Wednesday, December 16, 2009

Environmental Aspects (ISO 14001:2004, §4.3.1)

The requirement of §4.3.1 of ISO 14001 is to establish and maintain procedures 1) for identifying theenvironmental aspects of the organization’s activities, products, and services that it can control and those that it can influence and 2) for determining which of those aspects have or can have a significant impact on the environment. Understanding the requirement of this element of ISO 14001 is central to understanding the concept of an environmental management system.

A single manufacturing facility has potentially hundreds of environmental aspects. How far must it go in identifying its environmental aspects to satisfy the terms of the requirement? ISO 14001 specifies that the organization is to identify those aspects that it can control and those that it can influence and that it must also take into account planned or new developments and new or modified activities, products, and services. These stipulations in the requirements, without actually drawing boundaries on how far the organization must go in identifyingenvironmental aspects, at least establish some categories of aspect that must be considered. Beyond this principle, each organization must identify its aspects comprehensively enough so as to not fail to identify a significant aspect or a legal requirement. An objection to comprehensive identification of aspects is that the organization may become so immersed in aspects identification that it loses sight of the end objective of the procedure, which is to determine significance.

“Significant impact” is not a stand-alone term in §4.3.1. It is accompanied by the phrase “impact on the environment” and “environment” is a defined term. Significant aspects, then, are those environmental aspects that have or can have significant impacts on air, water, land, natural resources, flora, fauna, and humans. The organization determines, using its own criteria, what magnitude of impact on these seven environmental receptors constitutes a significant impact. Whether an aspect is regulated is not intended to be a factor in determining significance.

Proper execution of the environmental aspects procedure is important, in part, because it lifts environmental management out of the regulatory compliance mode and into the mode ofsystematically consequences for the environment, irrespective of regulation. The organization that rigorously applies the environmental aspects procedure discovers many opportunities to improve environmental performance that regulation does not address, including:· Use of energy

· Consumption of materials

· Environmental impacts of employee activities

· Environmental impacts of products and by-products post-manufacture, including distribution, use, reuse, and disposal

· Environmental impacts of services

· Unregulated waste streams such as carbon dioxide

INTEGRATING THE NATURAL STEP ELEMENTS INTO ENVIRONMENTAL MANAGEMENT SYSTEMS

In 1988, Dr. Karl-Henrik Robert began the process of developing the principles and objectives that have become known as The Natural Step.

Robert convened a group of over 100 Swedish scientists and asked them to develop a vision for a sustainable society based on the scientific principles. The Natural Step framework (Robert, 1991) was the result of this effort and is becoming widely recognized.

In this framework, there are four underlying principles or conditions and four guiding objectives.

These system conditions are:

Nature should not be subject to systematically increasing concentrations of substances extracted from the Earth’s crust;

Nature should not be subject to increasing concentrations of substances produced by society;

Nature should not be subject to systematically increasing degradation by physical means; and

People should not be subject to conditions that systematically undermine their capacity to meet their needs.

These conditions can be converted to four objectives that are more easily understood:

Eliminate our community’s contribution to fossil fuel dependency and to the wasteful use of scarce metals and minerals;

Eliminate our community’s contribution to dependency upon persistent chemicals and the wasteful use of synthetic substances;

Eliminate our community’s contribution to encroachment upon nature; and Meet human needs fairly and efficiently.

To apply The Natural Step, Boisvert et al. (1999) recommend an A-B-C-D approach: Awareness, Baseline Analysis, Compelling Vision, and Down to Action. Kent County chose to align its program with The Natural Step because of its simplicity and scientific basis.

An environmental management system (EMS) is a set of processes and practices that enable an organization to reduce the environmental impacts from its operations and increase efficiency. It helps the organization to systematically manage its environmental “footprint.” Alternatively, according to the ISO definition (ISO, 2004) an EMS is “a part of an organization’s management system used to develop and implement its environmental policy and manage its environmental aspects.” It is built upon the concept of continuous improvement and follows a four element Plan-Do-Check-Act cycle. The EMS is an evolving process and is consistently modified to accommodate new information, changing circumstances and changes in organization priorities.

The critical components of each of the four elements are:

Planning, includes identifying environmental aspects and establishing goals [Plan];

Implementing, includes training and operational controls [Do];

Checking, includes monitoring and corrective action [Check]; and

Reviewing, includes progress reviews and acting to make needed changes to the EMS [Act].

There are a variety of reasons that an organization may develop and implement an EMS. The reasons are many and varied and often depend upon the type of organization. A business with international offices has different reasons than a public agency to develop and implement an EMS. Table 1 provides a list of the most common of these reasons.

Some disadvantages to developing and implementing an EMS relate to the costs associated with development of the program and include:

An investment of internal resources, including staff/employee time;

Costs for training of personnel;

Costs associated with hiring consulting assistance, if needed; and

Costs for technical resources to analyze environmental impacts and improvement options, if needed.

Critical factors that assure the success of any management system include:

Commitment from senior management;

Designated staff including a Core team to act as a cheerleader and a representative trained in the program;

Involvement of all employees in the covered fenceline;

Dedicated resources;

A link to the overall strategic planning of the organization;

Sufficient time to develop and implement the program;

Proper follow through on the checking and acting components; and

A willingness to make the cultural shift required for the program to succeed.

The ISO 14001 guidance lists 17 elements, shown in Table 2, as the foundation of an EMS.

Several documents and publications cover the various elements of an EMS in detail. One of these is the US EPA publication “Achieving Environmental Excellence: An Environmental Management Systems (EMS) Handbook for Wastewater Utilities,”

ISO 14001 Standards Audit

ISO 14001:2004 emphasizes the continuous improvement of an environmental management system (EMS). The standard specifies requirements for an environmental management system to enable an organization to develop and implement a policy and objectives which take into account legal requirements and information about significant environmental aspects. The certification process ensures the conformance of your EMS against the international standard, as well as any organizational specific requirements that have been identified.
The ISO 14001 Standards audit consist of 2 stage registration audit process followed by surveillanceaudits, and ultimately a recertification audit. ISO 14001 Audits include on-site assessments of documents, data, records, activity and personnel. Process audit trails are followed by interviews of personnel responsible for the tasks and reviewing associated activity and records of occurrence. The audit trail will follow interactions between processes as well as the details of the process itself. Following are the stages of the audit process.

Pre-assessmentRegistration Audit – Stage 2Audit Findings• A review of action taken on nonconformities identified during the previous auditA review of the continued effectiveness of the management system in its entiretyThe continued applicability to the scope of registration

The pre-assessment audit is an optional activity, outside of the registration process, it is highly encourages that any organization to undertake to evaluate the readiness to undergo the two stage registration process. That would optimally occur prior to the stage 1 and 2 audits.

Unlike the Stage 1 and Stage 2 activities you have full discretion as to which areas the preassessment should focus on and for the length of the pre-assessment. This activity allows your organization to become familiar with the audit process and helps prepare your employees for the registration assessment.

The auditor conducting the pre-assessment will typically return to the organization for the assessment. Similar to a ‘true’ audit, the end result of the pre-assessment will be a documented report identifying findings observed during the audit and a closing meeting to discuss the issues.

The pre-assessment activity allows you to correct any issues prior to beginning the registration process.

Assessment

New requirements for certification bodies have changed the registration process. Registration is now conducted in two distinct visits- Stage One and Stage Two- each of which has defined requirements that are outlined below.

Registration Audit – Stage 1

The stage 1 audit, conducted at your facility, is primarily performed for planning and determining the readiness of an organization to undergo a stage 2 registration audit. It also facilitates communicating any needs and expectations to the organization. Activities performed at a stage 1 audit include:

• Conducting a documentation review – This review determines if the organization’s EMS documentation adequately covers all the requirements of the ISO standard

• A review of the aspects and impacts and their significance and an evaluation of the facility(s) site specific conditions

• A review of your organizations non-conformance, preventive and corrective action system • An overview of applicable regulations

• Interviewing your organization’s personnel to assess their general readiness to undertake a stage 2 audit

• Confirming the applicability of the scope of the organization’s EMS

• Obtaining evidence that internal audits and management reviews are being planned and performed

• Providing focus for the planning of the stage 2 audit

If during the stage 1 audit any nonconformities are identified, the auditor will request a corrective action response (see Corrective Action Response).
The objective of the Stage 2 on-site audit is to assess your organizations’ adherence to your own policies, objectives, and procedures and to ascertain conformance to the requirements of the ISO 14001 standard. To accomplish this, the audit will address the implementation of all the elements of the standard. Review of documentation and records to support the implementation is an expected part of the assessment process. If non-conformances or opportunities for improvement are identified they will be documented in a report which will be presented to the organization during the closing meeting. The report will include the auditor’s recommendation regarding registration.
Any deviation from procedures or requirements of the standard will be identified as an audit finding, which will be documented in the audit report. The auditor will draw your attention to non-conformities as they arise so there will be no “surprises” at the closing meeting. Findings are categorized into three categories defined as follows:

• A major non-conformity relates to the absence or total breakdown of a required process or a number of minor non-conformities listed against similar areas. A major non-conformity at the Registration Audit – Stage 2 would defer recommendation for registration until that major has been closed.

• A minor non-conformity is an observed lapse in your systems ability to meet the requirements of the standard or your internal systems, while the overall process remains in tact.

• An observation or opportunity for improvement relates to a matter about which the Auditor is concerned but which cannot be clearly stated as a non-conformity. Observations also indicate trends which may result in a future non-conformity.

Corrective Action Response

ISO 14001 Standards requires corrective action responses from all Registration Audits. Once certification is achieved, dependant upon the extent and nature of the findings, your organization may be required to submit a corrective action plan, detailing your intent to correct the non conformity.

The auditor may also recommend that your organization submit objective evidence to support the to verify closure may be required.

It is recommended that all non-conformities are addressed within your internal corrective action system. Typically, opportunities for improvement would be addressed as preventive actions by your organization.
closure of the finding. In certain circumstances such as a major non conformity an on site activity
Surveillance Audits
Company shall conduct Surveillance Audits on an annual or semi-annual basis. The purpose of the Surveillance Audit is to ensure that the EMS continues to conform to both the organizations’ and the ISO 14001 requirements. Certain processes will be reviewed at each surveillance including:
• Internal audits and management review

• Customer and interested parties communications

• Effectiveness of the management system in achieving defined objectives

• The progress of planned continual improvement activities

• Continuing operational control

• A review of any changes made by the organization which may have impact on the registration

• Use of accreditation and certification body logos provided to the organization upon registration

• objectives, targets and programs

• evaluation of compliance

Re-assessment Audits

The accreditation body requires that a recertification audit be carried out every three years. The purpose of the recertification audit is to confirm the continued conformity and effectiveness of the management system as a whole, and its continued relevance and applicability for the scope of activity.

Recertification audits review the performance of the EMS over the registration period, and include a review of previous surveillance audit records. The recertification audit includes the following:

The continued relevancy of the organization’s policy and objectives

The continued effective interaction between the processes of the management system

A review of internal audits, management reviews, document changes during this certification period

ISO 14001 Standards – Emergency Preparedness and Response Plans

ISO 14001 Section 4.4.7, Emergency Preparedness and Response, requires that organizations establish and maintain procedure(s) to:
1. Identify potential accidents and emergencies
2. Respond to accidents and emergencies
3. Prevent and mitigate the environmental impacts that may be associated with accidents and emergencies.
Section 4.4.7 also requires that organizations review and revise, when necessary, their emergency preparedness
and response procedure(s), especially after an accident or emergency situation. Organizations must also periodically test such procedures where practicable.
Most organizations have already developed and implemented emergency response plans to comply with various federal and state regulations that require such plans. Examples of federal regulations that require such plans include:
• Resource Conservation and Recovery Act (RCRA) Contingency Plans
• Spill Prevention, Control, and Countermeasures (SPCC) Plans
• Facility Oil Response Plans under the Oil Pollution Prevention Act of 1990
• Employee Emergency and Fire Prevention Plans under Occupational Safety and Health Administration (OSHA).
Some states have regulations that require similar emergency response plans. For instance, the state of Pennsylvania requires certain facilities to develop and implement a Preparedness, Prevention, and Contingency (PPC) Plan in addition to federal requirements.
The ISO 14001 requirements are similar to the requirements of most regulatory emergency plans. Whether your facility has emergency response plans or not, you should review the following sections to ensure you meet the ISO 14001 emergency response requirements.
ISO 14001 Section 4.4.7, Emergency Preparedness and Response, requires that organizations establish and maintain procedure(s) to:
1. Identify potential accidents and emergencies
2. Respond to accidents and emergencies
3. Prevent and mitigate the environmental impacts that may be associated with accidents and emergencies.
Section 4.4.7 also requires that organizations review and revise, when necessary, their emergency preparedness
and response procedure(s), especially after an accident or emergency situation. Organizations must also periodically test such procedures where practicable.
Most organizations have already developed and implemented emergency response plans to comply with various federal and state regulations that require such plans. Examples of federal regulations that require such plans include:
• Resource Conservation and Recovery Act (RCRA) Contingency Plans
• Spill Prevention, Control, and Countermeasures (SPCC) Plans
• Facility Oil Response Plans under the Oil Pollution Prevention Act of 1990
• Employee Emergency and Fire Prevention Plans under Occupational Safety and Health Administration (OSHA).
Some states have regulations that require similar emergency response plans. For instance, the state of Pennsylvania requires certain facilities to develop and implement a Preparedness, Prevention, and Contingency (PPC) Plan in addition to federal requirements.
The ISO 14001 requirements are similar to the requirements of most regulatory emergency plans. Whether your facility has emergency response plans or not, you should review the following sections to ensure you meet the ISO 14001 emergency response requirements.

ISO 14001 Standards – Nonconformance, Corrective and Preventive Action


ISO 14001 Standards - Nonconformance, Corrective and Preventive Action

ISO 14001:2004 Section 4.5.2, Nonconformance And Corrective Andrequires that organizations establish and maintain procedures that:

Preventive Action,

• Define responsibility and authority for handling and investigating nonconformance

• Take action to mitigate any impacts caused by nonconformance

• Initiate and complete the appropriate corrective and preventive action.

ISO 14001:2004 Section 4.5.2 also states that “…any corrective or preventive action taken to eliminate the causes of actual and potential nonconformances must be appropriate to the magnitude of problems and commensurate with the

environmental impact encountered.”

If any changes in the documented procedures result from any corrective and preventive action, you must implement and record these changes.

Nonconformance refers to any issues that do not meet or comply with the requirements established in the EMS or the ISO 14001 standard. Procedures developed under ISO Section 4.5.2 will provide the mechanism to handle

non-conformances and to ensure steps be taken to prevent a recurrence.

The procedures should include the following key steps:

1. Identify the problem

2. Determine the cause

3. Establish the solution

4. Document the solution

5. Implement the solution

6. Record the documentation and implementation of the solution

7. Communicate the solution.

Operational Control In ISO 14001 Standards

Operational Control In ISO 14001 Standards
Operational Controls over Significant Environmental Aspect Activities, ?4.4.6.a&b – ISO 14001requires the organization to identify and plan the operations associated with its identified significant environmental aspects in order to establish documented operational control procedures that preclude deviation from the Environmental Policy or not achieving objectives and targets.
Opportunities to apply operational controls can be found by reviewing operations. As shown in the accompanying text box, once the operations that can produce significant impacts are identified, it is a relatively simple step to establish operational control procedures that are consistent with the aims of the Environmental Policy and the objectives and targets and that stipulate operating criteria.
Significant Environmental Aspects of Goods and Services, §4.4.6.c – This requirement of ISO 14001 requires careful reading. Here is a parsed interpretation of the Operational Control requirement as it relates to goods and services furnished by others:
“The organization shall identify those operations that are associated with [its] identified significant environmental aspects… The organization shall plan these operations in order to ensure that they are carried out under specified conditions by… [1] establishing and maintaining procedures related to the identifiable significant environmental aspects of goods and services used by the organization and [2] communicating relevant procedures and requirements to suppliers and contractors.”
An easy way to conform to this requirement is to:
1. Identify the operations associated with the significant environmental aspects;
2. Identify the environmental aspects of goods and services furnished by others;
3. Determine how these aspects contribute to the organization’s significant aspect operations;
4. Establish appropriate/relevant requirements for the providers of these services; and
5. Communicate the requirements to suppliers and contractors.
Confusion in conforming to this requirement can arise because it is easy to read sub-clause c) independently of the first sentence of §4.4.6.
This first sentence gives context to the rest of the section in that it requires that we first “identify those operations… associated with the identified significant environmental aspects.” Once we have identified these operations, we look to the significant aspects of goods and services supplied by others and assess their contribution to the potential environmental impact. The accompanying example is offered to help clarify the intent of the requirement.

Sunday, December 6, 2009

Operational Control In ISO 14001 Standards

Operational Control In ISO 14001 Standards
Operational Controls over Significant Environmental Aspect Activities, ?4.4.6.a&b – ISO 14001requires the organization to identify and plan the operations associated with its identified significant environmental aspects in order to establish documented operational control procedures that preclude deviation from the Environmental Policy or not achieving objectives and targets.
Opportunities to apply operational controls can be found by reviewing operations. As shown in the accompanying text box, once the operations that can produce significant impacts are identified, it is a relatively simple step to establish operational control procedures that are consistent with the aims of the Environmental Policy and the objectives and targets and that stipulate operating criteria.
Significant Environmental Aspects of Goods and Services, §4.4.6.c – This requirement of ISO 14001 requires careful reading. Here is a parsed interpretation of the Operational Control requirement as it relates to goods and services furnished by others:
“The organization shall identify those operations that are associated with [its] identified significant environmental aspects… The organization shall plan these operations in order to ensure that they are carried out under specified conditions by… [1] establishing and maintaining procedures related to the identifiable significant environmental aspects of goods and services used by the organization and [2] communicating relevant procedures and requirements to suppliers and contractors.”
An easy way to conform to this requirement is to:
1. Identify the operations associated with the significant environmental aspects;
2. Identify the environmental aspects of goods and services furnished by others;
3. Determine how these aspects contribute to the organization’s significant aspect operations;
4. Establish appropriate/relevant requirements for the providers of these services; and
5. Communicate the requirements to suppliers and contractors.
Confusion in conforming to this requirement can arise because it is easy to read sub-clause c) independently of the first sentence of §4.4.6.
This first sentence gives context to the rest of the section in that it requires that we first “identify those operations… associated with the identified significant environmental aspects.” Once we have identified these operations, we look to the significant aspects of goods and services supplied by others and assess their contribution to the potential environmental impact. The accompanying example is offered to help clarify the intent of the requirement.

Monitoring and Measurement In ISO 14001 Standards

Monitoring and Measurement In ISO 14001 Standards
The Monitoring and Measurement section contains two requirements:
1) Measurement and monitoring of environmental performance associated with operations that can have a significant impact on the environment; and
2) Calibration and maintenance of equipment used for environmental monitoring and measurement.
Monitoring and Measuring of Performance — This section calls for a“procedure to monitor and measure… key characteristics of… operations that can have a significant impact on the environment.”
Note that the section does not specifically require the organization to monitor and measure the significant environmental impacts of its products or services. As a practical matter, however, organizations should establish measurements over all environmental aspects that they determine are significant irrespective of whether the impacts relate to an activity, product, or service.
This section also requires the documentation“of information to monitor performance, applicable operational controls, and… environmental objectives and targets.” §4.6,
Management Review, requires that environmental performance and achievement of objectives and targets become inputs into the Management Review (sub-sections c & d).
Calibration and Maintenance — The requirement of having a calibration system is to ensure that measurements are reliable and accurate. A calibration system may be developed following these steps:
· Identification of measurements to be made;
· Identification of equipment, instruments, hardware and software to be used;
· Identification of the testing methods to be used;
· Determination of the accuracy and precision required or desired;
· Definition of calibration procedures;
· Use of the system;
· Establishment of records;
· If equipment is found to be out of calibration, corrective action; and
· Improvement of the system as necessary.