ENVIRONMENTAL
MANAGEMENT SYSTEM MANUAL
i EMS-0001
Rev. 2.0
This is an electronically controlled and issued document; hard copies should be verified for revision.
ENVIRONMENTAL MANAGEMENT
SYSTEM MANUAL
SPARTAN MOTORS USA, INC.
1000 REYNOLDS ROAD
CHARLOTTE, MICHIGAN 48813
TABLE OF CONTENTS
1.0 Introduction .............................................................................................................................1
2.0 Cross-Reference Table ............................................................................................................1
3.0 Distribution, Revision and Control ......................................................................................2
4.0 Environmental Management System Requirements .........................................................3
4.1 General Requirements ......................................................................................................3
4.2 Spartan Motors Safety and Environmental Policy .......................................................3
4.3 Planning ..............................................................................................................................4
4.3.1 Environmental Aspects ...........................................................................................4
4.3.2 Legal and Other Requirements ..............................................................................5
4.3.3 Objectives and Targets ............................................................................................6
4.4 Implementation & Operation ..........................................................................................6
4.4.1 Structure and Responsibility ..................................................................................6
4.4.2 Training, Awareness and Competence .................................................................7
4.4.3 Communication ........................................................................................................7
4.4.4 Environmental Management System Documentation .......................................8
4.4.5 Document Control ...................................................................................................8
4.4.6 Operational Control .................................................................................................9
4.4.7 Emergency Preparedness and Response ..............................................................9
4.4.8 Incentives ................................................................................................................10
4.5 Checking & Corrective Action .....................................................................................10
4.5.1 Monitoring and Measurement .............................................................................10
4.5.2 Evaluation of Legal and Other Requirements ...................................................10
4.5.3 Non-Conformance and Corrective Action .........................................................11
4.5.4 Records Management ...........................................................................................11
4.5.5 Environmental Management System Audits .....................................................11
4.6 Management Review ......................................................................................................12
TABLES
Table 1 ISO 140001:2004 Cross – Reference ...............................................................................2
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ENVIRONMENTAL MANAGEMENT
SYSTEM MANUAL
1.0 INTRODUCTION
Spartan Motors USA, Inc. (Spartan) is located at 1000 Reynolds Road in Charlotte,
Michigan. In order to improve management of environmental issues related to its
operations and sites, Spartan is implementing an ISO 14001:2004-compliant environmental
management system. This Environmental Management System (EMS) manual presents
the environmental policy, structure of the management system, and related documents.
2.0 CROSS-REFERENCE TABLE
The EMS is designed according to the requirements set forth by the ISO-14001:2004
Standard and consistent with U.S. EPA’s “Compliance-Focused Environmental
Management System – Enforcement Agreement Guidance” (CFEMS) (Revised June 2005).
Sections 4.1 through 4.6 parallel the ISO-14001 Standard number scheme (TABLE 1). Each
of these sections and related documentation provide specific information or instructions
necessary for complying with the requirements in the ISO-14001 Standard and Appendix
B of CFEMS.
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TABLE 1
ISO 14001Cross-References
ISO 14001:2004
Element
Description
Applicable Documents
Spartan Motors USA, Inc.
4.1
General Requirements
EMS-0001
4.2
Environmental Policy
EMS-0001
4.3.1
Environmental Aspects
!
EMS-PD -0001.pd f
4.3.2
Legal and Other
Requirements
EMS-PD -0002.pd f
4.3.3
Objectives, Targets, and
Environmental Programs
EMS-PD -0003.pd f
4.4.1
Resources, Roles,
Responsibilities and
Authority
4.4.2
Competence, Training and
Awareness
4.4.3
Communication
EMS-PD -0006.pd f
4.4.4
Documentation
4.4.5
Document Control
EMS-PD -0007.pd f
4.4.6
Operational Control
EMS-PD -0008.pd f
4.4.7
Emergency preparedness
and response
EMS-PD -0009.pd f
4.5.1
Monitoring and
measurement
EMS-PD -0011.pd f
4.5.2
Evaluation of compliance
EMS-PD -0002.pd f
4.5.3
Nonconformance and
corrective and
preventative actions
EMS-PD -0010.pd f
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4.5.4
Records
EMS-PD -0012.pd f
4.5.5
Environmental
Management system
internal audit
EMS-PD -0013.pd f
4.6
Management Review
EMS-PD -0014.pd f
3.0 DISTRIBUTION, REVISION AND CONTROL
The “Controlled Master Copy” is kept electronically in the Spartan Business System (SBS).
• Environmental Health and Safety will review the EMS manual for changes
annually.
• Environmental Health and Safety will make all requested revisions to the manual
as needed throughout the year.
4.0 ENVIRONMENTAL MANAGEMENT SYSTEM (EMS) REQUIREMENTS
4.1 GENERAL REQUIREMENTS
Spartan will establish and maintain an environmental management system compliant with
the ISO 14001 standard and focused on compliance.
The system will include the designation of responsibility for achieving objectives and
targets at each relevant function and level of organization and means and time frame by
which they are to be achieved. With any projects that relate to new developments or new
or modified activities, products, or services, the system shall be amended where relevant
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to ensure environmental management is applied to such projects.
4.2 SPARTAN MOTORS ENVIRONMENTAL HEALTH AND SAFETY POLICY
Spartan Motors is committed to Environmental, Health & Safety excellence. To this end,
Spartan Motors will:
• Protect people and the environment by working to prevent accidents and pollution.
• Ensure our facilities and processes are compliant with applicable local, state, and
federal regulations (environmental requirements), industry best practices, customer
requirements, and other applicable requirements.
• Promote environmental and safety achievement through its leadership, and
associate involvement across all locations.
• Establish, promote and drive toward specific performance goals to ensure
continuous safety and environmental improvement.
• Provide personnel and resources to maintain a compliance-focused environmental,
health and safety management system.
Spartan will ensure the environmental policy remains appropriate to the nature, scale and
environmental impacts of its activities, products or services, including commitments to
pollution prevention. Spartan will maintain compliance and provide a framework for
setting and reviewing environmental objectives and targets by implementing the
following procedures outlined in this document.
4.3 PLANNING
Spartan will ensure all activities affecting the environment are planned in a manner to
minimize their impact. Legal requirements are taken into consideration when establishing,
implementing and maintaining the EMS.
The following definitions are used during planning:
• Environmental Aspects - Elements of the organization’s activities, products or
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services that can interact with the environment.
• Environmental Impact - Any change to the environment, whether adverse or
beneficial, wholly or partially resulting from an organization’s activities, products
or services.
• Significant Environmental Aspect - An environmental aspect (interaction) that has
or can have a significant environmental impact.
4.3.1 Environmental Aspects
Spartan has identified applicable environmental aspects and related impacts of its
activities and products within the defined scope of the EMS that it can control and
that it can influence taking into account planned or new developments, or new or
modified activities and products in order to determine which can have a significant
impact on the environment. Spartan utilizes a Significant Aspect Planning
Summary Sheet (EHS-FR-0009) and Initial Environmental Review (EHS-FR-0024) to
identify the environmental aspects of its activities, products, and services within the
defined scope of the EMS.
Consistent with 4.5.3, the aspects/impacts assessment carried out pursuant to this
section shall specifically include, but not be limited to, identifying activities,
products, or services where equipment malfunctions and deterioration, operator
errors or deliberate malfeasance are causing, or have the potential to cause: (1)
unplanned or unauthorized releases of hazardous contaminants to the
environment, (2) a threat to human health or the environment, or (3)
noncompliance with legal requirements.
Related Documentation
EMS-FR-0001 Environmental Management Program Form
EMS-PD-0001 Environmental Management System - Aspects and Impacts
EMS-PD-0002 Environmental Management System - Legal and Other Requirements
EMS-PD-0005 Environmental Management System - Training
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EHS-FR-0009 Significant Aspect Planning Summary Sheets
EHS-SR-0003 Environmental Aspects Rating Rationale
4.3.2 Legal and Other Requirements
Spartan is required to comply with a variety of legal and other requirements that
are applicable to the environmental aspects of its activities, products or services.
Spartan ensures these applicable legal and other requirements to which we
subscribe are taken into account in establishing, implementing and maintaining the
EMS.
Related Documentation
EMS-PD-0002 Environmental Management System - Legal and Other Requirements
EMS-SR-0020 Standard/Reference: Regulatory Requirements
REC-PD-0001 SBS Record Retention
REC-SR-0003 Record Retention Matrix
4.3.3 Objectives and Targets
Spartan has established and maintains documented environmental objectives and
targets coherent with the environmental policy. Spartan ensures that objectives and
targets are measurable where practicable and consistent with the environmental
policy including the commitments 1) to prevention of pollution, 2) to compliance
with applicable legal requirements and with other requirements to which the
organization subscribes and 3) to continual improvement.
Related Documentation
EMS-PD-0003 Environmental Management System - Objectives and Targets and
Environmental Management Programs
EHS-FR-0009 Significant Aspect Planning Summary Sheet
EMS-FR-0001 Environmental Management Program Form
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4.4 IMPLEMENTATION & OPERATION
4.4.1 Structure and Responsibility
Spartan has defined, documented and communicated the roles, responsibility and
authority of personnel in order to facilitate an effective EMS. The organizational
chart includes responsibility and authority information. Spartan ensures the
availability of resources essential to establish, implement, maintain and improve
the EMS. Resources include human resources and specialized skills, organizational
infrastructure, technology and financial resources.
Related Documentation
EMS-PD-0004 Environmental Management System - Roles and Responsibilities
4.4.2 Training, Awareness and Competence
Spartan has identified training needs of all employees in relation to the EMS.
Systems are maintained for identification, evaluation, recording and fulfillment of
training needs. Personnel, including contract employees whose work may create a
significant impact upon the environment receive the appropriate training.
Related Documentation
EMS-PD-0005 Environmental Management System - Training Procedure
HRT-PD-0006 Training Systems
HRT-FR-0001 Training Sign-In Sheet
4.4.3 Communication
With regard to its environmental aspects, compliance with legal requirements and
EMS, Spartan has established and maintained procedures for:
a) An ongoing means of internal communication regarding environmental issues
and information among the various levels and functions of the organization, to
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include all organization personnel and those working on its behalf, and a means
for receiving, documenting, and responding relevant communication form
those individuals.
b) Handling internal communications between the various levels and functions of
the organization and external communications with interested parties.
c) As appropriate, implementing and maintaining security measures to prevent
unauthorized disclosure of EMS information (including audits and reviews) and
documentation, which shall include protocols for responding to inquiries and
requests of information.
Related Documentation
EMS-PD-0006 Environmental Management System - Communications
4.4.4 Environmental Management System Documentation
Spartan has developed an EMS documentation system that is organized into a four-
tiered structure. Each of these levels will provide direction to relative documents in
other levels.
• Level 1 - EMS Manual
• Level 2 – EMS Processes
• Level 3 – Business Processes/Operational Instructions
• Level 4 – Forms/Records
This manual is the Level 1 EMS documentation that provides clear linkage to all
elements of the EMS.
Related Documentation
EMS-0001 EMS Manual
4.4.5 Document Control
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Spartan has established a document control system that controls all documents and
data that relate to satisfying the elements of the ISO 14001 standard. Essential
documentation affecting environmental issues is reviewed for adequacy and
approved by authorized personnel before its release. Changes to documents are
reviewed and approved by the same functions that performed the original review.
Related Documentation
EMS-PD-0007 Environmental Management System - Document Control
4.4.6 Operational Control
Spartan identifies and plans those operations that are associated with the identified
significant environmental aspects consistent with our environmental policy,
objectives and targets in order to ensure that they are carried out under appropriate
conditions.
Preventative Maintenance will be used to monitor equipment and provide for
scheduled maintenance activities. Well maintained equipment will help maximize
energy conservation and minimize potential environmental impacts.
Related Documentation
FAC-PD-0001 Preventative Maintenance Process
EMS-PD-0008 Environmental Management System - Operational Control
QUA-OI-0001 through QUA-OI-0781 Operational Instructions
4.4.7 Emergency Preparedness and Response
Spartan has identified the potential for accidents and emergency situations that
could result in environmental impacts. Spartan responds to actual emergency
situations and accidents and prevents or mitigates associated adverse
environmental impacts. Spartan shall periodically review and, where necessary,
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revise its emergency preparedness and response procedures, in particular after the
occurrence of accidents or emergency situation. Spartan shall also periodically test
such procedures where practicable.
Related Documentation
EMS-PD-0009 Environmental Management System - Emergency Response
EHS-PD-0003 Injury Investigation Form Completion
HRT-FR-0001 Training Sign-in Sheet
HRT-PD-0006 Training Systems
DOC-PD-0004 Document and Data Control
4.4.8 Incentives
It is the responsibility of Spartan personnel to maintain environmental compliance,
environmental stewardship and EMS conformance on a day-to-day basis. To that end,
Spartan has implemented a War on Waste (WOW) recognition process where team
problem solving techniques are utilized to identify waste streams and develop waste
reduction or waste elimination solutions.
4.5 CHECKING AND CORRECTIVE ACTION
4.5.1 Monitoring and Measurement
Spartan has established and maintains a system for measuring and monitoring the
key characteristics of our operations that can have a significant impact on the
environment. This system includes recording information to track performance,
relevant operational controls, and conformance with the established objectives and
targets.
Related Documentation
EMS-PD-0011 Environmental Management System - Monitoring and Measuring
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4.5.2 Evaluation of Legal and Other Requirements
Spartan has established a procedure to periodically evaluate how well our
organization complies with legal environmental regulations and other
requirements.
Related Documentation
EMS-PD-0002 Environmental Management System - Legal and Other Requirements
4.5.3 Non-Conformance and Corrective Action
Spartan has established and maintains a procedure for implementing corrective and
preventive actions, which include procedures for the assessment, reporting,
analysis and corrective actions of environmental related problems. To measure
Spartan’s compliance with the EMS, scheduled site inspections will be conducted.
Upon inspection completion, all corrective actions will follow the Corrective and
Preventive Action Procedure. During subsequent site inspections the previous
audit’s corrective and preventive actions will be verified.
Related Documentation
EMS-PD-0010 Environmental Management System - Corrective and Preventive
Action
EHS-FR-0009 Significant Aspects Planning Summary Sheet
EHS-FR-0024
4.5.4 Records Management
Spartan has established procedures for identification, maintenance and disposition
of all environmental records. These records are kept to demonstrate conformance to
Spartan’s EMS, the ISO 14001 standard and applicable regulations.
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Related Documentation
EMS-PD-0012 Environmental Management System - Records
4.5.5 Environmental Management System Audits
Spartan has established and maintains procedures to carry out periodic audits of
the environmental management system. The audit will determine whether the
EMS conforms to planned arrangements for environmental management, including
the requirements of the ISO 14001 standard and CFEMS and has been properly
implemented and maintained.
A compliance audit will be conducted at least annually, by auditor(s) independent
of the facility being audited. Evaluation results are reported to senior management
and nonconformities (i.e., instances of noncompliance) are addressed through the
process developed pursuant to element 4.5.3. Spartan’s annual compliance audit
work plan, including any schedule, shall be based on the legal requirements
applicable to the evaluated facility, and results of previous audits. Spartan will
conduct routine, objective, self-inspections by supervisors and trained staff.
Related Documentation
EMS-PD-0013 Environmental Management System - Audit
EMS-PD-0002 Environmental Management System - Legal and Other Requirements
EMS-PD-0004 Environmental Management System - Roles and Responsibilities
4.6 MANAGEMENT REVIEW
Spartan has established a process for top management to review the EMS. Top
management will review the EMS at planned intervals to ensure continuing suitability,
adequacy and effectiveness. Spartan will conduct a complete management review at least
semi-annually.
Related Documentation
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EMS-PD-0014 Environmental Management System - Management Review
MGT-PD-0001 SBS Management Review