Implementation and Operation

• Resources, Roles, Responsibility and Authority
• Competence, Training and Awareness
• Communication     
• EMS Documentation  
• Control of Documents    
• Operational Control   
• Emergency Preparedness and Response    

Resources, Roles, Responsibility and Authority- Procedure SOM-P-ROL-04

SOM management has defined and documented roles and responsibilities of School of Medicine personnel in order to fulfill the School of Medicine's environmental policy and the whole of the EMS. Defined roles, responsibilities and authorities for:

1. Implementation and sustaining the EMS,

2. Management of environmental programs, 

3. Procedures for control of activities, products, services.  

An Environmental Management Representative has been appointed to oversee EMS Implementation and has been provided the resources necessary to implement and maintain the SOM EMS.  All responsibilities and authorities are listed and are effectively communicated within each relevant level and function of the department in order to maintain the effectiveness of the EMS.

Competence, Training and Awareness —Procedure SOM-P-TR-05

The SOM has identified, provided, and documented training and instruction for SOM personnel and others  working on behalf of SOM in order to:  

1. Comply with environmental regulations
2. Ensure that appropriate personnel understand their  roles and responsibilities for implementation of the  EMS 
3. Ensure practice owners understand specific procedures to control environmental impacts of their activities, products and services
4. Reduce the potential to cause a significant environmental impact

Communication—Procedure SOM-P-COM-06

SOM has established levels of internal and external communication relevant to the EMS, which includes:

1. Methods adopted for communicating within levels and functions of the SOM
2. Effectively communicating with those with authority and responsibility with the JCAHO accreditation
3. Reference to the School of Medicine's policy of external communication 

Documentation

The SOM has established and maintains a written EMS description document that describes

1. The EMS elements, including Environmental Management Procedures (EMPs) to implement the elements;
2. How elements relate to each other and reference of related documents
3. The location where related documents and records are maintained.

SOM has  four levels of EMS documentation:

Level	Description
I	EMS Manual describing conformance with the ISO 14001:2004 EMS,  including the environmental policy and objectives and targets.  The SOM manual also provides description of  GEMS and USC EMS guidance and directives
II	EMS procedures based on the ISO 14001:2004 EMS Criteria to implement the EMS elements  SOM established procedures that relate to various EMS elements, e.g., external communications.
III	Standard Operating Procedures (SOPs) developed by each SOM unit - these  SOPs  are based on the EMS responsibility of each SOM department.
IV	Forms for EMS reports, lists and requirements

Control of Documents—Procedure SOM-P-DOC-07

Document control within the SOM EMS will be integrated with existing document control procedures.  Establishment of EMS documentation will be reviewed, approved, and distributed in a manner that ensures effective communication of tasks and responsibilities of all SOM personnel.   Revision of procedures, work instructions, forms will be conducted in accordance with SOM document control procedures to ensure: 

1. All internal documentation related to the functioning of the EMS has been identified, including external documentation.
2. Documentation is periodically reviewed and revised, and approved for adequacy of use
3. Current versions of relevant documents are available when needed
4. Obsolete documents are removed from all points of issue, and 
5. Any obsolete documents that are retained for legal and/or knowledge preservation purposes are suitably identified. 

Operational Control—Procedure SOM-P-OPC-08

SOM has identified those operations and activities that are associated with the identified significant environmental aspects in line with its policy, objectives and targets.
SOM has planned has planned these activities, including maintenance, in order to ensure that they are carried out under specified conditions by which will increase control over operations to minimize risk through:

1. establishing and maintaining documented procedures to cover situations where their absence could lead to deviations from the environmental policy and the objectives and targets;
2. stipulating operating criteria in the procedures;
3. establishing and maintaining procedures related to the identifiable significant environmental aspects of goods and services used by the organization and communicating relevant procedures and requirements to suppliers and contractors.

Emergency Preparedness and Response—Procedure SOM-P-ERP-09

1. The SOM has established and implemented documented procedures and methods, in accordance with the USC EH&S Department and the Dorn VA Hospital Emergency Preparedness procedures, to identify potential for emergencies and responses and migrating environmental impacts that might result.

2. The SOM, through the USC EH&S Department reviews and revises its emergency preparedness and response procedures when new practices are initiated and after the occurrence of accidents of emergencies.

3. Procedures are communicated to SOM personnel to ensure they are aware of the scope and detail of their responsibilities in the event of an accident or emergency.