F I N A L

R E P O R T

ENVIRONMENTAL
MANAGEMENT SYSTEM
GAP ANALYSIS
221ST BASE SUPPORT BATTALION
WIESBADEN, GERMANY

Prepared for
Headquarters, U.S. Army, Europe
Zenger Strasse #1, Gebaude 3796
69126 Heidelberg, Germany

October 2002

URS Group, Inc.

200 Orchard Ridge Drive, Suite 101
Gaithersburg, Maryland 20878
15292080.20000

TABLE OF CONTENTS
Executive Summary............................................................................................................................... ES-1
Section 1
Section 2
Section 3

ONE

TWO

THREE

3.1
3.2
3.3
3.4
3.5
3.6
3.7
3.8
3.9
3.10
3.11
3.12
3.13
3.14
3.15
3.16
3.17
Section 4

FOUR

Introduction..................................................................................................................... 1-1
Methodology ................................................................................................................... 2-1
Analysis........................................................................................................................... 3-1
ISO 14001, Section 4.2 Environmental Policy ................................................. 3-1
ISO 14001, Section 4.3.1 Environmental Aspects............................................ 3-2
ISO 14001, Section 4.3.2 Legal and Other Requirements................................ 3-3
ISO 14001, Section 4.3.3 Objectives and Targets ............................................ 3-4
ISO 14001, Section 4.3.4 Environmental Management Programs ................... 3-6
ISO 14001, Section 4.4.1 Structure and Responsibility.................................... 3-7
ISO 14001, Section 4.4.2 Training, Awareness and Competence .................... 3-7
ISO 14001, Section 4.4.3 Communication ....................................................... 3-8
ISO 14001, Section 4.4.4 EMS Documentation ............................................... 3-9
ISO 14001, Section 4.4.5 Document Control ................................................. 3-10
ISO 14001, Section 4.4.6 Operational Control ............................................... 3-11
ISO 14001, Section 4.4.7 Emergency Preparedness and Response................ 3-12
ISO 14001, Section 4.5.1 Monitoring and Measurement ............................... 3-13
ISO 14001, Section 4.5.2 Nonconformance and Corrective and
Preventive Action............................................................................................... 3-14
ISO 14001, Section 4.5.3 Records .................................................................. 3-15
ISO 14001, Section 4.5.4 EMS Audit............................................................. 3-15
ISO 14001, Section 4.6 Management Review ............................................... 3-16
Conclusions .................................................................................................................... 4-1

Tables
Table 1

Summarized Results of EMS Gap Analysis ......................................................ES-1

Table 2

Summarized Results of EMS Gap Analysis ........................................................ 4-1

Appendices
Appendix A

ISO 14001 Flow Diagram

Appendix B

Environmental Management System Strengths Analysis Summary Table

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Executive Summary
President Clinton signed Executive Order 13148 in April 2000. It requires all federal agencies,
including the Department of Defense (DoD), to implement an Environmental Management System
(EMS) at their facilities by 31 December 2005. The U.S. Army decided to implement the EMS in
general accordance with the International Standards Organization (ISO) 14001 criteria. Due to the
nature of DoD installations, strict conformance with ISO 14001 criteria may not be feasible, nor
may it be desirable. Flexibility in the EMS development should be allowed by individual
installations in order to lead to development of the most functional system.
URS Group, Inc. (URS) performed an EMS gap analysis at the 221st Base Support Battalion (BSB)
in Wiesbaden, Germany from 19-20 August 2002. The purpose of the analysis was to determine
current environmental management practices and compare them to ISO 14001 standards. This
analysis evaluated present environmental activities and identified both strengths of the current
system and missing elements.
The gap analysis showed that U.S. Army installations in Europe have active environmental
management programs that are primarily compliance based. Personnel interviewed within the
BSB all have good environmental awareness and continuously strive to meet and maintain
environmental compliance requirements. However, the BSB does not have EMS documentation
including an environmental policy specific to the BSB, a formal procedure to identify and rank
environmental aspects, or a full listing of objectives and targets. The objectives and targets that
have been identified are limited to environmental compliance only and do not include objectives
and targets for continuous environmental improvement. Job descriptions for individuals
overseeing various environmental media should be more clearly documented and communicated to
facilitate managing the various programs. In addition, written programs that are available do not
always match actual installation activities. The table below summarizes the results of the gap
analysis by each EMS element described in the ISO 14001 standard.
Table 1: Summarized Results of EMS Gap Analysis
EMS Element
Environmental Policy
Environmental Aspects
Legal and Other Requirements
Objectives and Targets
Environmental Management Programs
Structure and Responsibility
Training, Awareness and Competence
Communication
EMS Documentation
Document Control
Operational Control
Emergency Preparedness and Response
Monitoring and Measurement
Nonconformance and Corrective and Preventive Action
Records
EMS Audit
Management Review
Definitions:

221st BSB
Wiesbaden
Status
None
Limited
Limited
Limited
Limited
Limited
Limited
Limited
None
None
Limited
Good
Limited
Limited
Limited
None
Limited

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ES-1

Executive Summary
None = Element is largely absent
Limited = Element is somewhat present in existing U.S. Army, Europe (USAREUR) and/or IMA EURO
procedures, documents or programs but will require formalization, modification and/or revision
Good = Element is largely present in existing USAREUR/IMA EURO procedures, documents or programs but may
require some formalization, modification or revision

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ES-2

SECTIONONE
1.

Section 1 ONE

Introduction

Introduction

Headquarters, U.S. Army, Europe (USAREUR) and the Installation Management Agency (IMA)
Europe Region (EURO) are in the process of establishing a formal, joint Environmental
Management System (EMS) and requested this gap analysis as a step toward developing an EMS
to comply with Executive Order (EO) 13148 Greening the Government Through Leadership in
Environmental Management. President Clinton signed this EO on April 22, 2000. The objective
of the EO is to achieve improved environmental performance by focusing on Environmental
Management Systems and Pollution Prevention (P2). The EO requires an EMS to be in place by
December 31, 2005. The Department of the Army has chosen to conform to the International
Standards Organization (ISO) 14001 as a goal for the EMS; full conformance to ISO 14001 is
required by FY09. Appendix A illustrates the ISO 14001 standard.
URS Group, Inc. (URS) performed an EMS/ISO 14001 gap analysis at the 221st BSB in
Wiesbaden, Germany from 19-20 August 2002. The purpose of the analysis was to determine
current environmental management activities and compare them with the ISO 14001 standard.
The analysis evaluated present activities and identified missing elements. This Gap Analysis
Report provides recommendations for developing and implementing an EMS in general
conformance with ISO 14001 standards. Due to the nature of Department of Defense (DoD)
installations, strict conformance with ISO 14001 criteria may not be feasible, nor may it be
desirable. Flexibility in the EMS development should be allowed by individual installations in
order to lead to development of the most functional system.
A gap analysis is a tool used to assess the current environmental management program and
identify existing elements of an EMS. It is not a regulatory compliance assessment and does not
identify areas of noncompliance.

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SECTIONTWO

Methodology

The assessment team conducted a 2-day site visit at the 221st BSB in Wiesbaden, Germany
during the period 19-20 August 2002. The assessment process involved reviewing available
documents and interviewing BSB personnel regarding the current environmental management
program. Personnel from other organizations (i.e., tenant organizations and contractors) were
also interviewed if available and time permitted. The URS team interviewed the following
personnel:
2.

Section 2 TWO

Methodology

Mr. Guerba, Chief, Environmental Management Office (EMO), Directorate of Public Works
(DPW)

Mr. Bopp, Environmental Engineer, EMO, DPW

Mr. Peter, Environmental Technician, EMO, DPW

Mr. Adam, Environmental Technician, EMO, DPW

Mr. Abeleanu, Chief, Utilities Division, DPW

Mr. Kusiak, Chief, Mechanical Branch, Utilities Division, DPW

Mr. Spears, Environmental Compliance Officer, 3d Corps Support Command (COSCOM)

Mr. Baldwin, Training Support Center (TSC) Manager, 7th Army Training Command (ATC)

Mr. Buecher, Fire Inspector, Fire Department

Ms. Seitz, Environmental Technician, Defense Reutilization and Marketing Office (DRMO)

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SECTIONTHREE
3.

Section 3 THREE

Analysis

Analysis

This section is organized as follows:

The relevant ISO 14001 section reference is identified, site observations are noted, and
recommendations for improvements are identified.

The reference numbers preceding each paragraph title used below (i.e., ISO 14001, Section
4.2 - Environmental Policy) refer to the corresponding ISO 14001 paragraphs. A brief
paraphrase of the ISO 14001 standard, as it applies to the items discussed below, is provided
at the beginning of each section. Please note that this is a paraphrase and not a direct quote
from the standard.

Observations: Strengths and gaps were identified during the BSBs environmental program
assessment. The gaps generally are associated with attaining consistency with the ISO 14001
standard. Site observations are summarized and discussed.

Recommendations: Continual improvement is a key tenet to a successful environmental

management program and a requirement of the ISO 14001 standards. Accordingly,
improvements recommended for the BSBs environmental management program are
summarized and discussed.

3.1

ISO 14001, SECTION 4.2 ENVIRONMENTAL POLICY

According to ISO 14001, senior staff must define a policy and ensure that it is appropriate to the
mission and key environmental issues at the installation. The policy must include a commitment
to continual improvement, pollution prevention, and compliance with regulations and other
requirements. The policy must provide a framework for setting and reviewing objectives and
targets, must be implemented and communicated to all personnel and be made available to the
public, subject to considerations of military security and force protection.

Observations
Strengths
The BSB currently has the U.S. Army environmental goals (posted on the wall of the EMO) and
a BSB-specific environmental compliance policy memorandum (Memorandum, Headquarters,
221st Base Support Battalion, AETV-WSB-DPW-EE, 12 April 2002, subject: 221st BSB
Commander's Policy 1-25 (Environmental Compliance)). These documents may be used in
further developing the EMS policy.
The BSB-specific environmental compliance policy memorandum was distributed throughout
the BSB, including tenant organizations.
Gaps
A formal ISO 14001 environmental policy, specific to the BSB, does not currently exist. The
current policy lacks the following ISO 14001 requirements: a commitment to continual
improvement and pollution prevention, a framework for setting objectives and targets, and its
availability to the public.

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SECTIONTHREE

Analysis

Recommendations
1.

Develop an ISO 14001 compliant environmental policy specific to the 221st BSB. The
policy must consider the size of the BSB, its activities and environmental impacts and
include the following:
-

2.

3.2

A commitment to continual improvement and pollution prevention,

A commitment to comply with all applicable U.S. and Host Nation environmental
regulations, to include U.S. Department of Defense (DoD), U.S. Army, and USAREUR
regulations and policies, and
A framework for setting and reviewing environmental objectives and targets.

The environmental policy must be documented, implemented and maintained, and

communicated (i.e., via local U.S. Army newspaper, email, Web site, bulletin board posters,
pamphlets) to all personnel within the BSB, including tenant organizations and contractors
working within the BSB.

ISO 14001, SECTION 4.3.1 ENVIRONMENTAL ASPECTS

According to ISO 14001, the installation must establish and maintain a procedure to identify
environmental issues associated with each of its activities, products or services. A ranking must
be made for each environmental issue to identify those which have or could have a significant
impact on human health or the environment. Those issues that have or could have a significant
impact are considered key issues (i.e., significant aspects according to ISO 14001). Significant
aspects become the focus of the installation EMS and must be kept up-to-date.

Observations
Strengths
Various documents, listed below, are available at the BSB and within these documents potential
aspects may be found.

Final Governing Standards for Germany (FGS)

USAREUR Regulations (URs)

Department of the Army Regulations (ARs)

German laws and requirements

Asbestos Management Plan

Spill Prevention, Control, and Countermeasures (SPCC) Plan

Wiesbaden Air Base Wastewater Treatment Plant Permit

These documents could provide a partial list of environmental aspects. Examples include: the
effluent from the Wiesbaden Air Base wastewater treatment plant; air emissions from heating
plants; buildings with radon concentrations over 200 picocuries per liter; leaking underground
storage tanks; storage of water-endangering hazardous materials and waste; and buildings with
friable asbestos-containing material.

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SECTIONTHREE

Analysis

Gaps
The BSB does not have a formal procedure to identify and rank environmental aspects. The
procedure should focus on not only current compliance aspects, but an assessment of other
potential aspects not currently identified or considered. The aspects should be ranked in order of
significance.

Recommendations
1.

Develop and maintain a procedure to identify all environmental aspects related to the
activities of the BSB, which have or can have a significant effect on the environment. The
procedure should identify and rank the environmental aspects by significance.

2.

Perform a comprehensive BSB-wide review of aspects using the procedure developed

above.

3.

Document the results of the aspect identification and ranking.

4.

Those aspects determined to be significant must be considered when developing the BSB's
environmental objectives and targets.

5.

Communicate (i.e., via local U.S. Army newspaper, email, Web site, bulletin board posters,
pamphlets) significant aspects to all BSB personnel, tenant organizations and contractors
living and working within the BSB.

6.

Communicate, through training, the job-specific requirements to those personnel who can
have a direct impact on significant environmental aspects.

A significant aspect per ISO 14001 is an environmental aspect that has or can have a significant
environmental impact. The ranking system can be determined by the installation and may be
based on any number of factors such as mission or community importance. The aspects related
to significant impacts must be considered when setting environmental objectives.

3.3

ISO 14001, SECTION 4.3.2 LEGAL AND OTHER REQUIREMENTS

According to ISO 14001, the installation must establish and maintain a procedure to identify and
have access to legal and other requirements, which govern the operation and that are applicable
to the installation's environmental issues. In general for U.S. Army installations in Europe, the
Final Governing Standards are provided by the DoD-Appointed Environmental Executive Agent
and serve as the basic environmental compliance target.

Observations
Strengths
Many legal and other requirements are provided to the BSB by other organizations (i.e., Europe
Region, Technischer berwachungsverein [TV], and local German authorities). In addition,
some regulations and requirements are listed in the various documents below:

Asbestos Management Plan,

SPCC Plan, and

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SECTIONTHREE

Analysis

Potable Water Management Plan.

Section 2.1 of the Asbestos Management Plan describes the various U.S., German, and DoD
standards for Asbestos Management. Within the SPCC Plan, a cross-reference is made between
the various sections of the plan and the FGS for Germany, AR 200-1 and UR 200-1. The Potable
Water Management Plan paraphrases the drinking water requirements of the FGS for Germany.
Gaps
The BSB does not currently have a formal written procedure to identify and obtain all applicable
legal and other requirements.

Recommendations
1. Develop and maintain a formal written procedure to identify and promote access to
applicable legal and other requirements (DoD instructions, ARs, URs, various policies,
German organizations such as the TV) with which the BSB must comply. This procedure
must consider the FGS and also consider identifying other requirements that may be outside
the scope of the FGS.
2. For ease of access, compile a central list of all applicable legal and other requirements for
each environmental aspect identified. The list could be in hardcopy or kept as an electronic
file.
3. The list may be categorized by aspect.

3.4

ISO 14001, SECTION 4.3.3 OBJECTIVES AND TARGETS

According to ISO 14001, objectives and targets must be established and shall consider legal and
other requirements, and the significant aspects. The objectives and targets must be consistent
with the environmental policy (see Section 3.1), including a commitment to pollution prevention,
and must include the views of interested parties.

Observations
Strengths
Some informal, undocumented objectives and targets reportedly have been developed by the
BSB (i.e., quarterly inspections of all facilities storing, handling, or using hazardous
materials/waste).
Gaps
A full listing of objectives and targets has not yet been prepared since the BSB has yet to identify
all its significant environmental aspects. Those objectives and targets that have been identified
are generally limited to environmental compliance.

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SECTIONTHREE

Analysis

Recommendations
1.

Develop and maintain written environmental objectives and targets at each relevant function
and level within the BSB from the Commander to the user-level. The BSB must consider
the following when developing and revising its environmental objectives:
-

Legal and other requirements (as outlined above),

The significant environmental aspects (as outlined above),

The technological options,

Financial, operational, and business requirements, and

Views of interested parties (i.e., tenant organizations and contractors).

Various documents, listed below, are available at the BSB and could be used in developing a
list of objectives and targets for various environmental aspects. The documents include:
-

FGS,

ARs,

URs,

German laws and requirements,

BSB Potable Water Management Plan, and

Wiesbaden Air Base Wastewater Treatment Plant Permit.

Examples of objectives and targets that may be obtained from the aforementioned documents
include the following:
-

Wiesbaden Air Base Wastewater Treatment Plant Permit: Specific parameters and control
values are set.

FGS and the Potable Water Management Plan: Specific sampling requirements are
outlined, including parameters, maximum contaminant values and sampling frequency.

AR 200-1 (1997): Sets a specific waste minimization goal to reduce hazardous waste
generation by 50%.

German law and the FGS: The use of specific ozone depleting compounds is restricted.

The environmental objectives should also be in line with the BSB's environmental policy and
its commitment to pollution prevention.
2.

Keep a central list of all environmentally related objectives and targets to facilitate and
ensure the development and execution of the associated environmental management
programs.

3.

Communicate the objectives and targets to those personnel who can have a direct impact on
specific significant environmental aspects.

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SECTIONTHREE
3.5

Analysis

ISO 14001, SECTION 4.3.4 ENVIRONMENTAL MANAGEMENT PROGRAMS

According to ISO 14001, programs must be established and maintained for achieving the
objectives and targets. The programs must designate who has responsibility for the program as
well as the means and time frame by which the objectives and targets will be achieved.

Observations
Strengths
The BSB has developed environmental management programs (EMPs) to achieve compliance
with various environmental compliance media (i.e., asbestos, drinking water, wastewater, and
underground and above-ground storage tanks). For example, the BSB has developed an
Asbestos Management Plan, which essentially establishes a program as described by ISO 14001.
It could not be determined during the gap analysis how widely communicated and monitored
these EMPs are.
Gaps
Since not all objectives and targets have been identified at the BSB for significant environmental
aspects, additional EMPs may be required.
In some cases, a formal, documented program does not exist for achieving specific objectives
and targets already developed by the BSB. For example, although hazardous materials/waste
management was reported to be one of the BSBs most significant issues, the BSB was reported
to have an inadequate written hazardous materials/waste management plan.
Regarding drinking water, the current management plan does not include clearly defined roles
and responsibilities of various BSB organizations/personnel as required by the ISO 14001
standard.
There is also a lack of awareness within various organizations at the BSB regarding some EMPs
that have already been developed (i.e., SPCC).

Recommendations
1.

Develop and maintain environmental programs to meet each objective and target; EMPs
should include the following:
-

Clearly defined roles and responsibilities throughout the chain-of-command, including

tenant organizations and contractors, and

The means and time frames to complete each objective and target.

2.

EMPs should be revised when new or modified activities or projects may influence the
environment.

3.

Although the EMPs may be managed by various organizations, they should be centrally
tracked by one entity.

4.

The EMPs should be communicated to all personnel who have a responsibility within the
respective program.

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SECTIONTHREE
3.6

Analysis

ISO 14001, SECTION 4.4.1 STRUCTURE AND RESPONSIBILITY

According to ISO 14001, roles, responsibilities, and authorities must be defined, documented,
and communicated. Management must provide the essential resources to implement and control
the environmental management system. These resources include human resources, specialized
skills, and technological and financial resources as necessary.

Observations
Strengths
Informal (undocumented) structure and responsibilities within the EMO have been developed to
facilitate the environmental program. In addition, some plans clearly identified roles and
responsibilities (i.e., Asbestos Management Plan, SPCC Plan). The BSB has issued, through the
BSB Commander, standard operating procedures (SOP) for environmental compliance. Within
the SOP, roles and responsibilities regarding environmental compliance are described for various
organizations within the BSB. The SOP was distributed to all organizations within the BSB,
including tenant organizations.
Gaps
The environmental management responsibilities for managers/supervisors in the various
organizations (i.e., DPW, tenant organizations) should be clarified and more clearly documented,
communicated and implemented. For example, current job descriptions do not adequately
describe in detail the roles and responsibilities of the personnel within the EMO. It is reported
that in detailing job descriptions, employees are restricted from conducting duties outside the
documented job description.
Current human resources in charge of the environmental programs within the EMO (4 personnel)
can be taxed by multiple responsibilities resulting in the ability to only fight fires versus
managing programs to prevent problems.

Recommendations
1.

Clearly document the roles, responsibility, and authority of each individual within the
installations hierarchy. This may simply be accomplished by developing a Point of Contact
(POC) list for various environmental issues or by developing an organizational chart for the
environmental management program without affecting formal job descriptions.

2.

Assess the workload requirements to implement and maintain the EMS and to determine the
need for additional resources (contract or permanent) where necessary.

3.7

ISO 14001, SECTION 4.4.2 TRAINING, AWARENESS AND COMPETENCE

According to ISO 14001, the installation must identify the training needs and require that all
personnel whose work may create a significant environmental impact receive the appropriate
training. All personnel must have a thorough understanding of their role in maintaining
conformance with the environmental policy and procedures and how their work activities can
impact human health and the environment.

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SECTIONTHREE

Analysis

Observations
Strengths
BSB personnel interviewed during the gap analysis demonstrated general environmental
awareness; this is partly the result of some training activities and partly from experience.
Gaps
No procedure exists to identify the type of training (i.e., hazardous materials/waste management,
spill response, underground and above-ground storage tank management, regulatory
compliance), frequency of training including refresher courses, and which personnel should
receive specific types of training.
In addition, training is inconsistent due to frequent turnover of unit personnel.

Recommendations
1.

Develop and maintain a procedure to identify training requirements per personnel, training
frequency and documentation of training (records) for all personnel whose activities may
have a significant impact on the environment; include a method to train new personnel as
soon as possible.

2.

The procedure must also include awareness training for all personnel throughout the BSB,
including tenant organizations and contractors regarding the following:

3.8

The importance of following the BSB's environmental policy, procedures and the EMS,

Actual and potential significant environmental impacts per activity,

Environmental benefits of continuously improving personal performance,

Roles and responsibilities of each person regarding the BSB's environmental policy,
procedures, and EMS, to include emergency preparedness and response requirements,
and

The potential consequences of not conforming with specified operating procedures.

ISO 14001, SECTION 4.4.3 COMMUNICATION

According to ISO 14001, an installation must establish and maintain procedures for internal and
external communications regarding its significant environmental issues (significant aspects) and
its EMS. This includes internal communication between the various levels and functions within
the organization and responding to relevant communications from external interested parties.

Observations
Strengths
The BSB has established an Environmental Quality Control Committee (EQCC), which meets
quarterly, to discuss environmental compliance issues. Many BSB organizations, including
tenant organizations, are invited to attend the EQCC. This forum would be excellent to promote
communication of the EMS.
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SECTIONTHREE

Analysis

In addition, the BSB, through the BSB Commander, has issued an environmental compliance
memorandum and SOP establishing roles and responsibilities of various organizations within the
BSB, including tenant organizations, regarding environmental compliance, particularly for
hazardous materials/waste. This memorandum and SOP was distributed to all organizations
within the BSB.
Informal communications occur between various divisions within the DPW (i.e., EMO and
Utilities), between the DPW and other organizations within the BSB (i.e., EMO and Fire
Department, EMO and Training Support Center, EMO and 3d COSCOM), and between BSB
organizations and German organizations (i.e., EMO and local authorities, BSB fire department
and German fire department, Utilities and TV).
Gaps
The BSB does not have written procedures explaining and detailing various communications
between organizations within the BSB and for receiving, documenting and responding to
communications from external organizations.
Communication between divisions within the DPW and between the DPW and tenant
organizations is ineffective and does not occur on a regular basis as part of installation operations
(i.e., between EMO and 3d COSCOM, between the Utilities Division and EMO, between the
EMO and DRMO). Generally, communications only occur when one organization is seeking
specific information from another.

Recommendations
1.

Develop and maintain a procedure to describe communications regarding the BSB's

environmental aspects and the EMS. The procedure should include the following:
-

Internal communication throughout the BSB at all appropriate levels, to include tenant
organizations and contractors, and

Method for receiving, documenting and responding to communications from external

organizations (i.e., IMA EURO, 104th Area Support Group (ASG),
Wehrbereichsverwaltung, Bundesvermoegensamt, and local authorities).

2.

The procedures should include methods for proactive communication rather than the current
reactive communications.

3.

The BSB should consider a process for communicating its significant environmental aspects
externally (to the installation community) and record its decision. Under the current conditions, a
statement with regard to force protection would suffice as a reason for not communicating this
information outside of the BSB. Because of force protection, it is possible some information
should not be conveyed outside of the installation.

3.9

ISO 14001, SECTION 4.4.4 EMS DOCUMENTATION

According to ISO 14001, the installation must establish and maintain information in paper or
electronic form that describes the core elements of the environmental management system and
provides directions to related documentation.

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SECTIONTHREE

Analysis

Observations
Strengths
This ISO 14001 requirement is specific to the standard, and therefore, similar documentation
would generally not be found at the BSB.
Gaps
Since the EMS is not in place, a description of the core elements and direction to related
documents do not exist.

Recommendations
Establish an EMS Manual, either in electronic or hardcopy format, that describes all the core
elements of the environmental management system and their interaction, as well as instructions
to related documentation.

3.10 ISO 14001, SECTION 4.4.5 DOCUMENT CONTROL

According to ISO 14001, there must be procedures in place to control documents to ensure they
can be located, periodically reviewed and updated, removed when obsolete, and readily available
to all employees and operations that rely upon them. Documents must be legible, dated,
maintained in an orderly manner, and retained for a specified period. A procedure must be
established and maintained concerning creating and modifying the various types of documents.

Observations
Strengths
None observed
Gaps
Document control methods are inadequate per the ISO 14001 standard (i.e., ability to locate
documents is difficult, several obsolete documents were observed).

Recommendations
1.

Establish and maintain a document control procedure that includes the following:
-

Description as to where various documents are located,

A review process for all documents that is revised when necessary and approved by
authorized personnel (i.e., BSB Commander),

Instructions to make available all current and relevant documents at all locations where
activities essential to the effective functioning of the BSB's EMS are conducted,

A process for removing obsolete documents from all points of use or assuring against
unintended use, and
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SECTIONTHREE
-

Analysis

The identification of obsolete documents that must be retained for the purpose of legal
and/or historical preservation.
The U.S. Army has established the Modern Army Record Keeping System (MARKS). This
system combines filing and disposition procedures during the labeling process, and forms a
clear relationship between the numbering system of directives and the numbering system
used to file and find records that are produced as a result of those directives. The BSB
should evaluate a method for utilizing components of this system to develop an installationspecific document control system.

2.

All documentation must be legible, dated (including all revision dates), readily identifiable,
maintained in an orderly manner, and retained for a specific period of time.

3.

Establish and maintain a procedure for creating and modifying the various types of
documentation. Responsibilities of all personnel regarding this procedure should be clearly
defined.

3.11 ISO 14001, SECTION 4.4.6 OPERATIONAL CONTROL

According to ISO 14001, the installation must establish and maintain procedures and controls to
cover situations where the absence of such procedures/controls could lead to deviations from the
policy, objects, or targets. These controls must not only address normal operations but
maintenance activities as well.

Observations
Strengths
The BSB maintains numerous documents/plans that address various operational controls for
specific environmental areas (i.e., Potable Water Management Plan; SPCC Plan; Asbestos
Management Plan). For example, the SPCC Plan details procedures for preventing, mitigating,
and reporting spills of hazardous materials/waste. The Potable Water Management Plan
establishes a sampling plan for monitoring the drinking water at each installation within the BSB
to ensure compliance with the FGS. The Asbestos Management Plan describes operation and
maintenance procedures for work on and around asbestos-containing materials as well as air and
bulk sampling procedures. It could not be determined during the gap analysis how widely
communicated and how effective these documents are.
Gaps
Since the BSB has not determined their significant environmental aspects per the ISO 14001
standard, some operational controls have yet to be developed. For hazardous materials/waste
management the BSB has not formally documented the operational control procedures, though it
is reported to be one of their most significant environmental issues. Reportedly, the BSB has a
plan; however, it is inadequate and does not meet the needs of the BSB. The BSB has a funded
project to revise/update the plan, with work to commence following the finalization of the
revised FGS.

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SECTIONTHREE

Analysis

Recommendations
1.

2.

Develop and maintain operating procedures for those operations and activities associated
with the BSB's significant environmental aspects, and objectives and targets. The
procedures must include the following:
-

Instructions to cover situations where their absence could lead to deviations from the
BSB's policy and objectives and targets,

Specific operating criteria,

Maintenance activities, and

Instructions for the use of goods and services by the BSB and communicating relevant
procedures and requirements to suppliers and contractors.

Consider instituting operational controls, such as procedures, work instructions,

instrumentation or other technology, to ensure activities that may cause significant
environmental impacts are adequately controlled. This should be applied to existing
operational controls and to operational controls developed for future significant
environmental aspects.

3.12 ISO 14001, SECTION 4.4.7 EMERGENCY PREPAREDNESS AND RESPONSE

According to ISO 14001, the installation shall establish and maintain procedures to identify the
potential for, and response to, accidents and emergency situations. Emergency preparedness and
response procedures are to be reviewed after the occurrence of a situation and must be tested
periodically.

Observations
Strengths
The BSB has conducted mass-casualty exercises with the German fire department, police, and
area hospital. The BSB has a SPCC Plan that has been distributed to various organizations. The
BSB fire department personnel, as the first responders, receive appropriate annual training for
their job. In addition, the fire department is asked to attend the BSBs quarterly EQCC meetings.
Personnel within the BSB were aware that the BSBs fire department is the first responder in the
event of emergencies.
Gaps
The SPCC Plans roles and responsibilities do not reflect the actual implementation of the plan.
For example, the EMO is identified as the individual to coordinate and direct the overall control
and cleanup of hazardous materials (HM) or hazardous waste (HW) discharges or spills on the
installation; however, it appears that the fire department takes this role.
An overall plan for other emergency scenarios (i.e., flooding, high winds, explosion, biological
and chemical attacks) apparently does not exist.

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SECTIONTHREE

Analysis

Recommendations
1.

Develop and maintain procedures to identify the potential for, and response to, all types of
accidents and emergency situations and methods for preventing and mitigating
environmental impacts that may result from the response. This may involve revising and/or
expanding the current BSB SPCC Plan.

2.

Review and revise the procedures when necessary, particularly following the occurrence of
an accident or emergency situation.

3.

Expand the annual mass casualty exercise to include other potential emergency situations
(i.e., loss of potable water, airplane crash at the airfield).

4.

The plan should be distributed to all appropriate personnel.

5.

The current SPCC Plan should be revised to reflect actual roles and responsibilities (i.e., the
fire department is responsible for overall control and cleanup of HM/HW discharges or spills
on the installation).

3.13 ISO 14001, SECTION 4.5.1 MONITORING AND MEASUREMENT

According to ISO 14001, the installation shall establish and maintain procedures to monitor and
measure the key characteristics of its operations and activities that can have a significant impact
on human health and the environment. These procedures must include recording information to
track performance, relevant operational controls and conformance with the organizations
objectives and targets.

Observations
Strengths
Since the BSB has not implemented an environmental management system, there are no aspects,
objectives and targets and associated monitoring and measuring procedures; however, current
programs include monitoring and measuring techniques (i.e., drinking water monitoring,
underground storage tank (UST) leak detection systems, asbestos identification and assessment,
and HM/HW management inspections). No written records of monitoring or measurement were
observed during the gap analysis.
Gaps
For many of the BSBs current monitoring and measuring techniques there is an informal, nondocumented procedure for implementing methods, equipment calibration, and records
maintenance (i.e., UST leak detection system monitoring, HM/HW management inspections).

Recommendations
1.

Develop and maintain procedures for regularly measuring and monitoring all the BSB's
operations and activities that can significantly impact the environment. The procedures must
include a method for recording results:
-

To track performance, of relevant operational controls, and

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SECTIONTHREE
-

Analysis

To determine whether the BSB is meeting its environmental objectives and targets.

2.

Methods for calibrating and maintaining monitoring equipment, as well as procedures for
recording the results of these activities must also be included in the BSB's procedures.

3.

Develop and maintain procedures for periodically evaluating compliance with relevant
environmental legislation and regulations.

3.14 ISO 14001, SECTION 4.5.2 NONCONFORMANCE AND CORRECTIVE AND

PREVENTIVE ACTION
According to ISO 14001, the installation shall establish and maintain procedures for defining
responsibility and authority for handling and investigating non-conformances, taking action to
mitigate any impacts and for initiating and completing corrective and preventive action.

Observations
Strengths
Current programs include non-conformance and corrective and preventive techniques (i.e.,
flushing to reduce lead in drinking water; corrective actions for non-compliant HM/HW
management following inspections; TV inspections for USTs and chimney sweep air emission
results include required corrective and preventive actions that must be taken to achieve
compliance). These current non-conformance and corrective and preventive action procedures
could be used as a format for resolving similar issues from newly identified significant
environmental aspects.
Gaps
For many of the BSBs current non-conformance and corrective and preventive techniques there
is not a documented procedure including responsibilities, implementation of appropriate actions,
and documenting revisions. For example, there are no procedures for HM/HW management
inspections or corrective action recommendations.

Recommendations
1.

2.

Develop and maintain procedures that include:

-

Defining roles and responsibilities and authority for handling and investigating
nonconformance,

Actions to be taken to mitigate impacts, and

Methodology for initiating and completing corrective and preventive actions.

Implement and record all changes to the documented procedures that have resulted from
corrective and preventive actions.

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SECTIONTHREE

Analysis

3.15 ISO 14001, SECTION 4.5.3 RECORDS

According to ISO 14001, the installation shall establish and maintain procedures for the
identification, maintenance, and disposition of environmental records. These records shall
include training records and the results of audits and management reviews.

Observations
Strengths
Some programs have good record maintenance techniques (i.e., asbestos identification surveys,
chimney sweep air emission reports, and TV UST inspection reports). As mentioned under
Section 3.10-Document Control, the U.S. Army has developed the MARKS for maintaining
records.
Gaps
In many instances current record keeping is fragmented and dispersed and, therefore, information
retrieval is difficult (i.e., HM/HW management inspection reports are kept by various personnel
within the EMO at their desks). There is no procedure in place for identifying and retaining
records/files, including personnel, legal, operations, training, environmental/regulatory and
compliance audits.

Recommendations
1.

2.

3.

Develop and maintain procedures for the following:

-

Identification of environmental records,

Maintenance of the records, and

Disposition of the records.

The environmental records must be:

-

Legible,

Identifiable,

Traceable to the activity or service involved,

Stored and maintained so that they are easily retrievable,

Protected against damage, deterioration or loss, and

Maintained according to specified retention times.

The environmental records must also include training records and results of audits and
management reviews.

3.16 ISO 14001, SECTION 4.5.4 EMS AUDIT

According to ISO 14001, the installation shall establish and maintain programs and procedures
for periodic EMS audits to determine if the organization is functioning according to the plans
and procedures of the EMS and according to the ISO 14001 standard.
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SECTIONTHREE

Analysis

An internal EMS audit should be conducted annually by the BSB. IMA EURO will conduct an
external audit of the BSBs EMS every three years.

Observations
Strengths
Environmental audits are conducted by IMA EURO using Environmental Compliance
Assessment System (ECAS) every three years and by using the 104th ASG Command Inspection
Program (CIP) annually at the BSB. The BSB submits installation status reports annually using
Installation Status Report (ISR) II. However, these reports do not substitute as formal internal
audits.
Gaps
The aforementioned environmental audits have primarily focused on environmental compliance.
The BSB does not have formal written procedures to conduct comprehensive environmental or
EMS audits.

Recommendations
1.

Develop, implement and maintain procedures and a program to periodically review the
BSB's EMS to determine whether:
-

It conforms with the ISO 14001 standard, and

It has been properly implemented and maintained. Existing methods may be adapted to
perform this review.

2.

The program, including its schedule, must be based on the environmental importance of the
activities concerned as well as the results of previous audits.

3.

The audit procedures must include:

4.

The scope of the audit,

Frequency,

Methodology,

Roles and responsibilities,

Requirements for conducting audits, and

Requirements for reporting results.

The results of the audit must be provided to senior staff (i.e., during quarterly EQCC
meetings).

3.17 ISO 14001, SECTION 4.6 MANAGEMENT REVIEW

According to ISO 14001, a management review shall be conducted to ensure the suitability,
adequacy, and effectiveness of the environmental management.

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SECTIONTHREE

Analysis

Observations
Strengths
The BSB reportedly has established an EQCC that meets on a quarterly basis. The BSB
Commander acts as the Chairman of the EQCC. However, EQCC meeting minutes were
unavailable for review during the gap analysis.
Gaps
Currently, the EQCC does not review the EMS, since an EMS has not been formally established
at the BSB. In addition, all organizations that should attend the EQCC are not always
represented (i.e., 3d COSCOM).

Recommendations
1.

Once an EMS has been formally established at the BSB, a management review (i.e., EQCC)
must be conducted of the system. The review must be conducted at intervals set by senior
staff (i.e., BSB Commander, EQCC) to ensure its adequacy, suitability and effectiveness.
The review process must ensure that the management has the necessary information to
adequately evaluate the system. The review must be documented. It must address the
possible necessity to change the BSB's policy, objectives, and other items of the EMS,
taking into account the results of audits, changing circumstances, and the commitment to
continual improvement.

2.

The current EQCC could easily be adapted to address the management review of the BSB's
EMS by simply adding it as an agenda item.

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SECTIONFOUR

Conclusions

The gap analysis showed that the 221st BSB has an active environmental management program
that is primarily compliance based. Personnel interviewed within the BSB all have good
environmental awareness and continuously strive to meet and maintain environmental
compliance requirements. However, the BSB does not have EMS documentation including an
environmental policy specific to the BSB, a formal procedure to identify and rank environmental
aspects, and a full listing of objectives and targets. The objectives and targets that have been
identified are limited to environmental compliance only and do not include objectives and targets
for continuous environmental improvement. Job descriptions for individuals overseeing various
environmental media should be more clearly documented and communicated to facilitate the
management of the various programs. In addition, written programs that are available do not
always match actual installation activities. The table below summarizes the results of the gap
analysis by each EMS element described in the ISO 14001 standard.
4.

Section 4 FOUR

Conclusions

Table 2: Summarized Results of EMS Gap Analysis

EMS Element
Environmental Policy
Environmental Aspects
Legal and Other Requirements
Objectives and Targets
Environmental Management Programs
Structure and Responsibility
Training, Awareness and Competence
Communication
EMS Documentation
Document Control
Operational Control
Emergency Preparedness and Response
Monitoring and Measurement
Nonconformance and Corrective and Preventive Action
Records
EMS Audit
Management Review

221st BSB
Wiesbaden
Status
None
Limited
Limited
Limited
Limited
Limited
Limited
Limited
None
None
Limited
Good
Limited
Limited
Limited
None
Limited

Definitions:
None = Element is largely absent
Limited = Element is somewhat present in existing USAREUR/IMA EURO procedures,
documents or programs but will require formalization, modification and/or revision
Good = Element is largely present in existing USAREUR/IMA EURO procedures, documents
or programs but may require some formalization, modification or revision
A summarized list of strengths by each EMS element identified during the BSB's gap analysis
that may be used to help in developing the EMS once the BSB identifies and ranks all of its
environmental aspects is provided in Appendix B.
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Appendix A
ISO 14001 Flow diagram

Appendix A
ISO 14001 Flow Diagram
EMS Management
Review

Environmental
Policy
Aspects:
Identification
Evaluation of
Significance

Objectives and
Targets

Management
Program

Legal and Other

Requirements

Roles,
Resources,
Training and
Communication

Records (of
everything in
system)

Operational
Control and
Emergencies

Monitoring
and
Measurement

EMS Manual
and
Document
Control

NonConformance
and Corrective
Action

EMS
Audit

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Appendix B
Environmental Management System (EMS) Strengths Analysis Summary Table

Appendix B
Environmental Management System (EMS) Strengths Analysis Summary Table
EMS Element
Environmental Policy

Environmental Aspects

Legal and Other

Requirements

Objectives and Targets

Environmental Management
Programs

Structure and Responsibility

Training, Awareness and

Competence
Communication

EMS Documentation

Document Control
Operational Control

221st BSB
Wiesbaden
U.S. Army Environmental Goals posted bulletin
Environmental Compliance Policy memo (12 Apr 2002)
Final Governing Standards (FGS)
USAREUR Regulations
Department of the Army Regulations
German Regulations
Asbestos Management Plan
SPCC Plan
Wastewater Treatment Plant Permit
IMA EURO
TV (German Federal Authority)
Local German Authorities
Asbestos Management Plan
SPCC Plan
Potable Water Management Plan
BSB inspections of HM/HW facilities
Various compliance programs including:
- Asbestos
- Drinking water
- Wastewater
- Underground storage tanks
- Above-ground storage tanks
- Radon
EMO personnel education, professional certifications
and technical skills appear appropriate to their
responsibilities
BSB demonstrate good general environmental awareness
Environmental Quality Control Committee (EQCC)
Informal communication between EMO and tenants
BSB Commander issuance of environmental compliance
memo to the installation (12 Apr 2002)
The EMS documentation (manual) is specific to the
program; therefore, a similar document does not exist
None observed
Potable Water Management Plan
Asbestos Management Plan
SPCC Plan
Environmental Compliance SOP (12 Apr 2002)

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Appendix B
Environmental Management System (EMS) Strengths Analysis Summary Table
EMS Element
Emergency Preparedness
and Response

Monitoring and
Measurement

Nonconformance and
Corrective and Preventive
Action

Records

EMS Audit

Management Review

221st BSB
Wiesbaden
BSB recently conducted mass-casualty exercise
including the German fire department, police and
hospital
SPCC Plan distributed to various organizations
BSB fire department receives appropriate annual training
Installation personnel are aware that the fire department
is the first responder to contact in emergencies
Some current programs involve monitoring:
- Drinking water
- UST leak detection
- Asbestos identification
- HM/HW inspections
Some current programs involve corrective/preventive
actions:
- Flushing to reduce lead in drinking water
- Follow-up to HM/HW inspections
Some programs have good record maintenance
techniques:

Asbestos

USTs
Current external audits:
IMA EURO (ECAS)
th
104 ASG (CIP)
Current annual status reports:
- ISR II
Quarterly EQCC meeting

Note: The summary of strengths identifies current sources of USAREUR/IMA EURO

procedures, documents, and programs that may contribute to fulfilling the requirements of the
respective EMS element. The strengths are provided as examples and are not meant to represent
all potential applicable procedures, documents, and programs.

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