Implementing the EFEC program is a continual process. The general process is as follows (a more detailed flow chart is provided in Appendix C):

The process of implementing EFEC begins at the top. Management must be willing to begin the process. The EFEC program requires the acceptance and support of top management (Corporate Officer, President, and Board of Directors, etc.). Management must understand what it will take to put EFEC in place.  Management commitment and vision to making the environment an organizational priority and incorporating environmental management into daily operations and activities should be clear and communicated across the organization to build and sustain an effective EFEC program. 

Initially, management must understand that the facility will have to put forward some effort.  Management will have to allocate resources to begin the process.  Initial steps include identifying the EFEC Program Manager to begin the process. Later, management will formerly adopt the environmental policy and support the actions put into place by the EFEC team.  Management will also take part in the annual EFEC program review to ensure the program is operating properly and given the appropriate level of attention.

An EFEC Program Manager must be chosen to effectively implement the program.  The choice of a project champion is critical.  The champion must be given the necessary authority and understand the organization and its environmental status.  The primary responsibility of the EFEC Program Manager is assembling and leading the EFEC Team.  Potential choices are the environmental manager, plant engineer, or the person responsible for environmental issues at the plant or company.  

The AHFA will offer a Program Manager course and certification.  It is not required by EFEC to have a certified Program Manager, but it is strongly recommended.  Contact the AHFA for additional information on Program Manager certification.

The EFEC team will be responsible for the EFEC program.  The team tasks include: developing, implementing and monitoring the EFEC program; budgeting and scheduling for EFEC program implementation; ensuring employees are trained; and reporting to top management.

The EFEC team should include representation from key company functions (i.e., production, finishing, woodworking, boilers, plant engineering, warehouse, finance, human resources, marketing, purchasing, etc.).  Employees often have knowledge and insight on environmental issues related to their areas.  External parties such as contractors and suppliers may also be helpful.  Typical representation in the cross-functional team may include:

Project team members must be committed to implementing the EFEC program and willing to undertake responsibilities.  The project team should meet frequently (i.e. at least once a month), especially in the early stages of EFEC development.  The team should focus on addressing facility-wide environmental issues and identifying areas of improvement, paying particular attention to problem situations that may require attention.  After performing a preliminary review of the existing program, the team must then develop a system that meets the EFEC requirements. The EFEC team will define, document, and communicate EFEC roles, responsibilities, and authorities throughout the organization. 

The EFEC team should prepare a budget and schedule for implementation of the program.  The budget will need to support the team, gap analysis and implementation.  Some of the costs include staff time, training, materials, equipment, and possibly outside consulting assistance.  However, staff time will be the majority of the expense.  A realistic implementation schedule should be established and communicated throughout the organization.

As with any project, key questions include what will it cost and how long will it take.  As stated earlier, the primary cost will be the effort put forth by the EFEC Program Manager and EFEC Team.  An estimate of the man-hours to develop and implement EFEC are contained in Appendix C.

The implementation rate will be based on the level of effort given to the program.  The program is designed to be developed and implemented using existing plant personnel.  No new dedicated staff are envisioned.  In addition, no or very little capital expenditures are expected from the program.  The estimated design and implementation time is 6-12 months.  An approximate schedule is provided in Appendix C.

The next step in developing your EFEC program is to perform a preliminary review of current environmental practices and programs, also known as a gap analysis. The purpose of this review is to identify gaps between your current environmental program and EFEC. This review should be a comprehensive evaluation of your organization’s current environmental program (i.e., policies, procedures, training programs, etc.).  Your current environmental program should be compared to the eleven EFEC requirements.  Most likely, your organization will have many of these elements in place, though some existing components may need improvement or will have to be created.  This review will consist of reviewing appropriate procedures and documents. The results of the review should be summarized in a short memo.  Appendix C contains guidance on how to conduct the gap analysis.

The gap analysis should also serve as a roadmap or implementation plan for developing your EFEC program.  Areas where you meet EFEC requirements do not need immediate attention, but deficiencies can be prioritized.  The EFEC team can then focus their attention on these specific areas. The EFEC team can prepare an implementation plan to fulfill the EFEC requirements (as described in Section 3). This plan should describe in detail the key actions required, the responsible person or party for each action, and a schedule.  The implementation plan must be consistent with management’s expectations and must be linked directly to your environmental policy.

Implementation of the EFEC program will require the development or refinement of facility procedures to meet EFEC requirements. This may involve modifying or updating existing environmental procedures and documents or creating new ones.  The EFEC team will be responsible for conducting or overseeing this process. The EFEC team and other employees are an excellent source of input. Employees often have knowledge and insight on environmental impacts and issues related to their areas.  Furthermore, by incorporating employees in EFEC development, a sense of employee ownership of the policies and procedures is formed, creating commitment to the program.

When developing the EFEC program, the system must be designed to be flexible so that it may reflect the realities of your organization.  Though periodic assessments and updates will be required, flexibility will prevent frequent updates to accommodate every change that occurs at your facility.

A manual must be developed that details your facility's EFEC program. The manual must include the documentation required to meet EFEC requirements listed in Section 3. The manual can either contain the necessary information or reference the user as to where to find the appropriate information.  This manual must be a living document, rather than a document that is put on a shelf and forgotten.  The EFEC manual must be updated when there are process changes or changes to your EFEC program.  In addition, backup documentation (training records, inspections, etc.) should be kept with the document. An example EFEC manual is included in Appendix E.

After your EFEC program is up and running within your organization, its performance must be assessed annually at a minimum so that changes can be made to provide better performance for your organization.  This assessment is best accomplished through periodic EFEC self-assessments and ongoing monitoring and measuring.  Example issues to consider during the self-assessment include:

Another aspect of assessing your program is a meeting with top management.  The EFEC team should have a meeting with top management (the individual or individuals that adopted the environmental policy) to discuss the progress of the program, success stories and breakdowns in the process.

Periodic environmental compliance audits can also improve environmental performance by identifying potential problems and compliance issues.  A list of regulations is provided in Appendix C.  Example EFEC auditing methods and protocols are also provided in Appendix C.  

Annual maintenance audits are required to maintain EFEC registration.  These audits are less detailed than EFEC registration audits, which are required every 3 years.  More information on registration requirements can be found in Section 5.

    Annual Assessment Process