Environmental Management Systems in Unlikely Places: Notes from Yellowstone National Park

Joni Teter

The literature about environmental management systems tends to be dominated by discussions of ISO 14001 and the needs of larger manufacturing companies with international aspirations. When reading these discussions I find it easy to get lost in the procedural details of certification. However, environmental management is not really all that complicated, and certification need not be the goal. For many organizations, environmental management is simply about applying good business practices to environmental problems, focusing on the areas that are most important to that organization’s needs. This article will discuss how environmental management is being used in Yellowstone National Park to internalize "greening" into every aspect of the park’s day-to day operations.

"Greening" Yellowstone

Yellowstone National Park encompasses a mostly-wilderness area of just under 3500 square miles. There are eight "developed areas" within the park, containing concessioner-operated visitor services (lodging, campgrounds, restaurants, stores and activity rental services) and National Park Service ("NPS") operation centers (vehicular and facility maintenance centers, ranger stations, visitor education centers, employee housing and park administration). More than 3 million people now visit the park each year, making Yellowstone’s operations much like a medium-sized municipality surrounded by wilderness.

A poodle-at-large reportedly launched Yellowstone’s greening program. The poodle encountered a large puddle of uncontained motor oil; after the inevitable follow-up visit from an EPA enforcement inspector, Yellowstone’s management made a serious commitment to improve Yellowstone’s environmental operations. Post-poodle, Yellowstone has pursued a dual strategy for hazardous waste management. Wherever possible, hazardous wastes have been eliminated; systematic controls have been imposed on remaining hazardous waste streams to assure compliance with applicable regulations. The park’s maintenance division reports reducing hazardous waste streams up to 90% since the early 1990s. Much of this reduction is attributable to the park’s strong "P² products" program: NPS management has aggressively sought out less toxic alternatives to hazmat and petroleum-based products, and has changed some operational practices as well. Today, environmentally preferable products/processes are being used in the following categories: paints and coatings, antifreeze and motor oils, solvents, cleaning product, herbicides/pesticides, and biosynthetic oils.

The Code of Environmental Management Principles

EPA and other federal agencies have developed guidance on how environmental management principles should apply to the federal family. (Implementation Guide for the Code of Environmental Management Principles for Federal Agencies, EPA 402-R-96-017, November, 1996, accessible on EPA’s webpage at http://es.epa.gov/oeca/fedfac/complian/exguide.) The Code of Environmental Management Principles ("CEMP") is a collection of five broad principles aimed at achieving environmental excellence. In creating this guidance, participating agencies agreed that adherence to the five principles and their underlying performance objectives will help ensure federal environmental performance that is proactive, flexible, cost-effective, integrated and sustainable.

The five CEMP principles are consistent with private sector environmental management systems: management commitment; compliance assurance and pollution prevention; enabling systems; performance and accountability; and measurement and improvement. As part of its "compliance assistance" program, EPA will perform environmental management reviews ("EMRs") for sister agencies using the CEMP principles.

Environmental Management Review in Yellowstone: P² Products

Yellowstone has invested a tremendous amount of time and energy in converting to less hazardous products. A major concern for park management is how to ensure that these "P²" products/processes remain in use, avoiding the tendency for conventional, more hazardous products to creep back into the park. Yellowstone believed that an EMR could help to address this concern, and asked EPA for help.

The traditional approach to "material control" is to centralize purchasing and distribution of products (both hazardous and "green"), distributing them from central supply on a prescription-like basis. This approach is usually referred to as the "pharmacy" system, and is strongly recommended in most EMS approaches. In the federal context, material control originated with the Navy and Air Force, where centralized supply is a fact of life. The hazmat pharmacy system has been extremely effective in these organizations because it dovetails nicely with the existing culture and fits into organizational structures and operating procedures that are already in place.

However, the "NPS" does not operate like a military organization. Distances between the developed areas are great (averaging about 50 miles), and usage conditions among the developed areas can vary considerably. As a result, Yellowstone has a fairly liberal purchasing policy: managers in the interior areas frequently purchase supplies independent of central supply, and a large number of staff are authorized to use NPS credit cards for work-related purchases. Because of this liberal purchasing policy, the "pharmacy approach" is unlikely to succeed in Yellowstone.

Although the park could consider changing its purchasing procedures, a change to the "pharmacy" approach would run counter to the organizational culture (in addition to creating major delays in obtaining necessary products). Yellowstone’s "greening" success is tied to champions who exhibit a high degree of personal initiative in carrying out their jobs. The use of champions appears to be typical of all Yellowstone operations – personal initiative is both expected and rewarded within the park’s culture. As auditors, EPA staff recommended that the park find ways to capitalize on this ethic of personal initiative, rather than creating a standardized procedure that would get in the way of people trying to get work done.

Yellowstone employees perceive protection of "the resource" to be an important part of their jobs. A good deal of employees’ motivation to do a good job comes from this personal ethic. However, many employees did not perceive that "resource protection" also includes good management of hazardous materials (as well as reduction of solid and hazardous waste, and reducing impacts from transportation and facilities). When employees connected hazmat management to their own jobs and use of P² products became a part of their personal value system – they were more likely to bring in ideas for new P² products than slip back to conventional, more hazardous formulations. An important, ongoing task for Yellowstone’s management will be to maintain awareness that individuals can help to "protect the resource" by paying attention to impacts caused by their own actions.

NPS staff take much pride in their work, and the products/procedures at issue in P² decisions are staff’s "tools of the trade." Yellowstone has very high standards for maintenance coupled with some very tough performance challenges: high volumes of use (4,000-6,00 visitors per day in some locations), old facilities; unique water quality characteristics (high mineralization, high sodium content, etc.), extremely cold winter temperatures, and wide temperature extremes. In some instances, environmentally preferable products will not achieve the same level of performance as more impactful products. However, that extra increment of performance comes at a cost: health and environmental impacts, management and disposal costs and increased liability to the park. Trade-offs are inevitable. We recommended that Yellowstone’s management be mindful of these tradeoffs, make clear decisions about performance standards/environmental impacts, and explain the "why" behind decisions when communicating to staff.

Communication and training are critical to the park’s success in controlling employee use of hazardous materials. If staff fully understand the benefits achieved – and if the product performs adequately – staff can be relied upon to use an environmentally preferable product over conventional formulations. Future product decisions should provide opportunities for staff to "buy in" to product conversion by establishing clear criteria for environmentally preferable products and communicating theses criteria to employees and vendors; central supply can be used as an educational resource, steering staff to "green" replacement products.

Conclusion

Environmental management need not be a "one-size-fits-all" undertaking. Certification to an approved standard is helpful in some circumstances (especially for companies involved in international trade) but can be daunting and even represent overkill for smaller and locally based organizations. To some extent, environmental management systems can be treated like a cafeteria plan: an organization can choose certain tools from the EMS toolbox in order to address priority needs, or even create its own timing/sequence to personalize the organization’s evolution towards environmental excellence. For many organizations, the critical questions relate to risk and profit: Where are we most at risk from the environmental impacts we create? Where are our biggest opportunities to make improvements that will deliver dollars to the bottom line? The tools of environmental management systems can help managers explore these questions and develop answers customized to their own organizations.

Joni Teter is an enforcement attorney with the U.S. Environmental Protection Agency’s Denver office (Region 8). Region 8 staff, including Ms. Teter, performed an EMR review at Yellowstone National Park during Summer 1999.