An official website of the United States government.

This is not the current EPA website. To navigate to the current EPA website, please go to This website is historical material reflecting the EPA website as it existed on January 19, 2021. This website is no longer updated and links to external websites and some internal pages may not work. More information »

Guide to Developing an Environmental Management System - Plan


Building an Environmental Management System (EMS) might sound like an overwhelming task for a smaller organization, but it need not be. Taken in steps, it is a job that small and medium-sized organizations can tackle. These pages will take you through basic steps as they are outlined in the 2001 Second Edition of Environmental Management Systems: An Implementation Guide for Small and Medium-Sized Organizations. This page pulls out particular steps from the "Plan" section of the Guide, and points back to specific pages in the guide to fill out worksheets and get additional materials.

Plan: Planning, including identifying environmental aspects and establishing goals

EMS Cycle of continuous improvement - PLAN step

Time and resources are limited in any organization, so it is important to use resources wisely. The information below illustrates 10 steps in the EMS planning process. Take the time to figure out what needs to be done, how to do it, and who must be involved.

Step 1: Define Organization's Goals for EMS

The first step in EMS planning is to decide why you are pursuing the development of an EMS. Are you trying to improve your environmental performance (e.g., compliance with regulations or prevent pollution)? Write your goals down and refer back to them frequently as you move forward. As you design and implement the EMS, ask the following questions: How is this task going to help us achieve our goals? How should we define the project scope? (i.e., What is the "organization" that the EMS will cover? One location or multiple locations? Should we "pilot" the EMS at one location then implement the system at other locations later?)

Step 2: Secure Top Management Commitment

One of the most critical steps in the planning process is gaining top management's commitment to support EMS development and implementation. Management must first understand the benefits of an EMS and what it will take to put an EMS in place. To develop this understanding, explain the strengths and limitations of your current approach and how those limitations can affect the organization's financial and environmental performances. Management also has a role in ensuring that the goals for the EMS are clear and consistent with other organizational goals. Management's commitment should be communicated across the organization.

Step 3: Select An EMS Champion

Not all small or medium-sized organizations have the luxury of choosing among multiple candidates, but your choice of project champion is critical. The champion should have the necessary authority, an understanding of the organization, and project management skills. The champion should be a "systems thinker" (ISO 9000 or ISO 14001 experience can be a plus, but is not necessary), should have the time to commit to the EMS-building process, and must have top management support.

Step 4: Build An Implementation Team

A team with representatives from key management functions (such as engineering, finance, human resources, production and/or service) can identify and assess issues, opportunities, and existing processes. Include contractors, suppliers or other external parties as part of the project team, where appropriate. The team will need to meet regularly, especially in the early stages of the project. A cross-functional team can help to ensure that procedures are practical and effective, and can build commitment to, and "ownership" of, the EMS.

Step 5: Hold Kick-Off Meeting

Once the team has been selected, hold a kick-off meeting to discuss the organization's objectives in implementing an EMS, the initial steps that need to be taken and the roles of team members. If possible, get top management to describe its commitment to the EMS at this meeting. The kick-off meeting is also a good opportunity to provide some EMS training for team members. Follow-up this meeting with a communication to all employees.

Top of Page

Step 6: Conduct Preliminary Review

The next step is for the team to conduct a preliminary review of your current compliance and other environmental programs/systems, and to compare these against the criteria for your EMS (such as ISO 14001:2015). Evaluate your organization's structure, procedures, policies, environmental impacts, training programs and other factors. Consider utilizing an ISO 14001 self-assessment tool or incorporating Safer Choice for gap analysis tools.

Step 7: Prepare Budget and Schedule

Based on the results of the preliminary review, prepare a project plan and budget. The plan should describe in detail what key actions are needed, who will be responsible, what resources are needed, and when the work will be completed. Keep the plan flexible, but set some stretch goals. Think about how you will maintain project focus and momentum over time. Look for potential "early successes" that can help to build momentum and reinforce the benefits of the EMS.

Step 8: Secure Resources, Assistance

The plan and budget should be reviewed and approved by top management. In some cases, there may be outside funding or other types of assistance that you can use (from a trade association, a state technical assistance office, etc.). See Appendix F of the Environmental Management Systems: An Implementation Guide for Small and Medium Sized Organizations for more ideas on possible sources of help.

Step 9: Involve Employees

Ownership of the EMS will be greatly enhanced by meaningful employee involvement in the EMS development process. Employees are a great source of knowledge on environmental, and health and safety issues related to their work areas as well as on the effectiveness of current processes and procedures. These employees can help the project team in drafting procedures.

Step 10: Monitor and Communicate Progress

As you build the EMS, be sure to regularly monitor your progress against the goals and project plan, and communicate this progress within the organization. Be sure to communicate the accomplishments that have been made and describe what happens next. Build on small successes. Be sure to keep top management informed and engaged, especially if additional resources might be required.

Before beginning the "Do" section, review the key elements of an EMS with worksheets and examples. See pages 15-77 of Environmental Management Systems: An Implementation Guide for Small and Medium Sized Organizations.

Top of Page