedback in real time (these might include process controls such as water sub meters, run charts on waste generation or water use, etc.)
• Establish a procedure to ensure that the P2 Hierarchy is followed consistently in all decisions regarding environmental performance.
• When documented procedures for activities are required because their absence could cause significant environmental impacts, establish additional procedures to ensure that these activities are given highest priority for P2 action.
• Have a procedure for regularly reporting on P2 progress to senior management.
  

6. Corrective and Preventive Action and Emergency Procedures

• Apply the P2 Hierarchy in all corrective and preventive actions.
• Use a hazard analysis to identify potential emergency situations and make the related activities a priority for P2.
  

4. Training, Awareness and Competence

• Provide modules on P2 in all existing training.
• For staff with significant environmental aspects to manage, ensure that required EMS training includes detailed P2 methods and solutions.
• Besides basic training in P2 concepts, ensure all staff have basic training in specific P2 resources and solutions applicable to their functions (such as accounting, marketing, design, etc.).
• Give key staff training in how to use the Internet to tap into the local and global network of practical P2 solutions.
• Use case study data in training to show the real business benefits of P2.
  

5.Organizational Decision-making and Planning

• Use life-cycle analysis to identify environmental threats and opportunities up and down the product or service chain that could affect business performance, from natural resource harvesters to product disposers.
• Develop proactive strategies to minimize environmental risks in the product or service chain.
• Ensure that all senior managers have specific P2 goals to meet.
• Integrate P2 strategies into planning for business-driven process and product changes.
• Empower and encourage work teams to pro-actively make P2 improvements that do not need significant capital or other resources.
• Give priority in decision-making to proposals that could significantly improve environmental performance.
  

6. Document Control

• Ensure that data on process environmental performance, fully-loaded materials costs (including waste management costs), and waste fate is made readily available and understandable to relevant staff.
• Use electronic documentation to minimize paper use and improve records management.
• Document all P2 suggestions, implemented or not, in a standard form and collate them as a reference tool for staff. Ensure the documents are reviewed and updated regularly.
  

7. Continuous Evaluation and Improvement

• Ensure that environmental evaluation is directly linked to evaluation of responsible products and processes.
• Encourage self-evaluation and improvement processes among worker teams.
• Use performance audits as P2 opportunity assessments.
• In P2 assessments, use cross-discipline teams including representatives of all line departments and support departments.
• Establish a solid process for getting P2 improvement ideas from outside the organization, including training, networking, use of Internet, etc.
• Establish benchmarks for P2 performance with leading competitors and/or others and use these to evaluate and improve performance.

Two US EPA guides explain how to integrate P2 into EMS. Both are written for small and medium enterprises (SMEs):

• Environmental Management Systems: An Implementation Guide for Small and Medium Sized Organizations.
• Integrated Environmental Management Systems Implementation Guide.

An EMS does not necessarily promote pollution prevention. The report "ISO 14001: A Discussion of Implications for Pollution Prevention" was an early paper developed by the National Pollution Prevention Roundtable to address the small emphasis that ISO 14001 offers for pollution prevention. This potential disconnect is also pointed out in EPA’s recently revised Facility Pollution Prevention guidance manual; the new version, An Organizational Guide to Pollution Prevention, describes three implementation approaches to P2, one of which uses an EMS to develop successful P2 programs and projects. The State of Washington developed a document, Environmental Management System (EMS) Alternative to Pollution Prevention Planning [pdf], directed to facilities required to do P2 planning.

But the opportunity for improving P2 performance does exist with a well-executed EMS. A preliminary University of Oregon study indicates that firms with ISO 14001 certification have reduced emissions compared to a control group of firms not certified. Several US States are moving to explicitly integrate EMS and P2 in their assistance to small and medium sized enterprises. A portion of the article "Pollution Prevention: The Cost-Effective Approach to ISO 14001 Compliance" provides guidance on how to incorporate P2 principles into an EMS. It appears that facilities that have pollution prevention plans in place have demonstrated improved performance to facilities without such plans. The suggestion has been made in a study [pdf] of the National Database on Environmental Management Systems (NDEMS) that a similar differentiation of performance would occur with EMS implementation by enterprises such as SMEs.