National Biosolids Partnership EMS Update

From BioCycle
Journal of Composting &Organics Recycling
May 2001, Page 57

DEMONSTRATION PHASE
NATIONAL BIOSOLIDS PARTNERSHIP EMS UPDATE
Key documents of the Environmental Management System for biosolids have been completed in an interim form and are being "beta tested" by 27 wastewater treatment agencies.
Nora Goldstein

WHEN the National Biosolids Partnership (NBP) was formed in 1997, its mission was to advance environmentally sound and accepted biosolids management practices —to implement programs that build public confidence and go beyond regulatory requirements. From the beginning, the partnership focused on developing an Environmental Management System (EMS) model, based on ISO 14001 principles for biosolids that would build in improved management practices tailored to meet the needs of the community (see “Environmental Management System Initiative,” September, 1999).

The partnership is an alliance between the Association of Metropolitan Sewerage Agencies (AMSA), the Water Environment Federation (WEF), and the U.S. Environmental Protection Agency (EPA). It is housed at the WEF offices in Alexandria, Virginia. Biosolids producers, service contractors and users — together with stakeholders from regulatory agencies, universities, public health departments, media, water quality professionals, the farming community, and environmental organizations — have input into shaping the NBP priorities both through committees and meetings. The partnership has been funded in part by a Congressional appropriation.

There are five components to the NBP’s EMS Blueprint. The first, developed by the partnership itself, is a Code of Good Practice that lays out the commitments that facilities need to make to participate in the EMS program. Contracts were given to several consulting firms to help the NBP develop the other four components of the EMS Blueprint. They include the Common Elements of an EMS for Biosolids —17 system requirements for effectively managing biosolids activities at all critical control points (the accompanying article, “The Making of an Environmental Management System,” explains the elements in more detail); the National Manual of Good Practice for Biosolids — one-volume, “how-to” document designed around the critical control points for managing biosolids, from pretreatment through public acceptance strategies; the EMS Guidance Manual — detailed manual with step-by-step guidance on how to implement the 17 elements; and the Independent Third-Party Verification Recommendations — guidance for developing a program to verify and certify that organizations have implemented EMS programs consistent with the Common Elements.

The Code of Good Practice and interim drafts of Blueprint documents are available on the NBP’s website (www.biosolids.org). Before finalizing the Blueprint, 27 waste-water treatment agencies (see sidebar), referred to as Demonstration Organizations, are pilot testing the documents –- essentially using them to create an EMS for their biosolids management programs. "The agencies in this demonstration program are highly variable in size, from New York City to the small town of Omak, Washington," says James Horne, a special assistant to the director of EPA’s Office of Wastewater Management and the U.S. EPA representative to the NBP. The goal is for all of them to have completed their EMS in early 2002, after which they would go through the third party audit, which is necessary in order to be certified by the NBP.

A workshop was held in March for the 27 agencies. Consultants who had worked on the EMS Elements, the Manual of Good Practice and the Third Party Verification program (PA Consulting/CH2M Hill, The Sear-Brown Group, Ross and Associates Environmental Consulting, Ltd.) were on hand to explain those components and answer questions. “Most of the agencies, with the exception of the Orange County, California Sanitation District and San Diego, are in the early stages of the EMS development process,” says Horne. “That is essentially the planning stages, or the first six to eight elements of the 17 total elements that have to be included in an EMS.”

Peter Machno, the EMS coordinator on the NBP staff who is working closely with the 27 Demonstration Organizations, emphasizes that most of these agencies have the workings of many of the elements in place already. “Whether they are organized into a real EMS envisioned by the NBP is the question,” he says. “For example, they may have various policies, a training program and so forth, but they may not all be working in a systematic way together toward the same goal of public acceptance of biosolids.”

Consultants to the NBP worked with the 27 agencies to assess what procedures exist and what needs to be developed to complete the components of each element — to give them a sense of what had to be done during the life of the demonstration. It also confirmed to agency staff that they didn’t have to start entirely from scratch to put the EMS together. “Hopefully the EMS assessments, if looked at objectively, showed that,” says Horne.

INDEPENDENT AUDIT

While the agencies are working with the Blueprint documents, the NBP is developing the final component of the EMS program — the guidance for the auditors who will conduct the third party verification. The NBP will hire a certified EMS audit company with five years minimum of wastewater experience, and that can provide individual auditors who have such qualifications. Ross & Associates has been retained by the NBP to facilitate discussions with the Advisory and Development Groups, comprised of stakeholders in the biosolids management community and specialists in the EMS field, as they prepare the auditor guidance. The firm also facilitated the process to develop the third party verification program. Most of the stakeholders who worked on third party verification are volunteering again to help develop the auditor guidance.

“The guidance will be used by the auditing firm contracted by the NBP to go on site and evaluate the EMS at the wastewater treatment agencies,” says Horne. “It will lay out in detail how the audit will be conducted, qualifications of the auditors, types of questions that will be asked and so forth.” Another reason for developing the guidance is to demystify the auditing process for the agencies to be audited. The participating organizations will know what the auditor will be looking for in their EMS. “They will know what to expect and the auditors will operate within certain guidelines that the partnership will develop,” he adds. “If it is done right, people will understand that the third party auditing process isn’t a ‘gotcha,’ but instead is designed to point out both the strengths and areas for improvement with their EMS.”

At the workshop in March, Chris Toth from the city of San Diego — the first to have its wastewater facility EMS certified by ISO 14001, and now one of the 27 demonstration agencies in the NBP program — shared the audit experience with the others. “It will be like taking an exam,” he said. “You won’t get a perfect score but the goal is to get a passing score and then see where you need to improve. Think of the auditor as your friend.’”

Representatives from about ten of the 27 demonstration organizations have agreed to be part of the auditor guidance Development Group. “The goal is to have the auditor guidance completed and accepted by the NBP Management Committee this fall, and the auditing program in place by the time the demonstration agencies complete and implement their EMS,” says Machno. Adds Horne: “Step 1 for the agencies is to make sure they have all 17 of the common elements of the EMS in place; Step 2 is to have the EMS operational; and Step 3 is to go through the audit, which typically happens six months after implementation. Following that schedule, the third party audits would begin to take place in early 2002.” The audit guidance will be the basis of an RFP to contract with a certification company and will be used by that company to perform the audits.

The overall purpose of the third party audit is to verify if a local agency is actually implementing its EMS consistent with the NBP EMS Blueprint. It also serves to teach agency staff and all other involved or impacted parties about elements of the system that they didn’t know before. “The audit identifies strengths and weaknesses and helps everyone involved follow the continuous improvement philosophy,” explains Horne. If and when the auditor determines that the local organization meets the blueprint requirements, they will be certified by the NBP. Identifying the specific criteria for determining if those requirements have been met are part of the task of the auditor guidance Development and Advisory Groups.

Wastewater treatment agencies that go through the audit and receive the certification will get official recognition from the NBP. “The certification will be similar to the Good Housekeeping Seal of Approval ,” says Machno. “It means that the local organization has a good biosolids management system in place that controls potential environmental impact well and will help with public acceptance. The public will be more apt to ‘trust’ a local organization’s biosolids program because it has been through an independent third party review like the Good Housekeeping Seal of Approval. The partnership is designing an insignia that the local organization would be able to use on its letterhead, facility decals and so forth. As of now, however, they would not be able to put the insignia on their product, e.g. on a bag of composted or pelletized biosolids. This summer, the NBP’s Advisory Group will be working on what it would take to allow a ‘stamp of approval’ to be used on the product.”

EMS DEVELOPMENT PROGRESS

The majority of the 27 agencies involved in the demonstration program land apply the biosolids generated; a few rely on landfilling or incineration. In 16 of the 27 organizations, the lead person putting the EMS in place is on the agency’s management/administrative staff; 11 agencies have a biosolids person in the lead. These individuals have put together a team comprised of representatives from the entire organization, including people with responsibilities for pretreatment, treatment plant operations and biosolids handling. “Establishing the EMS involves documenting how the solids and biosolids are being managed, which means that a fair amount of time is needed to write everything down, as well as sort out where it is necessary to update procedures and make sure the procedures complement each other and are leading to the common goal of producing biosolids products that meet the quality requirements for their intended markets,” explains Machno. “That is why the EMS has to be a common effort within an organization. Everyone needs to buy into the ‘systematic approach’ to managing the solids/biosolids. The writing should be a shared experience among an organization’s staff in order to achieve that ‘buying into’ of the EMS.” This also establishes “facility-wide ownership” for the EMS, adds Horne.

Both large and smaller agencies can follow the principles of the NBP EMS, but the amount of information to define their EMS will be different. For example, the required documentation may be perceived as overwhelming for a small agency with a small staff or the treatment plant manager responsible for pretreatment, treatment and biosolids handling. A large agency, on the other hand, may hire temporary staff or a consultant to help staff with that work. “The NBP is working with small agencies in the demonstration program to assure that the EMS Blueprint is applicable to small organizations, not just the large and medium size facilities,” adds Machno. Adjustments can be made where appropriate, says Horne.

FORMALIZED PUBLIC INVOLVEMENT

Number 6 of the common elements, Public Participation in Planning, requires public involvement in the EMS process. Institutionalizing public involvement, especially for wastewater treatment agencies managing biosolids via land application, is an extremely important asset of an EMS, but also one of the most challenging to develop. At the workshop in March, the demonstration agencies participated in an exercise to come up with a draft public participation plan. Each group had a hypothetical situation, for example, a large utility that land applies its biosolids and a) has significant opposition or b) has no opposition. Who are the stakeholders to talk to, what is the message the agencies want to send to those people and how do they get their involvement in the EMS process?

“This was the introduction of public participation training for the Demonstration Organizations,” says Machno. “Exactly what the auditors will use to assess implementation of this element is one of the ‘areas of definition’ the NBP and the auditor guidance Development and Advisory Groups will be working on this summer. The recommendations in the third party verification blueprint document with regard to public participation will be the starting point for the work group. One of the challenges is that we will need to define what the auditor will look for and what the participating organization needs to do so there will be no surprises when the auditor is asking questions of a local organization.”

In general, the NBP will not dictate how agencies should carry out element 6. Instead, it will explain that they must demonstrate that stakeholders have been given the opportunity to provide input into the EMS. Machno points out that most biosolids programs will not be starting from scratch on this element either. “There are many good public participation programs in place and already operational.”

ALL AROUND LEARNING EXPERIENCE

The NBP and its consultants are providing ongoing technical assistance to the Demonstration Organizations as they continue developing their EMS. It’s a learning experience for all parties involved, and will serve to clarify and strengthen both the EMS blueprint and the overall strategy for taking the EMS initiative full-scale to the biosolids management industry. The NBP expects that 40 organizations will have received its “stamp of certification” by 2003. It also has a goal of 100 organizations being part of the EMS program by that point (meaning that they have embraced the NBP Code of Good Practice). Another goal by 2003 is to have support for the NBP EMS program by national environmental organizations.

The five components of the EMS Blueprint will be integrated into a single program following the pilot testing by the 27 pioneering public organizations. The demonstration program will be expanded to include 13 additional projects, with the emphasis on smaller agencies. Workshops will be used to encourage at least 60 additional organizations to sign up for what the NBP is calling the “Code of Good Practice Club.”

Concludes Machno: “The overall goal of the NBP is to gain public acceptance of the use and disposal of biosolids. The NBP said early on that the way we were working to achieve public acceptance in the past was not really working in all areas. Public controversy was continuing to show up around the country. Being reactive rather than proactive was not working and we had to find a way to be proactive. The EMS with its third party verification is a proactive approach. The public doesn’t trust most public agency biosolids program managers. There is the perception that they have a waste from society that must be gotten rid of the cheapest way possible.

“The private sector developed programs such as the ‘Underwriters Laboratory’ third party stamp of approval on electrical appliances and the ‘Good Housekeeping Seal of Approval.’ The NBP believes that this same approach should work for public agencies. The public is more apt to give a public agency the benefit of a doubt if they have an independent third party verification and stamp of approval process.

“In addition, the EMS offers a systematic approach to management. This approach is going to avoid the ‘dumb’ mistakes that have been made in the past, mistakes have typically resulted in major public acceptance problems in areas around the country. This is not to say the EMS will catch everything. Things like extreme weather events do happen!

“I like to refer to the Demonstration Organizations as the pioneers that are paving the way for the rest of the 15,973 public wastewater organizations around the United States to assure public acceptance of their biosolids programs.”

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