Environmental Management
System (EMS)

Our environmental policy, practices and procedures apply to 100 percent of Waste Management-owned and -operated facilities and operations.

1. Environmental Policy

Our Corporate Environmental Policy establishes the vision for our Environmental Management System (EMS). The Policy states, in part:

Waste Management is committed to protecting human health and the environment. This commitment is a keystone of all that we do, reflected in the services we provide to customers, the design and operation of our facilities, the conditions under which employees work, and our interactions with the communities where we live and do business. We will be responsible stewards of the environment and protect the health and well-being of our employees and neighbors. We have policies and standards for specific environmental and related aspects of our operations.

2. Planning

Our EMS focuses on preventing, correcting and ultimately reducing impacts associated with our operational activities. Specifically, we focus on the following:

  • Eliminating environmental impacts, including spills or leaks from vehicles, landfill gas impacts on the air or subsurface and releases to surface water or groundwater;
  • Eliminating community impacts, including odors, litter, noise, dust, and spills or leaks; and
  • Eliminating regulatory impacts, including regulatory inspection-alleged issues, warning letters, violations and enforcement actions.

We also use several databases, systems and processes designed to help facility managers plan, implement, check and respond to their site-specific environmental requirements.

Legal and Other Requirements

Our EMS tools continually evaluate and determine what regulations, permit conditions and contract requirements apply to facilities. These tools include the following:

  • CyberRegs: An online source for all state and federal statutes and regulations
  • Regulatory Outreach: Active involvement by our technical professionals in state and local activities associated with environmental regulation development and policy making

Waste Management’s environmental teams work closely with our Legal and Government Affairs departments, and they utilize the above resources to ensure that all facilities have access to relevant laws and regulations.

Objectives and Targets

We use the following indicators to quantify environmental performance:

  • Environmental impacts/No impacts to the environment
  • Community environmental concerns/No community environmental impacts
  • Regulatory violations/No violations

Our Environmental Incident Rate (EIR) measures our performance and tracks progress toward these goals at the facility level. The EIR is used to drive continuous environmental improvement on a year-over-year basis.

3. Implementation

Roles and Responsibilities

Our EMS relies on our corporate, geographic area and facility-level personnel with job-specific functions, roles and responsibilities for planning, implementing and evaluating the EMS components. The specific departments and personnel involved include the following:

  • Environmental Protection (EP): Develops environmental policies, tools and training, and provides strategic or technical advice, with the goal of 100 percent compliance. Oversees environmental performance and ensures environmental impacts and issues are resolved, including correction and prevention.
  • Corporate Engineering Science: Manages research and engineering science to develop an understanding of the interrelationships between our disposal processes and the environment.
  • Environmental Engineering (EE): Provides expertise in the planning and design of our facilities to ensure that operational activities have limited environmental impact. Performs annual planning and forecasting of life-of-site costs for our landfills, including Financial Accounting Standard 143 retirement obligations; the engineering and accounting controls exercised during this process are extensive and are subject to SOX 404 controls (from section 404 of the Sarbanes-Oxley Act) that are reviewed annually by independent external auditors.
  • Air/Landfill Gas Management (AGM): Develops and implements the corporate GHG and carbon emissions tracking and reduction strategies. Sets policies and standards. Is responsible for the planning and development of air quality and landfill gas management tools.
  • Groundwater Protection (GP): Provides expertise and direction on groundwater protection programs and ensures that environmental monitoring networks are installed and operating to specifications. Provides laboratory services that ensure accuracy and quality control in the analytical testing of environmental samples.
  • Laboratory Services (LS): Provides oversight and guidance to the commercial laboratories that support Waste Management’s monitoring programs in order to manage risk associated with the analytical testing of environmental samples. Provides support to all facilities that collect certain routine environmental data as detailed by the Groundwater Protection Program.
  • Waste Approvals: Ensures permit compliance and safe and environmentally sound waste acceptance procedures and controls.
  • Government Affairs: Monitors and engages with key federal, state and local governmental entities to ensure that we are at the forefront of developing trends and regulations.
  • Legal: Provides guidance, support and advice to our sites and market areas. Monitors compliance trends. Manages the company’s process of analyzing the root cause of any failures.
  • Site Managers and Frontline Employees: Are responsible for all environmental aspects at the site level, with key environmental tasks assigned to appropriately trained local staff.

Training

Waste Management recognizes that in order to achieve environmental performance goals, employees must possess the knowledge and skills to manage and conduct operations in environmentally responsible ways. Our environmental training targets a range of operational and functional levels within the company. All new employees participate in corporate ethics and compliance training, which includes our company’s standards for environmental practices. Corporate and local staff with responsibility for environmental leadership are trained in the company’s environmental practices.

Employees with environmental leadership responsibility are provided training through the following programs:

  • Waste Management University (WMU) – Environmental Protection Learning Series (EPLS) online modules: Monthly online site management trainings on a different environmental subject each month. Attendance is mandatory and knowledge is tested and tracked.
  • In-person training sessions: On-site trainings conducted by our field EP and/or operations professionals for facility management and technical staff on environmental and compliance subjects.

In addition, Waste Management has environmental training programs targeting operational and functional levels. Our Environmental Compliance Awareness Program (ECAP) provides mandatory monthly training for front-line employees and managers, covering a different environmental subject each month. Knowledge is tested and tracked at the site level. Monthly topics are aligned between these programs whenever possible.

Local training is also provided periodically via in-house classroom training, on-the-job training and outsourced training. In addition, staff with responsibilities related to specific environmental requirements for our operations sometimes need job-specific training, which is provided to employees and managers at all Waste Management operations.

We also use our WMU capacity to provide training to customers, for example on DOT hazardous waste handling requirements.

Communications

Communicating environmental commitment and performance to our customers, communities, regulators and investors strengthens our ability to be an environmental leader in our industry. Internal communications regarding environmental commitment and performance help to create an atmosphere where all employees work toward the common goal of continuous improvement.

We communicate within the company using the following methods:

  • Waste Management’s Environmental Incident Alert Notification System gives immediate notification of significant environmental or regulatory events — including reportable quantity (RQ) spills, environmental impacts (e.g., stormwater, leachate), alleged violations and enforcement actions — company-wide.
  • Waste Management’s CASES Database and Public Commenter Systems provide real-time notification of any customer-related environmental issues to site managers for response and resolution.
  • Environmental performance results, including the following impacts, are tracked monthly and communicated company-wide and to senior leadership via the EP Dashboard:
    • Environmental impacts such as spills, leaks, gas migration, groundwater contaminant exceedances, certain releases to ambient air and stormwater discharges in excess of applicable standards
    • Regulatory impacts such as alleged violations, inspections and enforcement actions
    • Community impacts such as off-site spills/leaks, odors, noise, pests, mud and litter
  • Waste Management Visor, our intranet system, updates reporting systems to help manage tracking of landfills, tanks, authorized vendors and environmental compliance.
  • Overall compliance performance is reported to management according to the EP reporting structure, via routine activity reports.

We communicate with our communities, customers, regulators and investors through other methods, including the following:

  • Waste Management’s corporate website highlights significant research, environmental awards and unique achievements in environmental management.
  • Community comments are centrally managed and tracked through response and, if necessary, correction.
  • Our environmental scientists and professionals present achievements and research at national and international environmental conferences.
  • Our Corporate Communications department is responsible for communication of environmental issues at the company.
  • Our local managers support community outreach programs.

Documents and Operational Controls

Waste Management has several internal systems for maintaining documents and records related to the EMS. The location of any particular document or record depends on the specific application, since many of the EMS tools are multiple-purpose programs. The two main internal systems are the following:

  • Waste Management Visor Environmental Protection website: Visor is the company’s intranet, with links to all formal corporate environmental policies, standards, documentation and resources, including the EMS, training materials, web-based tracking systems and databases. Visor is available to all company employees and is reviewed and revised on a routine basis to ensure that it is up-to-date and includes the most recent documents.
  • Waste Management Environmental Program SharePoint: The EP SharePoint webpage is used to store and share environment-related documents, guidance, training materials and other electronic resources. All Environmental Program and Technical Managers have access to the EP SharePoint website. The SharePoint is available for interactive program tracking (e.g., site visits, odor tracking), document development, idea development and sharing, and document sharing. The EP SharePoint page is regularly reviewed and updated.

We have a wide range of environmental databases including the following:

  • Cycle: The compliance assurance task calendar program for identifying and tracking completion of site environmental tasks regarding permits, regulations, site plans, policies, etc.
  • Environmental Reporting System (Incident Alerts): The repository for reported agency-identified violations (AIVs), environmental exceedances and public comments.
  • Dakota Auditor and Tracer: A third-party audit management system used to manage compliance representation letters. Also used to track environmental and safety audit findings and corrective actions.
  • Environmental Enforcement Database (EED): The Legal department’s violation tracking database for tracking significant violations through completion and reporting the results to senior management and corporate governance.
  • Storage Tank Database: Used to manage aboveground and underground storage tanks, including registrations for insurance purposes.
  • Applied Landfill Information Analysis System (ALIAS): A relational database used to cross-reference landfill characteristics (e.g., cover, liner, waste type) to monitoring points and results.
  • EQuIS: Contains our groundwater, surface water and other analytical data provided by contract laboratories. Used for reporting, data integrity and management purposes.
  • Landfill Gas Management System (LGMS): Houses operational and performance data relating to landfill gas collection and control systems.
  • PharmE Waste Wizard: Maintains hazardous waste categorization for over 220,000 pharmaceuticals on the market, updated weekly.

In addition to the above, each facility is responsible for maintaining its own operating record, including documents, inspections and reports required by regulation.

Emergency Preparedness and Response

We’re always working to refine and improve the disaster response and preparation plans for our facilities. We maintain an Emergency Situations and Evacuation Plan Policy, which communicates management objectives for addressing emergency situations. Facilities may also be required to maintain specific emergency response plans including the following:

  • Hurricane Preparedness Plans and annual simulation exercises.
  • Disaster Preparedness and Management Plans in areas subject to natural disasters (e.g., tornados, fires, earthquakes), for safe handling of disaster-generated debris.
  • Spill Prevention Control and Countermeasures (SPCC) Plans for facilities that store certain volumes of petroleum products and are required to prevent, contain and control spills.

Our employees are trained and drilled to comply fully with Emergency Situations and Evacuation Plans, Local Preparedness Plans and Spill Plans.

4. Assessment and Corrective Action

Monitoring and Measurement

We use the following programs as a multipurpose, integrated system to monitor, measure, report and track environmental aspects and impacts through closure/completion:

  • EP Dashboard – Environmental Incident Rate (EIR):his online system is used to measure, track and report performance across three areas: the environment, our communities and regulations. Our performance goal is continuous year-over-year improvement in EIR performance (Environment, Community and Regulatory).
    • Environment: Environmental incidents that occur at our operations are compiled, including the following:
      • Spills/leaks that hit the ground from vehicles
      • Groundwater impacts that exceed regulatory criteria or that show increasing trends
      • Stormwater impacts above benchmarks or reportable release levels
      • Leachate impacts
      • Air impacts that include surface emission overages or reportable air emissions
      • Landfill gas impacts registered by perimeter gas probes
    • Community: To underscore the company’s commitment to the communities it serves, Waste Management developed and deploys a public comment management system. When a comment is received, the information necessary for a prompt response and remedy is routed to the closest responsible manager. The manager is empowered to take action appropriate to the circumstances and track remedies through to completion.
    • Regulatory: Regulatory incidents and, more important, their precursors are tracked, managed and recorded for each occurrence as part of the company’s compliance program and continuous improvement process. Lessons learned are shared via the company’s EP Dashboard and program of weekly and monthly reporting. Senior management, including the Board of Directors, is briefed on performance on a regular basis. The position of Chief Compliance Officer exists to elevate the issue of regulatory compliance.
  • EP Dashboard – EP Toolkit: The EP Toolkit is used to evaluate environmental performance system metrics for the company’s business operations every month. EP Toolkit metrics help ensure that all cycle tasks, audit findings and environmental incidents are completed in a timely manner, and effective corrective actions and preventive measures are implemented.
  • EP Dashboard – System Reports: A System Report is a month-end environmental performance summary that is automatically sent to EP Dashboard users of record.
  • Dashboard reporting tool also provides users with the ability to review and report environmental performance results on a real-time or scheduled basis.

Corrective Action and Preventive Measures

Local EP Managers are responsible for ensuring resolution and prevention of issues identified through the EP Dashboard, EP Toolkit and other environmental database reports. Facility and EP Managers are responsible for ensuring that all identified incidents are closed out completely and correctly. Measures or actions that are not effective are subject to reopening of the incident.

  • Environmental Incident Rate incidents are documented and tracked until all corrective actions and preventive measures are implemented. Performance related to completion of the corrective and preventive measures is tracked via the EP Toolkit.
  • Public Comment Management Program is the process for addressing environment-related calls from our customers and communities. Environmental comments received at Customer Service Centers are entered into a program called CASES, while calls received directly by the facility are entered into Public Commenter by the site staff. Any comment requiring corrective action is routed to the local entity for response and resolution. Environment-related comments uploaded into either system are centrally tracked through correction and preventive measure implementation.
  • The Waste Management Compliance and Ethics Help Line is our portal to internally identify potential instances of noncompliance with company or regulatory procedures. We communicate to employees that it is available for their use. Every inquiry is logged and tracked to ensure that the issue is resolved, up to and including any required corrective actions. The Legal department and EP work together to assess whether the incident has any national implications and to ensure that the corrective action is spread across the organization — so that a lesson learned in one location is rippled across the organization. The Help Line is a confidential system, designed to protect employees’ identities while ensuring that the reported issue is resolved.

Our facilities are expected to ensure that corrective actions and preventive measures are effective. Environmental issues are not closed out in any of these systems without the concurrence of the EP Manager.

Compliance Audits

Waste Management’s Corporate Compliance Audit Services (CAS) conducts independent environmental, health and safety (EHS) and transportation compliance audits. Each year the department conducts hundreds of audits at facilities owned, operated or controlled by the company. Audit planning and scope are based on risk assessment principles, including the nature of operations and consideration of emerging regulatory and EHS trends. CAS reports to the Vice President and Assistant General Counsel/Regulatory, Chief Compliance Office and Legal department. Audit practices are modeled on the nationally recommended compliance audit practices approved by the American Standards for Testing and Materials and the standards for professional auditors approved by the Board of Environmental Health and Safety Certifications.

CAS evaluates and supports improvement of the company’s EHS performance through the following activities:

  • Conducting systematic, documented and objective evaluations to verify compliance with environmental regulatory requirements;
  • Assisting the company in evaluating and improving the effectiveness of existing EHS and transportation systems and policies; and
  • Assisting the company and its managers in preventing, detecting, correcting and proactively addressing compliance issues.

CAS processes and procedures include the following:

  • Assessing risk and selecting facilities to audit;
  • Training of staff conducting audits;
  • Developing audit protocol documents;
  • Planning and conducting audits;
  • Identifying noncompliant activities;
  • Resolving audit findings;
  • Documenting management and retention;
  • Reviewing and updating program directives and procedures;
  • Auditing quality control and assurance; and
  • Communicating of audit results.

Facility staff use designated programs (e.g., Dakota Tracer) to document resolution of all audit findings. CAS reviews all findings before they are closed and conducts verification audits to ensure that the finding resolution was effective. CAS communicates the audit results to relevant local and corporate management and follows up to ensure the timely resolution of issues identified through its compliance audits.

Records

Certain data elements are reported with routine frequency, while others are reported on a nonspecified schedule.

Certain groundwater and surface water test data are collected on a routine basis and tied to sampling events specified in operating permits, licenses and applicable permits (usually quarterly or semiannually). These results are housed centrally through our laboratory management program and are reported as they are generated.

Incidents related to unanticipated releases to the environment (e.g., spills, environmental impacts) are required to be reported within 48 hours to the corporate office, on a real-time basis. Notification of these incidents ensures the appropriate resources are made available to address the particular situation and to minimize potential impact to the environment. Response actions are also monitored for effectiveness and timeliness.

Records relating to analytical results, environmental performance elements and compliance assurance tasks are all maintained online within our IT, Legal and/or Environmental Protection departments. Documents and technical resources are available and maintained on our Visor and SharePoint intranet sites, as are training, guidance and standards resources.

Key environmental metrics are reported and compiled on a weekly basis, monitored and reported to senior management monthly, managed and stored online. Environmental aspects of our business, including notices of violation, are reflected in senior management reporting and through an internal environmental metric system that is provided to senior management and housed in the Environmental Enforcement Database (EED). Landfill gas collection system performance is monitored monthly with metrics designed to detect and correct upsets.

All of our facilities must certify annually their compliance with all applicable permits and regulatory requirements through our centralized Compliance Representation Letter process, which is reviewed by senior management yearly.

5. Management Review

Our management teams participate in a management review process to determine the level of success in achieving environmental goals. In doing so, they complete the following tasks:

  • Review environmental policies
  • Review Waste Management’s EMS
  • Review the EP Dashboard environmental performance, issues and incidents on a routine basis
  • Evaluate corporate and local environmental goals and objectives
  • Amend the EMS as needed, including policies, procedures, goals and objectives

Management review and response to environmental performance measures, incidents and issues are used to drive operational changes and ensure that continuous improvement goals are met. Our Internal Audit department performs compliance evaluations on an ongoing basis.