What is an Extraordinary Environmental Enterprise?
Under the Virginia Environmental Excellence Program, an “Extraordinary Environmental Enterprise” or E4 is a facility with a fully implemented environmental management system that has been verified by a third party. Additionally, the facility must document that it has committed to measures for continuous and sustainable environmental progress and community involvement. A strong environmental compliance record is expected of all VEEP participants. Typically, the drivers for superior environmental performance are not regulatory, but rather the demands of customers, shareholders and public opinion. Thus, there is an expectation that E4 facilities have a history of not only superior environmental performance, but also one of environmental leadership.
Although it is possible to achieve, it is unusual for a facility to join the program for the first time and be accepted at the E4 level.
The primary driver for E4 membership is the desire to be a leader in the mission to protect and conserve Virginia's natural resources. The benefits afforded to an E4 member are not so much rewards for membership but instead recognition of the member's commitment to that mission. Members are expected to display an attitude focused on the environment and conduct themselves in an exemplary manner with regards to environmental leadership. E4 members are expected to:
Promote environmentally responsible practices, awareness and improvement to their neighbors, employees, customers, the business community, and the public;
Partner with DEQ in promoting regulations as minimum requirements and not goals or measures of success;
Openly communicate with DEQ and the public on non-proprietary results and processes; and,
Set and achieve goals with discernable improvements to air and water quality and increases in land conservation and restoration.
What are the benefits of being an Extraordinary Environmental Enterprise?
Facilities achieving Extraordinary Environmental Enterprise or E4 status are eligible for all of the benefits of the Exemplary Environmental Enterprise or E3 level, including recognition and technical assistance. In addition, as a result of legislation adopted by the 2005 General Assembly, on a case-by-case basis, E4 facilities may be eligible for "alternative compliance methods." Please contact Sharon Baxter for more information.
What must a facility provide to DEQ to achieve Extraordinary Environmental Enterprise status?
Participation in VEEP is on a facility by facility basis. The E4 level of the program was established by legislation adopted by the 2005 General Assembly that became effective on July 1, 2005. As outlined in the legislation, in order to participate as an E4 facility, a facility must: (1) have implemented and completed at least one full cycle of an EMS as verified by an independent third party; (2) have a record of sustained compliance with environmental requirements; and, (3) have committed to measures for continuous and sustainable environmental progress and community involvement. Any facility that was accepted into EPA's Performance Track prior to March 16, 2009, will be deemed an E4 facility; however, facilities in EPA's program will need to renew their VEEP participation directly with DEQ at the end of their three-year membership term.
- Environmental Management System Implementation: The development and implementation of effective EMS is the primary goal of VEEP. DEQ does not prescribe the model or type of EMS or the structure of a facility’s environmental programs. However, DEQ is responsible for verifying that each facility accepted into VEEP meets the program criteria. Therefore, each E4 applicant is required to address key points related to its EMS:
- The facility’s policy statement outlining its commitment to improving environmental quality, stressing compliance with environmental requirements, pollution prevention, training, communication and continuous improvement.
- An evaluation of the actual or potential environmental impacts and aspects from current or future activities at the facility, including a comprehensive list of impacts and aspects, an explanation of the process used by the facility to determine its significant impacts and aspects, a summary of the most recent impact and aspect review process, and the facility’s schedule for reviewing and reevaluating its impacts.
- Objectives and targets for addressing significant environmental impacts, including the facility’s goals (or objectives) for addressing its significant impacts and aspects and the projects or tasks that are planned to address each of the significant impacts and aspects (with an implementation schedule).
- Description of the facility's pollution prevention program, including a comprehensive list of p2 projects and accomplishments, not limited to those which address its significant impacts and aspects and any environmental results and costs savings achieved from past projects if available.
- Identification of the facility's environmental legal requirements and a mechanism for tracking changes in environmental compliance requirements, including a system for learning about legal requirements and changes in regulations.
- Description of how the facility defines, documents and maintains roles, responsibilities and authorities for its environmental management system, including assignments for projects, tasks or reporting responsibilities and upper management involvement or review.
- Procedures for reporting and record keeping to document the status of EMS operations and activities, including a system for attractive tracking of the EMS.
- Procedures for ensuring that all employees have the necessary training, including a systematic approach ensuring all employees have role in the EMS.
- Emergency response procedures for responding to, reporting, mitigating and reviewing incidents, including emergency management program coordinated with local emergency response efforts.
- Monitoring, investigative and corrective actions for noncompliance with environmental management system.
- Voluntary self assessments (external or internal auditing system), which may include regular self-assessments, corrective action plans or third party audits.
- Procedures to communicate with and inform external and internal audiences.
- Unrelated Third Party Audit: E4 facilities are required to submit documentation showing that they have completed at least one full cycle of their EMS and that it has been reviewed and verified by an unrelated third party. DEQ defines the term "unrelated third party" in the context of VEEP to mean that the EMS assessment team members are neither directly employed by the applying facility nor have they played a substantive role in developing the facility's EMS. In addition, DEQ requires that third party auditors be qualified for their role in assessing the EMS. Facilities have a number of options for the audit and may choose from the following:
1. An assessment conducted by one of the following (a – c) so long as the lead auditor is not directly employed by the facility and did not play a substantive role in developing the EMS for the facility:
(a) an audit led by an individual certified as an EMS lead auditor by RABQSA or the Board of Environmental, Health & Safety Auditor Certifications (BEAC). For example, this could include ISO 14001 certification audits and audits performed in compliance with ISO 19011 or subsequent updates to or replacements of the auditing standards;
(b) a corporate audit whose audit team members meet the requirements of (1)(a) or the Qualifications for Independent Assessment Team Members below;
(c) an audit conducted under an established trade association EMS audit program (e.g., the Responsible Care audit program) whose audit team members meet the requirements of (1)(a) or the Qualifications for Independent Assessment Team Members below; or
2. An assessment of a Federal facility EMS conducted according to the designated federal auditing program whose team members meet the requirements of (1)(a) or the Qualifications for Independent Assessment Team Members below.
Qualifications for Lead Auditor:
Education: Bachelor's degree
Training: 40-hour RABQSA Accredited ISO 14001:2004 EMS Lead Auditor Course or IPC (formerly IATCA) EMS Lead Auditor Courses (must receive passing grade on course examination)
Work Experience: Five years of work experience in environmental management, environmental science and technology, environmental regulation or related field
Auditing Experience: Auditing experience required is 35 audit days (minimum of 8 hours) acting in the role of lead auditor planning, conducting and reporting on full EMS audits. A maximum of 10 days of off-site audit activity is allowed in the 35 days. The 35 days must include at least 7 complete EMS audits as a solo auditor, as a member of an audit team or as an audit team leader. At least 3 of the complete audits and a total of at least 15 audit days must be performed as an audit team leader managing a team of at least one other auditor.
Qualifications for Audit Team Members:
Education: Bachelor's degree
Training: 40-hour RABQSA Accredited ISO 14001:2004 EMS Lead Auditor Course or IPC (formerly IATCA) EMS Lead Auditor courses (must receive passing grade on course examination)
Work Experience: Three years of work experience in environmental management, environmental science and technology, environmental regulation or a related field.
Auditing Experience: Auditing experience required is 20 audit days acting in the role or co-auditor participating in environmental audits. A maximum of six days of off-site audit activity is allowed in the 20 days. Included in the 20 audit days, an applicant must demonstrate at least four complete EMS audits as a member of an audit team.
- Record of Sustained Compliance: Facilities applying to any level of VEEP must have a record of sustained compliance. As defined by Section 10.1-1187.1 of the Code of Virginia, record of sustained compliance means that "the person or facility (i) has no judgment or conviction entered against it, or against any key personnel of the person or facility or any person with an ownership interest in the facility for a criminal violation of the environmental protection laws of the United States, the Commonwealth, or any state in the previous five years; (ii) has been neither the cause of, nor liable for, more than two significant environmental violations in the previous three years; (iii) has no unresolved notices of violations or potential violations of environmental requirements with Department or one of the Boards; (iv) is in compliance with the terms of any order or decree, executive compliance agreement, or related enforcement measure issued by the Department, one of the Boards, or EPA; and (v) has not demonstrated in any other way an unwillingness or inability to comply with environmental protection requirements. DEQ will conduct a review of each applying facility’s compliance record, including a review of EPA records as appropriate.
- Commitment to Continuous and Sustainable Environmental Progress and Community Involvement: E4 facilities are required to document that they have committed to continuous and sustainable environmental progress and community involvement. Each facility’s situation in terms of purpose, location and impacts may prove unique from other facilities. Therefore, meeting this requirement will vary from facility to facility.
During DEQ's site visit to review the facility EMS, the following areas related to sustainable environmental progress will be reviewed and documented:
- Does the facility acknowledge and support the concept of environmental sustainability?
- Does the facility actively go beyond its fence line to assist the community and peers with efforts to improve environmental quality?
- Does the facility participate in programs that recognize environmental efforts?
Also during the E4 site visit. DEQ will document specific examples of community involvement. Typical categories include:
Inform the public about their EMS and environmental goals.
Participate in Adopt-a-Stream, Adopt-a-Highway or similar program
Participate in or supports an environmental conference
Mentor local businesses on EMS
Assist peers with environmental issues
Host or support an event that raises environmental awareness (example: Earth Day)
Partner with a local group for a river or park cleanup
Participate in and promotes environmental awareness at town or business meetings
Participate in regional environmental groups
Examples from current E4 facilities include:
Outreach related to wildlife and renewable energy use
- Community open house showcasing environmental efforts
Earth Day event combined with "take your kid to work day"
Site cleanup days
Collect cans for Habitat for Humanity
Support Forever Forest Project, which plants trees all over the world
Tours for local schools
Host sustainability conference
Participate on local committee boards
Involvement in various environmental education efforts such as Bayscapes, National Public Lands Day, etc.
Apply for Governor's Environmental Excellence Awards
Implement green procurement program
For more information, contact Sharon Baxter.