education is at a crossroads with regard to its environmental
performance. On the regulatory front, the Environmental Protection
Agency is putting significant compliance pressure on colleges
and universities. At the same time, interest is rapidly increasing
in many quarters in developing environmentally sustainable communities,
and higher education is seen as a potentially important leader
in this movement. Sustainability advocates look to higher education
both as a test bed for many of their ideas and as the social institution
most likely to incorporate their values in its activities. These
considerations have resulted in a "campus greening"
movement which seeks to use higher education campuses to investigate
the potential of green building initiatives, enhanced recycling
programs, energy conservation technologies, as well as the integration
of sustainability considerations into the fabric of community
believe that the confluence of these trends provides special opportunities
for creative thinking. As higher education works to find the resources
necessary to improve their compliance management systems to meet
governmental expectations, there is a unique opportunity to leverage
these resources and compliance efforts to go "beyond compliance"
and achieve superior environmental performance. We define superior
environmental performance inclusively to include the areas of
regulatory compliance, campus greening (i.e. minimization of environmental
impacts), and educating for sustainability. However, we recognize
that this creative thinking must occur in the highly decentralized
and complex institutional setting that characterizes American
academia. We believe that unless the creativity of those working
towards improving environmental performance in higher education
is framed in the context of management tools, these ideas will
lose their power to create long-term change.
this article, we describe some of the practical lessons we have
learned about Environmental Management Systems (EMS) thinking
and how we might use it to help achieve this potential. These
lessons have developed through the work of the Campus Consortium
for Environmental Excellence (C2E2). Originally organized around
regulatory compliance concerns, the C2E2 has broadened its interests
to include activities that support the continued improvement of
environmental performance in the broadest sense in higher education.
The Consortium's goals are primarily achieved through environmental
professional networking, information exchange, and the development
of professional resources and tools and testing of innovative
regulatory models. One of these resources is the EMS Self-Assessment
Checklist for Colleges and Universities. This Checklist will be
used as the framework for our discussion.
Through our work at the C2E2 (see www.c2e2.org
for a list of members), we know that there is little linkage between
the three component pieces of superior environmental performance:
regulatory compliance, campus greening and educating for sustainability.
Yet, we also know that the components for such excellence often
exist. They exist in the form of underlying values. They exist
in the form of the expertise of faculty and professional staff.
They exist within specific programs, policies and procedures.
Missing is a common tool that allows the variety of people interested
in the issue to unlock the many doors in higher education that
affect environmental performance. Our experience suggests that
the generally agreed upon elements of an effective EMS, loosely
modeled on the ISO 14001 standard, can be one such key.
system is anything that takes its strength and form from the ongoing
interaction of its parts. In other words, we believe every college
and university has a system for managing its environmental compliance
and impacts at some level. However, the problem at small and large
institutions alike is that most institutions have many disparate
systems that affect the environment. These systems need to work
together to be effective, but they often do not.
effective environmental management system (one that is designed
to manage all environmental issues - not just compliance) proceeds
according to the following three principles, which are illustrated
in Figures 1, 2 and 3.
An effective management system has an underlying form that contains
the essential elements of a "Plan, Do, Check, Act" loop,
which creates a cycle of continual improvement. (Figure 1)
2. The elements of an effective management system connect in a
pyramidal fashion, so that an explicit policy sets a clear institutional
goal, and information and guidance needed to support the achievement
of that policy are explicitly described. (Figure 2)
3. Consistent use of this management system form and function
allows for more effective integration of systems within departments,
between decentralized schools or campus-wide as illustrated in
the EMS "Bucky Ball." (Figure 3)
This model has informed the activities of the C2E2, including
the development of Environmental Management Plans for managing
laboratory wastes within the context of an EPA Project XL1
and an EMS Self-Assessment Checklist designed for use by any institution
of higher learning.
Tool That Helps: The C2E2 EMS Self-Assessment Checklist
In September 2000, the Campus Consortium for Environmental Excellence
released version 1.0 of its Environmental Management System Self-Assessment
Checklist for Colleges and Universities. The document was developed
by college and university EH&S professionals to help them
assess the management strength of their compliance programs. However,
we believe that it is equally informative when applied to other
environmental programs in higher education. The entire document
is downloadable from our web site at www.c2e2.org.
checklist was developed primarily for use by college or university
Environmental, Health and Safety professionals to improve their
understanding of the elements of an EMS. However, we have found
that the process of conducting this rapid "gap analysis"
is of significant value in raising awareness of the management
challenges associated with other environmental issues. Because
the tools permit the recognition of effective programs campus-wide,
it is effective in unlocking a variety of improvement opportunities.
campuses have many compliance practices in place, as well as other
programs that work to minimize environmental impacts. In designing
the checklist, we assumed that help is needed in organizing and
integrating such programs for review by upper administration and
regulators. By examining how closely existing practices correspond
to the standard elements of an EMS, the strengths and weaknesses
of the program can be discerned.
In all, there are 33 questions in the Checklist which are broken
down in the "Plan, Do, Check, Act" cycle as follows:
Policy - 7 questions
Planning - 4 questions
Implementation - 14 questions
Checking and corrective action - 7 questions
Management review - 1 question
assessment takes a few hours to complete. Each question corresponds
to a key element of an effective EMS. To facilitate answering
the questions, there is a table beneath each question with four
columns of examples. The column scores (0 -3) generally obeys
the following pattern:
0 (no process in place);
1 (a process exists but because it is unwritten or limited in
scope, it is not fully adequate or effective);
2 (the process generally works well or a procedure has been
articulated, but it is not comprehensive or integrated); or
3 (appropriately comprehensive and integrated procedure exists).
other words, a score of 3 represents an ideal end point. An example
of the scoring for a Planning Section question is illustrated
in Table 1 on the next page.
More than 750 copies of the Self-Assessment have been distributed
at conferences, workshops, and downloaded from the web. In our
conversation with colleges and universities, we have found that
many mid to larger institutions are using this or a similar EMS
"Gap Analysis" tool to evaluate their program management.
The feedback about the utility of the tool has been largely favorable,
although feedback has also pointed to the need for a variety tools
for going beyond the assessment phase and designing and implementing
better EMSs at colleges and universities based on best practices.
The following points represent some of the primary lessons learned.
campus-wide "total" scores fall somewhere in the
range of 35 - 65. Because the sections contain different numbers
of questions, a strength or weakness in a particular section
may skew the overall score. Some users have normalized the
scores across sections to overcome this problem.
The lowest scores are typically found at institutions without
an environmental policy. Institutions often gain a majority
of their points in the category of "Implementation"
and lose points in "Policy" and "Checking and
Corrective Action." In other words, a program defined
is a program effectively implemented. However, a program implemented
is unlikely to be tracked for performance or measured for
success. This latter category is clearly a weak link for many
institutions or programs. The higher scores typically come
from an institution that has strong upper administration support
and therefore has a policy and an obligation to conduct program
reviews for reporting to senior management.
We have found that the value of scoring is not the absolute
result, but simply that there is a score! This score can be
compared against departments, schools or across campuses if
there is reason to believe that the people doing the score
have followed the same criteria. We have seen the competitive
juices and grade-conscious culture of universities stimulated
to improve their score, and thus their performance.
That said, few universities are willing to share their scores
with external parties. Some universities have voiced concern
that such scores may be discoverable by the EPA. Because this
self-assessment is a "beyond compliance" initiative,
unrelated to any regulation enforced by the EPA, we believe
that there is little risk that this exercise can be used against
a university. In any case, it is unlikely that U.S. News and
World Report will soon set EMS or "Greening" as
a key criterion that is scored in its annual survey of colleges
Most institutions have found that the greatest value of this
rapid self-assessment is the opportunity to ask "process"
questions within an interdisciplinary group (e.g., facilities,
student, research professional, administration, risk manager)
and collaboratively compare notes, discuss environmental issues
and discover relevant and effective environmental programs
within the institution. This point returns us to one of the
original themes of this article: Policies, procedures, programs
and people exist in higher education; the key, and the challenge,
is uniting them in a coherent management system(s).
We have found that results from this tool are of significant
value to senior administration because it uses concepts familiar
to them, and respects their role in directing policy and conducting
management reviews rather than being involved in the minutia
of regulatory compliance.
Discovering programs beyond EH&S boundaries, interacting
with multiple stakeholders and identifying policies and procedures
already successfully implemented can help in better understanding
the EMS within your institution and in developing a roadmap
We have found that the self-assessment is flexible enough
to accommodate a review at a variety of scales, from (1) the
entire campus; (2) organizational groupings within the campus
(e.g., schools or departments); or (3) environmental impacts.
For example, the University of Vermont used the tool to evaluate
its "system" for managing its solid waste, air and
water impacts. They were interested to find that the strengths
and weaknesses of their management were generally consistent
across the categories.
While the tool is widely distributed and continues to be downloaded
on a daily basis, it is too early to measure any impact of
the tool in transforming EH&S management behavior in higher
education. We do know that some universities have used the
scores to develop EMS improvement plans. For example, a number
of institutions that scored poorly in the Environmental Policy
category have pointed to this deficiency in arguing to senior
administration for an environmental policy. (For those considering
the development of an Environmental Policy, the National Wildlife
Federation is currently conducting a benchmark review and
analysis of such environmental performance and policies in
higher education. Go to www.nwf.org/campus). Other institutions
have set their sights on improving their scores to all 2's
by the end of 2001.
Most universities conducting the self-assessments were less
concerned with poor scores in the areas that might be termed
"ISO 14001 oriented." Formal procedures, excessive
documentation and heavy emphasis on recordkeeping to demonstrate
conformance with explicit policies and procedures were not
perceived as priorities.
It is our sense, based on conversations with EH&S professionals,
that the EMS approach for colleges and universities is sensible
in trying to balance a people-centered management approach
(e.g., departmental turf, greening initiatives) with a structure
that can sustain an initiative or program in an individual's
We have found in our workshops that the C2E2 EMS Self-Assessment
may not be as valuable a tool to small colleges as a simpler
approach. For such institutions, it may be wise first to identify
major EH&S and "green" programs and subsequently
complete an EMS summary sheet (see C2E2.org) to determine
if each program is managed in accordance with certain EMS
elements (e.g., objectives, targets, defined roles and responsibilities,
training, monitoring of performance). If all the institution's
programs contain these elements, the EMS "bucky ball"
may be complete and an effective EMS in place. This grass
roots approach to building from the ground up can be used
to build an EMS, especially in the absence of senior administrative
support or resources.
In assessing the strengths and weaknesses of an institution's
approach to improving environmental performance, many colleges
and universities have found that the C2E2 EMS Self-Assessment
Checklist offers a process for honestly appraising current conditions
and for building a sustainable system for improving environmental
performance on campus. Based on the initial feedback, the C2E2
is focusing its next steps on developing best practice examples
and evaluating appropriate Environmental Performance Indicators
for higher education.
C2E2 members Boston College, University of Massachusetts Boston
and the University of Vermont received EPA approval on September
28, 1999 to pilot an alternative performance-based regulatory
model for managing hazardous wastes in laboratories. An important
element in this approval was the inclusion of an EMS basis within
the pilot replacement regulation. Additional information can
be found at www.c2e2.org.
Thomas Balf is Director of the Campus Consortium for Environmental
Excellence: c/o Nexus Environmental Partners, One Financial Center,
Boston, MA 02111; tel: 617-951-1181; email: email@example.com.
Stuart is Environmental Safety Program Manager, University of
Vermont, and President of the C2E2: Environmental Safety Facility,
University of Vermont, P.O. Box 50570, Burlington, VT 05405; tel:
802-656-5403; email: firstname.lastname@example.org.
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