EMP01. Environmental Management Plan

System Revision ID ASEMS Document Version Effective From State
3902 3.2 11/05/2017 - 10:30 Extant

1.1. Overview

1.1.0.1.

An Environmental Management Plan (EMP) defines the strategy for assessing environmental matters and outlines the Environmental Management System.  The EMP better enables Project Teams to manage environmental performance and apply appropriate resource.

The EMP is applicable to both the Environmental Impact Screening and Scoping (EISS) approach (EMP01 to EMP05) and the more in depth Environmental Impact Management (EIM) approach (EMP06 to EMP08). The EMP shall be applied proportionally to the POEMS option taken. The decision point for the choice between EISS and EIM is at EMP05.

1.1.0.2.

Effectively deploying the POEMS assessment will support and prompt better environmental management. This should enable a range of benefits including cost and compliance.

1.1.0.3.

The EMP should be detailed for the current stage of the Acquisition cycle but should also define a workable strategy for all the remaining stages, including Disposal.  This strategy covers the MOD’s environmental management activities and enables project Environmental Case development.

All projects submitted to the Investment Approvals Committee (IAC) must take sustainability and envioronmental impacts into consideration.

1.1.0.4.

Where relevant and proportional, a Sustainable Procurement Plan (SPP) shall be developed. The development of a SPP will be of most benefit during the Concept, Assessment and Design phases but can also be usefully employed through life at strategic points such as a refit. The Sustainable Procurement Guide and Toolkit; provide guidance and support tools. The Sustainable Procurement Plan is detailed at Step 1 of the Sustainable Procurement Toolkit.

1.2. Procedure

1.2.0.1.

The maturity of the project will dictate the level of information available during the production of the EMP. However, as the programme matures and progresses through the CADMID/T lifecycle, the EMP should be updated to accurately reflect the project and environmental activities to be undertaken (EMP09 Continuous Review).  The EMP must document how, who, what and when activities will be undertaken in order to meet the requirements of ASEMS.  

1.2.0.2.

The EMP shall be proportionate and relative to anticipated environmental impacts.  For example, a relatively concise EMP is entirely acceptable where the product, system or service is environmentally benign or its impacts and risks are small when compared to domestic household activity.  Conversely, a full, complete and well referenced EMP shall be appropriate where significant environmental impacts are anticipated. Project Teams shall approach the EMP in a proportionate and relative manner. The Project Team should make use of ASEMS Proportionality Guidance to assist with establishing scope, boundaries, depth and breadth for environmental management activities.  

1.2.0.3.

The EMP is a ‘live’ document that shall be maintained, reviewed and updated in accordance with the Continual Review Procedure detailed in Environmental Management Procedure EMP 09 Continuous Review (this will help to identify when, and if, the Plan needs to be reviewed).  As a minimum, this should be at:

  1. Planned intervals;
  2. Key project milestones;
  3. ‘Trigger’ events, such as:
    1. Changes in International or Defence Standards;
    2. Any change in the Concept of Use;
    3. Any change in the Concept of Operations;
    4. Relevant change/s to the materiel state;
    5.  Following an environmental incident. 

The EMP shall be revisited, updated and used throughout the POEMS process to better enable all POEMS outputs. In particular, development of an appropriately constructed EMP will better enable the EISS study and reports, the EIM study and report and the Environmental Case.  

1.2.0.4.

The EMP shall  include details of how the Project Team or equipment operators may respond/manage abnormal conditions and reasonably foreseeable emergency situations.

1.2.0.5.

A combined approach to safety and environmental planning offers process efficiency.  The output of this commonly employed approach is called a Safety and Environmental Management Plan (SEMP).

1.2.1. General

1.2.1.1.

The Project Team shall consider the context of the organisation and project when producing the EMP.  The Project Team should understand the needs and expectations of interested parties relevant to the project and which of these needs and expectations becomes its compliance obligations. 

1.2.1.2.

The EMP shall contain (where relevant to lifecycle stage):

  1. A Product, System or Service Description;
  2. Concept of use, operation and operating environment;
  3. A description of the Project Team and structure;
  4. Relationship with other systems;
  5. Summary of anticipated and/or actual legal compliance arguments, exemptions / derogations;
  6. Reference to the Environmental Policy to be met;
  7. Stakeholders;
  8. Anticipated and/or actual significant environmental aspects;
  9. Outline approach to anticipated aspects including objectives and targets and communications;
  10. Environmental responsibilities;
  11. Interface with other business systems/processes;
  12. Considerations to be embedded within the procurement process (link to significant environmental aspects);
  13. Key environmental management milestones;
  14. Assurance regimes;
  15. Resources required;
  16. Competence and SQEP;
  17. Other pertinent information.

1.2.1.3.

Each of the content headings above should be applied to each CADMID lifecycle stage where relevant.  Refer to Process Maps for further clarity.

1.2.2. Scope

1.2.2.1.

The Project Team shall determine the boundaries and applicability of ASEMS to their project in order to establish the scope.  The Project Team shall refer to ASEMS Proportionality Guidance to assist in determining the scope of the EMP and the Project Team should also consider the requirements of EMP02 to EMP09.

1.2.3. Reporting and Business Requirements

1.2.3.1.

The EMP shall outline the approach to significant environmental aspects and highlight how any deltas in compliance (including any exemptions or derogations) will be addressed through life and how environmental management will interface with other business systems/process (e.g. Investment Appraisal, Sustainable Procurement, Supply Chain Resilience, POSMS, Business and Capability Risk).  The project team shall consider how resulting actions from applying ASEMS may impact or interface with the environmental management objectives, technological options, financial, operational and business requirements and how these may be evaluated for effectiveness.

1.2.4. Competence and SQEP

1.2.4.1.

The EMP is required to consider appropriate competence and Suitably Qualified and Experienced Persons (SQEP) when considering what resources will be required to conduct environmental management activities.  GMP00, GMP03, EMP03 and EMP08 provide further guidance relating to competence and SQEP.

1.2.4.2.

Where sufficient competent resource is not available within the Project Team, the Project Team should establish how this may be addressed (such as training, mentoring, external support) and evaluate the effectiveness of any action.  Documentary evidence of competence shall be retained as part of the Environmental Case.

1.2.5. Stakeholders and Communication (EMP02, GMP01 and GMP03)

1.2.5.1.

The EMP shall establish how stakeholders will be defined and communication will be achieved in accordance with EMP02, GMP01 and GMP03.  The EMP shall outline:

  1. What it will communicate;
  2. When and who to communicate to;
  3. How to communicate;
  4. How external communications will be handled;
  5. How communications will be responded to, documented and retained;
  6. How pertinent information is disseminated in accordance with the scope of ASEMS.
1.2.6. Compliance (EMP03)

1.2.6.1.

The Environmental Management Plan shall establish how environmental standards information will be accessed and how demonstration of compliance will be achieved, in accordance with EMP03.

1.2.7. Environmental Aspects (EMP04, 05 & 08)

1.2.7.1.

The EMP shall identify how environmental aspects are to be identified and prioritised.  The EMP should also establish how environmental aspects can be controlled or influenced to be reduced across the CAMID/T Lifecycle and consider how best to embed mitigations within the procurement process.

The Project Team should make use of ASEMS Proportionality Guidance to assist with establishing scope, boundaries, depth and breadth for environmental management activities.  

 

1.2.8. Environmental Objectives (EMP06)

1.2.8.1.

Environmental objectives, in accordance with EMP06, shall be set in line with any significant environmental aspect, standards, risk and/or opportunities.  

1.2.8.2.

 The EMP shall outline how:

  1. Objectives will be achieved;
  2. What will be done and what resources are required;
  3.  Who will be responsible and accountable;
  4. Time frames for key milestones and completion;
  5. How progress will be monitored.

Acquisitions that pose no significant environmental impacts, standards or substantial further environmental risks and opportunities shall be recorded and limited to an Environmental Impact Screening and Scoping (EISS) study. The EISS will inform concise report outputs and be subject to continual review in line with EMP09. The more in depth Environmental Impact Management (EIM) approach will not be appropriate and the Environmental Case shall reflect this.

1.2.9. Reporting (EMP07)

1.2.9.1.

The EMP shall establish any stakeholder reporting requirements to Defence Regulators and other Business Units.

1.2.10. General Management Procedures

1.2.10.1.

The EMP shall establish how the Project Team environmental information will interface and meet the requirements of GMP00 to 04 and ASEMS Part 3.  Specifically the EMP shall establish:

Assurance Regimes:

  1. Use and number of Independent Environmental Advisor(s)/Auditor(s) (IEA);
  2. Constitution and number of Committee Meetings and/or Working Group/s;
  3. Internal and External Audits;

Suitably Qualified and Experienced Persons for the purposes of conducting/verifying identification and assessment activity;

Reporting:

  1. Business performance reporting requirements (eg. ASSERT submissions);
  2. Style and format of reporting outputs from the application of ASEMS (e.g. Environmental Management Plan or Environmental Case Report);
  3. Risk Referral;

Training and Awareness:

  1. Training required to meet Terms of Reference;
  2. Awareness training as a means of communicating pertinent elements of the EMP and fostering a sound environmental culture;

Documentation:

  1. Where documentation is located;
  2. Version Control.

Note:    The use of an Independent Environmental Auditor (IEA) is a matter of choice for its Environmental Committee unless mandated by Regulation. Electing to use an IEA is often driven by a high environmental risk profile and the associated need to manage environmental liabilities, often including the probability of significant reputational damage.  

1.2.11. Plan

1.2.11.1.

As a key part of the EMP the Project Team shall establish a Project Plan which articulates key environmental management milestones and how these interface with key project milestones to meet the requirements of ASEMS. 

1.2.11.2.

The EMP shall present:

  1. Effort (number of staff and time allocated – Full Time Equivalents);
  2. Competence of persons;
  3. Approving Authorities;
  4. Named resource (post or individual) for the purposes of Assurance.
1.2.12. Updates

1.2.12.1.

As the project matures the EMP shall be updated to reflect how the Project Team will implement findings and integrate information into the environmental case, e.g. how controls and mitigations will be implemented/managed or the setting of new objectives.

1.3. Responsibilities

1.3.0.1.

The Project Team Leader is accountable for the completion of the EMP.

1.3.0.2.

The Project Team Leader may delegate to internal focal point(s) and subsequently to external advisors where specialist knowledge is not available internally. 

1.4. When

1.4.1. Initial Application

1.4.1.1.

For new projects this procedure should be undertaken as early as possible in the Concept Stage, prior to Initial Gate approval.

1.4.1.2.

For legacy projects this should be undertaken at the outset to ensure that all relevant stakeholders and Subject Matter Experts are fully engaged and that the latest legislation and policies are being implemented.

1.4.2. Review

1.4.2.1.

The outputs of this procedure will require periodic review and likely revision throughout the lifetime of the project.  The appropriate timings for such reviews will be determined via Procedure EMP09 – Continuous Review.

1.5. Required Inputs

1.5.0.1.

For established projects with existing environmental information inputs may include:

  1. Environmental Impact Statement;
  2. Environmental Impact Screening and Scoping Study;
  3. Environmental Impact Management Report (formerly Environmental Impact Assessment);
  4. Environmental Case Report;
  5. Environmental risk, impact, evaluation or prioritisation register/s;
  6. Standards Register;
  7. Compliance Information;
  8. Domain Specific Guidance/Requirements (eg. JSP 454).

1.6. Required Outputs

1.6.0.1.

Conformance should be demonstrated by completing one of the following outputs:

  1. A standalone EMP;
  2. A combined Safety and Environmental Management Plan;
  3. A Sustainability Management Plan;
  4. Incorporation of EMP01 requirements into a strategic project plan.
1.6.1. Records and Project Documentation

1.6.1.1.

A copy of the EMP produced shall be documented, controlled and retained as part of the project’s Environmental Case.

1.6.2. The Environmental Case

1.6.2.1.

The Environmental Case is a structured argument and body of evidence that supports a project’s environmental claims.

 

1.6.2.2.

The Environmental Case will consist of the Environmental Impact Screening and Scoping report and associated Environmental Impact Statement or the Environmental Impact Management report along with its associated Environmental Impact Statement, the Environmental Management Plan, the Environmental Feature Matrix, appropriate records of Environmental Committee meetings and other pertinent information generated outside of  POEMS that might include a range of reports and documents such as a design for the environment study or a disposal plan.

1.6.3. The Environmental Case Report

1.6.3.1.

The Environmental Case Report provides a summary of the arguments made and presents relevant supporting evidence. The Environmental Case Report presents a snapshot in time relevant to when it is produced. Further information and about the Environmental Case and Environmental Case Report is located here: https://www.asems.mod.uk/guidance/manual/safety-cases-assessments 

1.7. Sustainability and Sustainable Procurement

1.7.0.1.

The POEMS performs a crucial role in ensuring that the MOD meets the environmental considerations of sustainable development and sustainable procurement.  Equally, sustainable development and sustainable procurement activity will enhance the POEMS activities.  For example, the outputs of a POEMS assessment undertaken during the “Concept” lifecycle stage can inform sustainable procurement activity and consequently eliminate or reduce anticipated environmental impacts within the procurement cycle (targeted contract management and enhanced design options etc.).  

1.7.1. Aligning Safety and Environment

1.7.1.1.

Environmental objectives and targets in EMP06 could be aligned to related safety objectives and targets, where beneficial.

1.7.1.2.

The setting of appropriate environmental objectives and targets should be carried out irrespective of the acquisition strategy. However, under some strategies it may be necessary, or appropriate, to negotiate objectives and targets rather than impose them, especially where the acquisition is one of international collaboration.

1.8. Version Control

1.8.1. Version 2.3 to 3.0 uplift

1.8.1.1.

Major uplift from the Acquisition System Guidance (ASG) to online version. POEMS has undergone major revision. Refer to the POEMS Transition Document for details.

1.8.2. Version 3.0 to 3.2 uplift

1.8.2.1.

The following changes have been introduced as part of the Sustainable Procurement Tool release: 

  • Addition of new content to reflect the introduction of the Sustainable Procurement Tool; see paragraph 1.1.0.4 ; 
  • Following T45 trials new content introdcued at para 1.6.2 bringing clarity to the role of the environmental case and report.

Refer to the POEMS Transition Document for additional details.

References to GMPs have been updated to reflect the new GMP structure.    

 

   

Subject to Policy Clauses

1.1

Conform to Secretary of State for Defence’s Policy

Those holding safety and environmental protection delegations shall ensure that in the procuring or supporting Products, Systems or Services, they conform to the Secretary of State’s Health, Safety and Environmental Protection Policy Statement.

3.1

Safety and Environmental Management System

Operating Centres, Project Teams or equivalents shall operate in compliance with established Safety and Environmental Management Systems.

3.2

Safety and Environmental Management Plan

Operating Centres or equivalent shall ensure that all Products, Systems or Services have a suitable and sufficient through life safety and environmental management plan.

3.4

Availability of Resources

Operating Centres, Project Teams or equivalents shall ensure the availability of resources necessary to establish, implement and maintain the safety and environmental management system and detail these in a through life safety and environmental management plan.

3.5

Core Element Documentation

Operating Centres, Project Teams or equivalents shall establish, maintain and retain suitable and sufficient information that describes the core elements of the safety and environmental management system(s), their interaction and any related documentation.

3.6

Accountability

Within Operating Centres, Project Teams or their equivalents, named individuals shall be appointed who shall have defined roles, responsibilities, accountabilities and authority for ensuring safety and environmental management systems are established, implemented and maintained in accordance with the requirements of ASEMS.

3.8

Audit Frequency

Compliance with the documented safety and environmental management system shall be verified via audit at planned intervals according to a published schedule, and as required.

4.2

Environmental Cases

Project Teams or equivalents shall establish and maintain through-life environmental cases that provide a compelling, comprehensible and valid argument that the environmental impact of a Product, System or Service is reduced or minimised as far as is reasonably practicable.

4.9

Assessment Approval

Project Team Leaders or equivalent shall personally approve safety and environmental case reports to confirm their acceptance with the progress of the safety case/assessment and of the risks associated with the project.

4.10

Independent Assurance

The Project Team Leader or equivalent shall ensure independent review of the Safety and Environmental Management System as appropriate and commensurate to the risk.

5.2

Change Management

Operating Centres, Project Teams or equivalents are to ensure that all new or increased safety risks arising from changes to Products, Systems or Services or to their operating environment are managed appropriately

5.3

Hierarchy of Controls

Operating Centres, Project Teams or equivalent shall adopt a recognised hierarchical approach for achieving a reduction in safety risk and environmental impact.

5.7

Non-compliance Reporting

In circumstances where the ability of the Delegation Holder to achieve compliance with the requirements of ASEMS may have been compromised, Operating Centres, Project Teams or equivalents shall take immediate steps to correct the situation. Actions required could include improving the clarity of the authority, instructions or responsibilities provided, increasing resources or correcting deficiencies in practices or procedures. Where resolution of the problem lies outside the control of the Delegation Holder, the issue is to be referred through the line management chain. This requirement is to be applied to any further levels of delegation as necessary.

Process Maps

EMP C1
Project Initiation

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EMP C2
Environmental Initiation and Plan Development

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EMP I1
Review Changes - Provide Training

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EMP D1
Selling or Scrapping of Equipment

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Covered by Audit Question Sets

1.1

Audit Question Set Section 1.1 Conform to Secretary of State for Defence's Policy

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 1.1.

3.1

Audit Question Set Section 3.1 Safety and Environmental Management System

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 3.1.

3.2

Audit Question Set Section 3.2 Safety and Environmental Management Plan

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 3.2.

3.4

Audit Question Set Section 3.4 Availability of Resources

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 3.4.

3.5

Audit Question Set Section 3.5 Core Element Documentation

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 3.5.

3.6

Audit Question Set Section 3.6 Accountability

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 3.6.

3.8

Audit Question Set Section 3.8 Audit Frequency

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 3.8.

4.2

Audit Question Set Section 4.2 Environmental Cases

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 4.2.

4.9

Audit Question Set Section 4.9 Assessment Approval

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 4.9.

4.10

Audit Question Set Section 4.10 Independent Assurance

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 4.10

5.2

Audit Question Set Section 5.2 Change Management

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 5.2.

5.3

Audit Question Set Section 5.3 Hierarchy of Controls

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 5.3.

5.7

Audit Question Set Section 5.7 Non-Compliance Reporting

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 5.7.