On Campus

38 � Division of Chemical

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More – and less – about EMS

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I n the last column, I spent some timedescribing two common uses of the term‘‘Environmental Management System,’’

or EMS. One, the ‘‘true EMS’’ is a managementsystem that seeks to reduce actual environmen-tal impact. I differentiated this kind of EMSfrom a ‘‘Compliance Assurance ManagementSystem’’ (CAMS) because compliance rarelyequates to actual environmental protectionon college and university campuses, and trueEMS rarely include compliance in their scopeof work.

Nowadays, some agencies are, however,using the term EMS to mean a new and whollydifferent concept. Like the true EMS, this pro-cess centers on an organization’s overt com-mitment to environmental protection, but it isan agreement between regulatory authoritiesand the organization about how the regulatorswill address concerns on site. Rather thanbeing a system that, in and of itself, createssuperior environmental performance orimproved documentation of complianceefforts, this system removes the potentiallyhostile interaction between regulators andthe regulated community. As such, this is moreof a Regulatory Relationship Management Sys-tem (RRMS) than either a true EMS or CAMS.

Like the true EMS, the RRMS requires anovert organizational commitment to environ-mental protection. Like the CAMS, the RRMSrequires organizational commitment to thespirit, and probably some of the more impor-tant letters, of the law. However, the RRMS is,in effect, a memorandum of understandingbetween a firm and its regulators, agreeing to

lth and Safety of the American Chemical Society

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the process of inquiry once some basic controlsare in place (policy, plan, resources, evaluation,measurement, etc.).

Under an RRMS, a single agency can brokera deal with a campus, and then use that modelto facilitate interactions with other agencies,should that become necessary. This kind ofpartnership is a progressive model for theinterim state of regulatory impact on campus.Because the RRMS redefines the relationshipbetween the regulators and the regulated com-munity, the organization should get more lati-tude over how it meets the regulatory concern,because it creates a performance orientedapproach to regulatory issues. Though it willprobably require extra effort on the part of thecampus as quid pro quo, the campus can relyon the terms of the agreement to eliminatenuisance inspections and citations – as forthose administrative issues that no campus willever be able to avoid completely. This lets thecampus stop chasing its own tail by trying todot every I and cross every t in an effort topalliate some state regulator’s vision of institu-tional compliance.

Naturally, the real solution to this problem istrue performance-oriented regulation, but it willtake an act of Congress, literally, to dislodge thecurrent scheme. Of course, the RRMS is not anEMS, nor is it a CAMS. But it might just be theholding action campuses need to tide them overto a time when Congress agrees that educationis the single most important sector in the econ-omy, and when the EPA agrees that 25-year-oldregulations built for industry might just not fitresearch and teaching.

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doi:10.1016/j.chs.2004.11.001