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Multi-Media Compliance Services
ENVIRONMENTAL MANAGEMENT SYSTEM
REVIEW, EVALUATION, AND TRAINING
Hawaii Department of Transportation, Hawaii
EA was contracted by the Hawaii Department of Transportation (HDOT), as a subcontractor to EnviroServices & Training Center, LLC, for this project. EA's scope of work covered half of 38 HDOT maintenance facilities statewide. Specifically, EA completed an environmental regulatory compliance assessment and conformance evaluation of the HDOT Environmental Management System (EMS) with respect to federal, state, and local requirements at a total of 19 maintenance facilities statewide (7 Harbors Division and 12 Highways Division on the Islands of Oahu, Kauai, Hawaii, Maui, Molokai, and Lanai). The information obtained during the environmental compliance audit was used to develop Compliance Checklists that will be used at all HDOT maintenance facilities.
Additionally, EA evaluated the conformance of the 12 elements central to the EMS based on the U.S. Environmental Protection Agency National Enforcement Investigation Center (NEIC) EMS model, which incorporates the globally-recognized EMS specifications of International Standards Organization 14001. The EMS evaluation identified where systems or subsystems have not been adequately developed or implemented. An Action Plan document was developed to serve as a management tool for integrating EMS requirements at HDOT maintenance facilities. The Action Plan addressed gaps in the EMS and provided guidance toward the further integration and continuous improvement of an overarching EMS that is consistent with HDOT’s commitment to the protection of human health and the environment.
EA conducted training for over 125 facility managers and maintenance staff that consisted of three modules including: general awareness overview of the HDOT EMS; an overview of the pertinent environmental compliance regulations; and use of regulatory compliance, best management practice, and pollution prevention checklist as a way to monitor ongoing compliance. A walk-through with the facility managers in how to use the checklist was conducted, and potential compliance findings were identified. Potential compliance findings were documented and presented to the Hawaii Department of Health and U.S. Environmental Protection Agency for self-auditing purposes. Corrective action recommendations were made and facility managers were encouraged to remedy compliance violations and potential best management practice and pollution prevention issues.
An EMS Manual was developed to communicate HDOT’s commitment to maintain and improve its EMS. The EMS Manual defines the scope and provides a roadmap of how HDOT will specifically address the 12 NEIC elements. Based on the “Plan-Do-Check-Act” process, the EMS Manual emphasizes the importance of establishing critical components of policy, organization, oversight, and responsibilities to support implementation of processes and procedures outlined in the manual.
At the conclusion of the project, an Evaluation Report was completed that reviewed HDOT’s implementation status of the 12 NEIC elements. Conformance status was once again presented to HDOT and recommendations for continuing improvement were provided. Additionally, a summary of potential findings identified during the compliance checklist training and assessment for each of the environmental requirements at all 19 maintenance facilities were also provided to HDOT.
Through this multifaceted approach, EA successfully evaluated current HDOT EMS practices, provided recommendations for addressing program weaknesses and compliance violations, and established site-specific baseline environmental compliance data that, in conjunction with self-audit practices, allow facility managers to track their progress toward achieving environmental improvement goals.