An EnvironmentalAn Environmental Management System for theManagement System for the

Wine Visitor +EducationWine Visitor +Education CentreCentre

By: Khalid MahmoodBabajide Funso

Kelly Baah

1st March, 2012

Table of Contents

1.0 Introduction...........................................................................................................................................................3

1.1 Background........................................................................................................................................................3

1.2 Company Profile.................................................................................................................................................3

2.0 Baseline Data.........................................................................................................................................................4

2.1.0 Findings...........................................................................................................................................................4

2.1.1 Mass Balance...............................................................................................................................................4

2.1.2 Potential environmental issues and concerns arising from day to day operations.....................................5

2.1.3 Existing Management and operational practices........................................................................................5

2.1.4 Previous Accidents or Incidents...................................................................................................................5

2.1.5 Legal requirements.....................................................................................................................................5

3.0 Environmental Policy.............................................................................................................................................6

4.0 Objectives and Targets...........................................................................................................................................6

4.1 Definitions..........................................................................................................................................................6

4.2 Objectives and Targets/Plan of Action and Milestones....................................................................................7

4.3 Achieving and Improving Objectives and Targets...............................................................................................9

5.0 Proposed Action.....................................................................................................................................................9

6.0 Organization...........................................................................................................................................................9

5.2 Responsibility...................................................................................................................................................11

5.2.1 Top Management......................................................................................................................................11

5.2.2 Environmental Management Representative (EMR).................................................................................11

5.2.3 Deputy Environmental Management Representative (DEMR)..........................................................................11

5.2.4 Environmental Management System Committee (EMS Committee).........................................................12

5.2.6 Function / Departmental Manager..................................................................................................12

5.2.7 All Employees...................................................................................................................................12

6.0 Resource Allocated..............................................................................................................................................12

7.0 Budget..................................................................................................................................................................13

8.0 Schedules.............................................................................................................................................................13

9.0 Sign-offs...............................................................................................................................................................13

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1.0 INTRODUCTION

1.1 BACKGROUND

The purpose of this report is to develop an Environmental Management System for the Wine Visitor and Education Centre of Niagara College. An Environmental management system (EMS) is a tool used by organizations to improve environmental performance. It provides a systematic way of managing an organization’s environmental affairs and also addresses immediate and long-term impacts of the organization’s products, services and processes on the environment.

In addition to improving the environmental performance of the Wine Visitor and Education Centre of Niagara College, the development and implementation of an Environmental Management System can yield the following key benefits;

o Reduced operating cost ( through waste reduction, energy conservation and other mechanisms);

o Improved environmental performance and enhanced company image;

o Improved access to financing, capital or insurance;

o Provide assurance to costumers of the organization’s commitment to environmental management;

o Improved investor/financial donor satisfaction through better environmental performance and reduced cost;

o Reduced liability from incidents/ external risks by providing a structured framework for; identifying and meeting regulatory requirements;

o Improved government relations with the organization; and

o Added benefits of receiving ISO certification

1.2 COMPANY PROFILE

The Wine Visitor and Education Centre, is the first of its kind on-campus facility in North America. The centre is located in Niagara College’s Niagara on-the-Lake campus, strategically positioned at the base of the Niagara Escarpment- a UN World Biosphere reserve. The Centre was officially opened in 2009 following an historic visit by His Royal Majesty the Prince of Wales.

Part of the products and services offered by the Centre, includes wine tasting counters, retail wine sales, interactive displays, room for seminars, meetings and presentations. The Wine Visitor and Education Centre, also has a non-profit wine manufacturing facility which produces an average of 45,000 to 50,000litres of wine per year. The Centre celebrates Ontario and Canadian wines, and is the home of the Niagara College’s Teaching Winery programs.

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2.0 BASELINE DATA

To facilitate the development of the EMS, an Initial Environmental Review (IER) was carried out. The IER assessed four key areas namely potential environmental issues and concerns arising from day to day operations, existing management and operational practices, previous environmental accidents/incidents and legislative requirements of the facility. Details of the documented IER report for this facility can be found in Appendix XX.

2.1.0 FINDINGS

2.1.1 MASS BALANCE

Figure 1.0 Schematic representation of inputs, processes, outputs and associated impacts on the environment

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InputsGrapes, Electricity, Water, Yeast, Nutrients, Human resource/Manpower, chemicals such as hydrogen peroxide, acidic and basic lab buffers.

OutputWine, CO2, Waste water, Organic waste, Cardboard waste, paper waste, glass waste and other related waste.

Processes

Crushing, Fermentation, Clarification, Teaching, learning, seminars, wine tours,

Impact on Air, Land and waterLand degradation, spent yeast, Greenhouse gas emissions from coal power plants, nuclear waste from nuclear power plants, etc.

Impact on Air, Land and waterCO2 emissions during fermentation, Global warming, organic waste (from pressed grape skins and spent yeast) disposed on land, waste water

Impact on Air, Land and waterCO2 emissions from fermentation, global warming, eutrophication of water-bodies through disposal of waste with high organic matter content, Landfill

2.1.2 SIGNIFICANT ENVIRONMENTAL ASPECTS OF THE WINE & VISITOR CENTRE (NOTL)

Functional area Environmental Aspect

Output Environmental Impacts

Potential to seriously damage the Environment (Yes/No)

Any Legislative requirement? (Yes/No)

Any public concern (s) relating to this aspect?

(Yes/No)

Sorting of grape bunch after harvesting: culling out rotten or under ripe fruit.

Water Waste, Waste water

Water pollution,

Waste disposal on land

Yes No Yes

Crushing Electricity, Water, Propane (forklift)

Solid waste (pressed skins)

Waste disposal on land

Yes No Yes

Fermentation Yeast, Nutrients

Must (Grape juice)

CO2, Wine GHG Emission

Yes No Yes

Clarification Finning agents (bentonite, casein - milk protein)

Spent yeast and solid precipitates

Water pollution, Land degradation, GHG emissions

Yes No Yes

Bottling Electricity, Paper & Glue

Frequency is 2wice a year (spring and late summer/fall)

Bottled wine, broken bottles

Air pollution (Coal power plants), Radioactive waste (Nuclear power plants), Impact on aquatic ecosystems (Hydro power plants)

Yes No Yes

Laboratory Acidic and Basic pH buffers

Laboratory waste

Soil and surface water contamination

Yes Yes- Occupational health and safety requirements- WHMIS

Yes

Laboratory, Used in Cleaning manufacturing equipments

Hydrogen Peroxide N/A, highly volatile

Strong oxidizer, corrosive, gives off explosive vapors at 70oC

Yes Yes- Occupational health and safety requirements- WHMIS

Yes

Note: Aspect is considered significant if it answers “Yes” on any one of the three questions above pertaining to impact on the environment, legal requirements and/or public concern(s).

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2.1.3 POTENTIAL ENVIRONMENTAL ISSUES AND CONCERNS ARISING FROM DAY TO DAY OPERATIONS

A review of the operations of the Wine Visitor and Education Centre revealed the following potential environmental issues;

o High electricity consumption specifically during wine bottlingo High water consumption required for sanitizing and cleaning the wine making equipments

o Organic waste (pressed grape skins)

o Spent yeast and solid precipitate by-product of the wine making process during the clarification phase

o Paper, cardboard, glass, plastic and organic waste generated within the facility by staff, student and visitors

o Chemicals of Concern- hydrogen peroxide, concentrated acidic and basic pH buffersIt is also worth noting that the facility has motion sensor lights as a control mechanism for electricity wastage.

2.1.4 EXISTING MANAGEMENT AND OPERATIONAL PRACTICES Even though no specific environmental policies or management systems exist within the facility, it was observed that necessary precautions and steps have been put in place to minimize and avert any potential adverse impacts of the facility’s operations on the environment. This is so because the facility is obligated to operate in line with the College’s (Niagara College) environmental policy, goals and targets. Occasional audits or site visits are carried out on the facility by internal auditors from the college, to review ongoing operations and facilities on the site. The facility already practices source separation as part of its waste collection and disposal techniques. Organic waste produced from pressed grape skins, over ripe and rotten grapes are separated from the garbage waste stream and designated for composting. The facility also utilizes a sterile waste water collection and disposal system. This involves the use of a control switch to channel water contaminated with organic matter and other contaminants to a waste water treatment plant instead of channeling same into the storm sewer collection system. Uncontaminated water used for rinsing the wine making equipments after cleaning is conversely channeled to the storm sewers. It is also noteworthy that the facility has a material safety data sheet and practice of carrying out mandatory WHMIS trainings.

2.1.5 PREVIOUS ACCIDENTS OR INCIDENTSNo accidents or incidents have been recorded since the facility started operation (2009).

2.1.6 LEGAL REQUIREMENTS

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The legal requirements for which the wine visitor + education centre falls under includes:-

o Vintners Quality Alliance (VQA) Act, 1999, S.O. 1999, c. 3 .o Ontario Regulations 403/00 under the VQA Act.o Ontario Regulations 405/00 under the VQA Act.o Ontario Regulations 406/00 under the VQA Act.o Smart serve certification

3.0 ENVIRONMENTAL POLICY

In line with Niagara College’s aspiration of becoming a leader in sustainable development, the Wine Visitor + Education centre is committed to protecting the environment of the Earth. To minimize environmental impacts concerning our activities, products and services, we shall:-

o Comply with applicable legal requirements and other requirements to which the Company subscribes which relate to its environmental aspects

o Prevent pollution, reduce waste and minimize the consumption of resources

o Educate, train and motivate employees and students to carry out tasks in an environmentally responsible and friendly manner

o Encourage environmental protection among suppliers and subcontractors.

The Wine Visitor + Education Centre, is committed to continual improvement of environmental performance. This Policy will be communicated to all staff, contractors and suppliers, and be available for the public.

Endorsed by:

_________________________

Steve Gill, General Manager

Date:

4.0 OBJECTIVES AND TARGETS

4.1 DEFINITIONS

o Environmental objective – overall environmental goal, arising from the environmental policy, the Wine Visitor and Education Centre of Niagara College set itself to achieve, and which is quantified where practicable.

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o Environmental target – is a detailed performance requirement, quantified when practicable, applicable to the Wine Visitor and Education Centre (Niagara College), that arises from the environmental objectives and that needs to be set and met to achieve those objectives.

4.2 OBJECTIVES AND TARGETS/PLAN OF ACTION AND MILESTONES

Practice: Sewers

Aspect: Wastewater Discharge-Sanitary Waste

Practice Owners

Objective Plan of Action Targets Milestones Status Entry Date

Production line

Reduce excess waste water discharge to

municipal treatment

plant

Optimize equipment

cleaning process

Optimize sludge and residual

organic waste recovery

30% reduction in waste water

discharge by 2014

Sludge and residual organic waste recovery evaluation

StudyPending- Due November 2012

Waste water discharge evaluation study to collect a full

season’s production cycle discharge data

Pending – Due January 2013

Meter installation to track waste water discharge volumes into municipal treatment plant

Pending – Due July 2012

Tracking Methods: Hard copy files – reports and review by EMS coordinator , regular monitoring

Practice: Crushing of grapes after harvesting

Aspect: Solid waste from pressed grape skin

Practice Owners

Objective Plan of Action Targets Milestones Status Entry Date

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Production line

Reduce solid waste from

pressed grape skins

Composting100%

diversion rate by 2013

N/A N/A

Tracking Methods: Documentation of waste generation by assistant wine maker and monitoring of disposal mechanism by EMS Coordinator

Practice: Bottling

Aspect: Electricity

Practice Owners

ObjectivePlan of Action

Targets Milestones Status Entry Date

Production lineReduce

electricity consumption

Market survey on the most energy

efficient technique for

bottling

3% reduction in electricity consumption

Obtaining and providing feedback on survey Pending – Due July 2012

Tracking Methods: Report/feedback to be provided on or prior to assigned due date

Practice: use of hydrogen Peroxides, Concentrated Acidic and Basic pH Lab buffers

Aspect: Potential spill

Practice Owners Objective Plan of Action Targets Milestones Status Entry Date

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Lab analystsMaintain zero spill incident

record

Improve storage

mechanism

Achieve zero spill incident

N/A N/A

Tracking Methods: Measured by Spill Log Review

4.3 ACHIEVING AND IMPROVING OBJECTIVES AND TARGETS

Assistance will be provided to the practice owners throughout the year to ensure the objectives and targets are achieved. This may come in the form of phone conversations, site visits, or emails.

There shall be formal review of the progress towards meeting identified objectives and targets, to be conducted on a semi-annual basis. This review will include an interview of each practice owner to determine what has been done to achieve the target and to obtain feedback on what assistance may be required to help in meeting the objectives and targets.

5.0 PROPOSED ACTION

a) To reduce the excess waste water discharged to the municipal treatment plant, consulting support is proposed to increase residual organic recovery through carrying out technical studies. Introducing monitoring equipment to record the production and volume of waste water drained into municipal sewer lines. Recommendations and then be proffered based on the outcome of technical study. This will augment our resolve to adopt best management practices for improving our environmental performance.

b) A composting facility of 50 tons per year is proposed close to the vineyards. This will not only eliminate solid waste produced from the pressed grape skin but it would be marketed to the vineyards. An estimated income of 25000 $ is likely to be received in a year. The hazardous effect of chemical fertilizers used on the soils of the vineyards will be reduced and organic matter content of the soil will be increased. This recommendation will also reduce nitrogen and phosphorous contamination of runoff water going into water bodies.

c) Since the facility is a small sized non-commercial wine manufacturing facility, not much concern or risk is associated with the storage of chemicals on site. This is so because chemicals are used in relatively minute quantities and do not pose any major risks. Notwithstanding, the existing storage mechanisms for chemicals on site, will be optimized to ensure the 100% accident or incident record regarding spillage is maintained.

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6.0 ORGANIZATION

5.1 ORGANIZATION CHART

The Wine Visitor and Education Centre’s (Niagara College) Organizational Chart capturing major staff and their role in EMS development and implementation. The organizational chart captures top management, functional or departmental heads, and individuals that would comprise the environmental management committee and the management review committee for the EMS.

Figure 2.0: Organizational Chart

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Top Management

General Manager

Retail Manager

Environmental Management Representative

Senior Wine Maker

Deputy Environmental Management Representative

Assistant Wine Maker

Event Planner

Function / Departmental manager

Assistant Wine Maker

Senior Wine Maker

Retail Manager

Management Review Committee

Environmental Management Committee

All Staff and students

Co-Op Student

Project students

Volunteer staff

Part-time staff

5.2 RESPONSIBILITY

This section of the EMS defines the role and responsibilities of the staffs / departments involved in the EMS such as top management, Environmental Management Representative, Deputy Environmental Management Representative, Environmental Management System Committee and Management Review Committee as captured in the above organizational chart.

5.2.1 TOP MANAGEMENT

Top Management is responsible for:

o Endorsing the environmental policy; o Ensuring appropriate resource allocation to enable the effective operation and continual

improvement of the EMS.

5.2.2 ENVIRONMENTAL MANAGEMENT REPRESENTATIVE (EMR)

The Senior Wine Maker position is hereby appointed the EMR and has the responsibility and authority for:

a) Ensuring that EMS requirements are established, implemented and maintained in accordance with the ISO 14001 standard;

b) Ensuring that sufficient resources are allocated for the proper implementation of the environmental policy and the EMS;

c) Regularly reviewing the policy and the effectiveness of the EMS, and ensuring that the necessary changes are made.

EMR is also the Chairman of the EMS Committee and has the responsibility and authority for:

a) Leading the EMS Committee to establish and implement the EMS in accordance with ISO 14001 standard, and monitoring the performance of the EMS;

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b) Coordinating internal EMS audits to ensure the EMS has been properly implemented and maintained;

c) Handling and investigating nonconformity and ensuring corrective and preventive action has been taken to mitigate any impacts caused;

d) Reporting on the performance of the EMS to the top management for review and as a basis for improvement of the EMS.

The EMR, Deputy EMR, EMS Committee and top management shall be responsible for undertaking the EMS management review on an annual basis, to ensure top management commitment and integration of the EMS with business strategies for its implementation and continual improvement.

5.2.3 DEPUTY ENVIRONMENTAL MANAGEMENT REPRESENTATIVE (DEMR)

The Assistant Wine Maker Position is the appointed Deputy EMR and has the responsibility and authority for:

a) Assisting the EMR to ensure the EMS is effectively implemented and maintained

b) Assuming the responsibility and action of the EMR when the EMR is unavailable

5.2.4 ENVIRONMENTAL MANAGEMENT SYSTEM COMMITTEE (EMS COMMITTEE)

This committee is responsible for:

a) The establishment and implementation of the EMS;

b) The establishment and review of objectives, targets, and programmes;

c) Ensuring the effective implementation of environmentally-related operational controls and programmes;

d) The internal communication of environmental matters between management and employees; and promoting environmental awareness among company staff;

e) The review of complaint records, nonconformity, corrective action and preventive action reports and the adoption of preventive actions as necessary;

f) Providing leadership in the pursuit of environmental issues;

g) Any other EMS activities that are assigned by the EMR;

5.2.6 FUNCTION / DEPARTMENTAL MANAGER

The Function / Departmental Managers are responsible for:

a) Establishing controls for the identified significant environmental aspects for his/her function team / department according to procedures and instructions;

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b) Ensuring that the EMS is properly implemented and that environmental matters are properly handled at all stages;

5.2.7 ALL EMPLOYEES

All employees are responsible for:

a) Working in accordance with the documented environmental procedures and instructions, specific responsibilities defined in individual procedures and instructions; and

b) Reporting problems or deviations associated with environmental issues and the EMS to the EMS Committee.

6.0 RESOURCE ALLOCATED

A total sum of $26,500 is earmarked for the establishment and implementation of this EMS. This expenditure would be met partly through donations from the Wine Council of Canada ($10,000) and $16,000 from UNEP special assistance.

7.0 BUDGET

Activity Estimated CostHiring of consultants for the reduction of waste water studies

$10,000

Purchase of equipment for monitoring and tracking of waste water $3000

Installation Cost$1000

Establishing of Composting facility at the wine center $12,000

Market Survey for energy efficient bottling equipment $500

Total $26,500

9.0 SIGN-OFFS

Endorsed by:

_________________________

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General Manager

Date:

10.0 APPENDIX A: INITIAL ENVIRONMENTAL REVIEW

Wine and Visitor Centre, Niagara on the lake campus

Initial Environmental Review Checklist

Location:

Wine and Visitor Centre, Niagara College, Niagara On the lake campus

Interviewer(s):

Khalid Mahmood, Olufunso Babajide, Kelly Baah

Interviewee:

Gavin Robertson

Date of visit: Prepared by:

Kelly Baah, Khalid Mahmood, Babajide Olufunso

1) General Information

a) Organizational Structure (Organization personnel and structure chart)

Board of directors include, college/department staffs and external consultants (estimate of 10board members)

General Manager – Steve Gill of both the brewery and the winery

Wine maker, retail manager (Lauren),

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Events Planner

Several retail staff (6empoyed retail staff, 3part time and 3full time), Assistant wine maker, 1 Co-Opt. Student

Question Response

b) Activities, processes, products Activities include wine making, winery, educational/ tutoring activities,

Wine Production which involves grape processing, fermentation,

Retail events, Sales, Public tours, educational seminars,

Student projects (Winery and viticulture technician program and Wine Business Management)

c) Number of employees 20 tentative (fluctuates with the season). 10 or 12 staff members during the summer period.

d) Environmental Coordinator No environmental coordinator

e) Types of facilities (i.e. office, warehouse, etc.) Four of Offices, wine production centre, conference room, Reception area, laboratory, wine tasting room, 1 class room

f) Type(s) of machinery used Fork lift, Impeller pump, Pneumatic press, grape elevator, grape crusher distemper, cooling unit,

g) Types of goods provided by suppliers Cleaning and sanitizing products, Yeast and yeast nutrients, fining agents, packaging (glass, labels and print), lab analysis apparatus and equipments, lab analysis chemicals, student project equipments (smaller containers for wine making), Wine production equipments (tanks, hoses, brooms, drums), maintenance equipments/tools.

h) Types of services provided by contractors Waste disposal

Criveller – survey, supply and service majority of the wine making equipments.

IT Department from Niagara college, service

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phones and computer itches or glitches

Security -

Horticulture department, gardening services

FMS (Facilities Maintenance service) provide cleaning services

i) Future activities / services N/A will remain in the business of wine making

2) Materials, Energy Usage and Control

Question Response

a) Primary materials consumed and quantities Grapes (80tones annually = 45,000 – 50,000litres of wine) and water (cleaning)

b) Materials purchasing policy Purchase of light weight bottles

c) Waste Management / Recycling practices Organic waste sent to compost pad behind the greenhouse at NOTL

d) Water consumption N/A water is consumed only when necessary. Largest impact or concern is water use for cleaning…..

e) Activities that use primarily water Cleaning (at practically every stage of the production process)

f) Water treatment facilities and / or practices Storm and sterile system: Separated waste water disposal system; two pipes are controlled using a switch to divert grey water and normal storm water to the municipal storm water drainage system. The grey diverted to a waste water treatment plant.

g) Water management policy or conservation measures

None, routine operations for water conservation

h) Electricity consumption Use of Motion sensor lights

i) Major electricity usage Temperature control, lighting, air-conditioning, heating, glycol chilling unit.

Twice a year, a bottling unit consumes 660volt all day during bottling of finished wine products

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j) Electricity management policy or conservation measures

Use of Motion sensor lights

k) Type of fuel consumed and quantity *****Natural Gas for heating, Propane gas for 1 big heater during the winter season

l) Major fuel usage Natural gas

m) Fuel management or conservation measures N/a

n) Other material management policy or conservation measures

N/a

3) Materials Storage and Handling

Question Response

a) Types and quantities of materials stored -Peroxide stored in cool area out of reach and away from any UV radiation

-Finished wine storage- out of sunlight

-Locked cage propane storage

b) Material specifications (i.e. MSDS) Use of an MSDS sheet

c) Material inventory control procedure Lab safety training, MSDS sheet updated annually

d) Expired materials or materials not requiring MSDS

Mostly yeast material disposed off in the garbage

e) Documentation of spills N/A

f) Presence of spill kits / tools N/A

4) Wastewater Management

Question Response

a) Wastewater sources Day to day cleaning, during grape harvesting (cleaning).

b) Characteristics of wastewater Organic******

c) Wastewater treatment method N/A only use of a storm and sterile switch

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d) Wastewater recycling / reuse / minimization policies

N/A ******

e) Location(s) of wastewater discharge Wine production Crush pad

f) Regulatory requirements (i.e. environmental compliance)

Municipal requirements *******

g) Records of wastewater discharges N/a

5) Chemical Waste Management

Question Response

a) Chemical waste sources N/A All chemicals used in the lab are used in low concentrations and there are no hazardous chemicals used….

b) Characteristics of chemical waste N/A

c) Chemical waste handling / treatment / storage method

N/A

d) Chemical waste recycling or minimization policies

N/A

e) Chemical waste disposal practices N/A

f) Regulatory requirements (i.e. disposal licenses) N/A

g) Chemical waste disposal records N/A

7) Solid Waste Management

Question Response

a) Primary types of solid waste Organic waste – Compost pad at the greenhouse, Cardboard recycling, Paper waste

b) Quantity of solid waste generated 20tones of grape skin waste per annum

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c) Waste disposal method Composting

d) Waste reduction / recycling methods N/A

e) Regulatory requirements (i.e. waste disposal, licenses)

N/A

f) Record of solid waste disposal N/A

8) Noise and Other Waste Management

Question Response

a) Noise sources and noise levels

N/A

b) Noise control method N/A

c) Noise control regulations N/A

d) Radioactive waste sources N/A

e) Types of radioactive waste and quantity N/A

f) Regulatory requirements (i.e. licenses) N/A

9) Environmental Incidents / Accidents

Question Response

a) Nonconformity (i.e. material leakage, complaint, warning, non-compliance record)

N/A

b) Date and time of incident / accident N/A

c) Causes on nonconformity N/A

d) Corrective action N/A

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10) Environmental Training

Question Response

a) Existing environmental training programs (i.e. name, time, goal, employees)

None

b) Future training plan No or N/A

11) Environmental Audit

Question Response

a) Any environmental audit conducted None except for waste audits done by EMA students

b) Scope of audit, location N/A

c) Auditor / auditing firm N/A

13) Environmental Management System Requirement

Question Response

a) Environmental policy Always a good idea but the GM with the approval of the board of directors would have the final say

b) Legal or other regulatory requirements Smart serve certification

c) Environmental aspects Water, electricity, chemicals and organic waste

d) Objectives, targets and programs Water consumption

e) Resources, roles, responsibility and authority Management, departmental/unit heads, students and all staffs

f) Competence, training, awareness Yes, required

g) Communication

h) Documentation EMS document

i) Control of documents

j) Operational control ( i.e. standard operating procedures, work instruction)

Yes

k) Emergency preparedness and response None

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Existing emergency plans and procedures for dealing with environmental incidents (i.e. spill, accidental emissions)

Relevant guidance documents or guidelinesTypes of drills conducted, records

l) Monitoring and measurement Required

m) Evaluation of compliance Audits

n) Nonconformity and prevention action and corrective action

Management reviews

o) Control of records

p) Internal audit (reports) None

q) Management review As necessary

r) Environmental initiatives Motion sensor lights, source separation of waste, composting organics, sterile storm water control switch

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