1. Make the decision, commit to implement and make a senior person responsible for the system.
This person will report directly to the CEO on the progress and needs of the EMS implementation. This person must be an advocate of the EMS.

2. Form an Implementation Team and review need for an EMS advisor/consultant.
Select up to eight employees from a cross section of grades and functions. In virtually all organizations, this is too big a project for one person. Implementing an EMS will affect all departments and levels of employees. Having a good representation of departments and employees on this team will help ensure the decisions made are appropriate and will help with achieving buy-in across the organization.

3. Conduct an assessment (gap analysis) and report to senior management.
The report will identify the adequacy of current procedures and the need for new procedures.

4. Conduct a thorough inventory of the organization's environmental aspects and impacts. Determine which are significant.
The inventory of aspects and impacts will be one of the most important, and most difficult tasks to perform. This inventory will become the foundation for other critical activities.

5. Create an Environmental Policy, Set Objectives and Targets, and create an Action Plan.
Communicate the policy across the organization, develop agreed-upon objectives and targets and the plan for achieving the objectives and targets.

6. Develop leaders to create and sustain employee awareness.
All leaders and the implementation team must learn about the system so that they understand well enough to explain to others.

7. Define organizational structure and responsibilities.
Define and document how the responsibilities of the EMS will be met. Keep this list or matrix up to date with job titles as a formal document.

8. Involve all employees as appropriate, in developing and improving their system.
By training and awareness sessions, flowcharting of processes, team reviews of procedures and flowcharts.

9. Decide on the procedure for documentation structure.
Use this from day one of developing EMS documentation.

10. Flowchart key processes showing all interfaces.
Start with core processes and then tie in the support processes.

11. Create all forms in line with agreed coding procedure.
Every form should belong to a process, remove redundant forms.

12. Correlate all forms to flowcharts.
Every form should have a place, if not, check completeness of flowchart.

13. Review flowcharts for accuracy.
By "accuracy" we mean what actually happens!

14. Develop and use flowcharts as documented procedures.
Ensure process objective(s) also address environmental aspects.

15. Review, reconcile, approve and issue as-is procedures.
Involve everyone and do not ignore comments. Process owners should approve procedures.

16. Prepare new procedures and train staff to implement them.
These may include: EMS auditing and dealing with emergencies.

17. Issue new procedures and the environmental management program.
This will be the first program implemented by the EMS.

18. Describe the whole system in an EMS manual.
Keep it slim and simple for customers, every employee and suppliers.

19. Launch the system and respond quickly to revision requests.
Throw a well-deserved party! Invite continuous improvement.

20. Start auditing to continually improve your integrated system.
Your trained audit team will come from action 15. Cover suppliers too.

21. Conduct pre-assessment at least four months before first Registrar audit.
Use a registered systems auditor and ensure all corrective actions are up to date. Expect at least some non-conformances from this pre-assessment that will take time to correct prior to the Registrar audit.