ISO 14001-2004 Handoutv2

ISO14001 Seminar-Michigan Chamber of CommerceMarch 14, 2007

ASTI Environmental 1.800.395.ASTI 1

Environmental Management Systems

March 2007

Welcome

Investigations, Compliance, Investigations, Compliance, Remediation, and RestorationRemediation, and Restoration

Presenters

Thomas Wackerman, ASTI




Overview

Background

Benefits

The ISO14001 Elements

Break

Implementation and Management

Baseline Audits

Gap Assessments

Lunch

EMS Requirements

Aspects

Legal Issues

Planning

Break

Implementation and Management



Supporting the Program

Implementing Programs

Scheduling and Costs

Training

Annual Audits

Questions and Answers

Adjourn

Other Materials

Binder

Exercises

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Web Resources

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IntroductionInformation Session

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The structure, responsibilities, plans, procedures, processes, and resources used by an organization to develop and achieve its environmental policy.

What is an EMS?

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What is an EMS?

An environmental management system is the method an organization uses to manger their environmental affairs.

Its goal is to integrate business and environmental management.

It provides a basis for continual improvement of environmental management.

It is a process-oriented means of achieving business-critical and environmental-critical targets.



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Benefits of an EMS

Reduced costs, fewer accidents, reduced liabilities

Employee involvement

Delegate and decentralize environmental responsibilities

Heightened environmental awareness and interest by employees

Improved environmental performance

Positive, marketable image -- competitive advantage from enhanced customer trust (customer required)

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What is an EMS?

..part of an organizations management system used to develop and implement its environmental policy and manage its environmental aspects.

- ISO 14001:2004(E)

An organizational structure, incorporating responsibilities, practices, procedures, processes and resources, for implementing and maintaining environmental management

- ISO 14001:1996

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A model to follow when implementing an Environmental Management System (EMS)

An auditable standard for an environmental management system

Many similarities with ISO/QS-9000

A frame work for continual improvement of environmental performance, control and regulatory compliance

A plant-wide or corporate-wide system

What is ISO 14001?



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Development Process

1. Understand the ISO standard

2. Commit to Implementing ISO 14001

3. Select and train a core team

4. Assess the current EMS

5. Create the project plan or environmental management program

6. Select and hire outside support (consultant, legal Registrar, etc.)

7. Develop an environmental policy

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Development Process

8. Kick off ISO14000 employee awareness program

9. Identify external criteria

10. Establish internal criteria

11. Develop an EMS that conforms to ISO 14001

12. Implement the EMS

13. Participate in registration audit

14. Ensure continual Improvement

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PDCA

Plan

DoCheck

Act

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PDCA

Plan

DoCheck

Act

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Establish the objectives and processes necessary to deliver results in accordance with the

organizations environmental policy.

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PDCA

Plan

DoCheck

Act

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Implement the process.

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PDCA

Plan

DoCheck

Act

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Monitor and measure processes against environmental policy,

objectives, targets, legal and other requirements and report results.



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PDCA

Plan

DoCheck

Act

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Take actions to continually improve performance of the

environmental system.

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The Five Principles

Environmental Policy

Planning

Implementation & Operation

Checking & Corrective Action

Management Review

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Milestones

Implement EMS

Participate in Registration Audit

Continual Improvement Identify Requirements

Maintenance, Training, Awareness, Competence



Overview Of ISO14001:2004(E)Information Session

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Agenda

Background

What is an ISO 14000 EMS?

Benefits

Why Companies are doing it.

ISO 14001 Elements

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ISO 14000 Information

Is a series of environmental management standards.

Were designed to assist organizations show sound environmental performance.

Were written by ISO TC 207.

The U.S. Technical Advisory Group (TAG) developed the U.S. position on the ISO 14000 documents.



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The ISO 14000 Family

ISO 14001 - a standard that states requirements for implementing an EMS.

ISO 14004 - a guidance document on EMS principles and techniques.

ISO 14010 - guidelines on principles used in conducting environmental audits.

ISO 14011 - guidelines for procedures controlling environmental audits.

ISO 14012 - guidelines for environmental auditor qualifications.

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14001:1996 Environmental Management Systems - Specification with Guidance for Use14004:1996 Environmental Management Systems - General Guidelines on Principles,

Systems and Supporting Techniques 14010:1996 Guidelines for Environmental Auditing - General Principles14011:1996 Guidelines for Environmental Auditing - Audit Procedures - Auditing of

Environmental Management Systems14012:1996 Guidelines for Environmental Auditing - Qualification Criteria for

Environmental Auditors14020:1998 Environmental Labels and Declarations - General Principles14021:1999 Environmental Labels and Declarations - Self-declared Environmental Claims

(Type II Environmental Labeling)14024:1999 Environmental Labels and Declarations - Type I Environmental Labeling -

Principles and Procedures14031:1999 Environmental Management - Environmental Performance Evaluation - Guidelines14032:1999 Environmental Management Examples of Environmental Performance Evaluation (EPE) 14040:1997 Environmental Management - Life Cycle Assessment Principles and Framework14041:1998 Environmental Management - Life Cycle Assessment - Goal and Scope

Definition and Inventory Analysis14042/43 Environmental Management - Life Cycle Assessment - Life Cycle Impact

Assessment/Interpretation14050:1998 Environmental Management - Vocabulary14061:1998 Information to Assist Forestry Organizations in the Use of Environmental

Management System Standards ISO 14001and ISO 14004

ISO 14000 Series of Standards

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Benefits of ISO 14000

Helps organizations meet and maintain regulatory and legislative requirements.

4.2 Environmental Policy (commitment to compliance)

4.3.2 Legal and Other requirements (procedure to ID and have access to legal and other requirements)

4.3.3 Objectives and Targets (consider legal & other requirements)

4.5.1 Monitoring and Measurement (documented procedure to periodically evaluate regulatory compliance)



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Benefits of ISO 14000

Minimizes the environmental impact of products, activities and resources.

Produces opportunities for competitive advantages.

Customers, shareholders, etc.

May reduce liability and costs.

Promotes environmental awareness among organizations and the community.

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The purpose of ISO 14000 is to:

Help organizations meet environmental responsibilities through set standards.

Discourage countries from using environmental issues as trade barriers.

Eliminates the need for multiple registration for products shipped internationally.

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Who is driving ISO 14000?

The U.S. Dept. of Energy is urging suppliers to establish an ISO 14000 system.

U.S. EPA may reduce the number of audits for ISO 14000 organizations.

Eco-Management Audit Scheme (EMAS) recognizes ISO 14000 certification throughout Europe.

Japanese Ministry of International Industry is urging companies to develop ISO 14000 systems.



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Drivers

International Trade

Customers

Marketing

Investment

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Registration Requirements

Ford

at least one manufacturing site from each production and non-production supplier are required to be third-party registered by December 31, 2001, and all manufacturing sites shipping products by July 1, 2003 (Others by 2005)

General Motors

all suppliers implement an EMS by December 31, 2002 that is third-party certified or self-certifiedthrough a written declaration by a responsible executive. Third- party confirmation is strongly preferred.

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Registration Requirements

Daimler-Chrysler

all suppliers are required to be third-party registered by January 1, 2003

Honda

all 32 key suppliers be registered by December 31, 2001. Remaining 500 US suppliers are strongly encouraged to be third party registered.



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ISO 14000 applies to companies which want to:

Implement, maintain or improve an EMS.

Demonstrate conformance to their environmental policy.

Demonstrate conformance to the standard or other requirements.

Earn EMS certification or registration.

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ISO 9001 + ISO 14001

Are both voluntary standards.

Are both management standards - they do not establish performance levels.

Are both designed for internal use, but supports third-party registration.

Are both generic in nature so that any type and size of organization can use them.

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Common Elements of QMS and EMS

Quality Policy

Adequate Resources

Structure & Responsibility

Training

System Documentation

Process Controls

System Audits

Management Review


Adequate Resources

Structure & Responsibility

Training

System Documentation

Operational Controls

System Audits

Management Review



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Common Elements of QMS and EMS

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Differences Between ISO 9001 + ISO 14001

Manufacturing quality control = business profits?

Environmental quality management = legal responsibilities

i.e., U.S. EPA/MDEQ wont penalize or shut down operation not conforming to ISO 9000 system

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Combining QMS and EMS

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The ISO14001 Elements

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Environmental Management Systems (EMS) and ISO 14001

Brief Overview

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1 Scope

2 Normative References

3 Terms and Definitions

4 Environmental Management Systems Requirements

Organization

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4 Environmental Management Systems Requirements

4.1 General Requirements

4.2 Environmental Policy

4.3 Planning

4.4 Implementation and Operation

4.5 Checking

4.6 Management Review

Organization

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Applicable to organizations wishing to:

Establish, implement, maintain and improve an EMS.

Assure conformance with its environmental policy.

Demonstrate conformance to others.

Seek third-party registration of its EMS.

Make a self-determination and self-declaration of conformance to ISO 14001.

1 Scope

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3 Definitions

3.2 Continual improvement recurring process of enhancing the environmental management system in order to achieve improvements in overall environmental performance consistent in line with the organization's environmental policy

NOTE -The process need not take place in all areas of activity simultaneously.IS

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3 Definitions

3.5 Environment - surroundings in which an organization operates, including air, water, land, natural resources, flora, fauna, humans, and their interrelation

NOTE-Surroundings in this context extend from within an organization to the global system.

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3 Definitions

3.6 Environmental Aspect - element of an organization's activities, products or services that can interact with the environment

NOTE-A significant environmental aspect is an environmental aspect that has or can have a significant environmental impact.

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3 Definitions

3.7 Environmental Impact - any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organization's activities, products or services

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3 Definitions

3.9 Environmental Objective - overall environmental goal, consistent with arising from the environmental policy, that an organization sets itself to achieve, and which is quantified where practicable

3.12 Environmental Target - detailed performance requirement, quantified where practicable, applicable to the organization or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectivesIS

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3 Definitions

3.13 Interested Party person individual or group concerned with or affected by the environmental performance of an organization

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3 Definitions

3.16 Organization - company, corporation, firm, enterprise, authority or institution, or part or combination thereof, whether incorporated or not, public or private, that has its own functions and administration

NOTE - For organizations with more than one operating unit. a single operating unit may be defined as an organization.

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3 Definitions

3.18 Prevention Of Pollution - use of processes, practices, techniques, materials or products or services that to avoid, reduce or control the creation, emission or discharge of any type of pollutant or waste, in order to reduce adverse environmental impacts. pollution, which may include recycling, treatment, process changes, control mechanisms, efficient use of resources and material substitution

NOTE Can include source reduction or elimination, process, product or service changes, efficient use of resources, material and energy substitution, reuse, recovery, recycling, reclamation and treatment.

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4.1 General Requirements

The organization shall establish, document, implement and maintain and continually improve an environmental management system.

The organization shall define and document the scope of its environmental management system.

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Management shall define an environmental policy:

Appropriate to environmental impacts of products.

Commitment to show continual improvement, pollution prevention and compliance to appropriate regulations and other requirements to which the organization subscribes.

Serves as the basis for setting and reviewing environmental objectives and targets.

Documented, implemented, maintained and communicated.

Available to the public.

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4.3.1 Environmental Aspects

Organizations shall establish, implement and maintain procedures to:

Identify environmental aspects of activities, products and services which it can control or influence.

Determine which aspects have or can have a significant environmental impact.

Ensure that aspects are considered when establishing objectives.

Maintain current information.

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4.3.2 Legal and Other Requirements

Organizations shall establish, implement and maintain procedures to:

Identify and have access to legal and other requirements to which are subscribed.

Identify which legal requirements are applicable to the environmental aspects of its activities, products and services.

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4.3.3 Objective and Targets

Environmental objectives and targets need to be documented, which are:

Measurable and consistent with environmental policy.

Including commitment to prevention of pollution, compliance and continual improvement.

Consideration must be given to:

Legal and other requirements.

Significant environmental aspects.

Technological options.

Financial, operational & business requirements.

Views of interested parties.

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4.3.4 Environmental Management Program

An established environmental program shall:

Designate responsibility for achieving targets and objectives.

Include a plan and schedule for meeting targets and objectives.

Be amended to include changes and new developments.

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4.4.1 Structure and Responsibility

Roles, responsibilities and authorities must be defined, documented and communicated.

Management must provide resources to establish,implement, maintain and improve and control the EMS.

A Management Representative must be appointed, who will:

Oversee and insure the EMS implementation and maintenance.

Ensures conformance to ISO 14001.

Reports on performance to top management.

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4.4.2 Training, Awareness and Competence

The organization must identify training needs and establish, implement and maintain procedures.

Each relevant employee must be aware of:

The importance of meeting the EMS requirements.

The EMS impacts and benefits as related to their jobs.

Their roles and responsibilities in achieving EMS conformance.

Consequences of not meeting EMS requirements. Employees must be competent and have appropriate education,

training and experience.

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4.4.3 Communication

The organization will establish and maintain procedures for:

Communicating internally, information between various levels and functions.

Receiving, documenting and responding to external EMS communications.

The organization will consider external communication on its significant environmental aspects and record its decisions.

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4.4.4 EMS and Documentation

The organization will establish and maintain information, which:

Describes the scope and core elements of the EMS and the interactions.

Provides direction to related documents.

Shall include..

Policy, objectives and targets, relevant records and documents.

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4.4.5 Document Control

Organizations must maintain procedures controlling documents so that:

They can be located, reviewed, revised and approved by authorized people.

Current versions of documents are available.

Obsolete documents are removed or made unusable. Retained documents are identified.

Documents must be legible, identifiable, dated, maintained and retained with documented assigned responsibilities.

Review, approval, and updates must be documented

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4.4.6 Operational Control

Organizations must identify operations which effect their EMS.

Plans for control under specified conditions must include:

Documented procedures relative to the EMS targets and objectives.

Stipulation of operating criteria.

Control of goods and services used by the organization.

Communication of procedures for significant environmental aspects to suppliers.

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4.4.7 Emergency Preparedness and Response

Procedures must exist for emergency and accident situations, and how to prevent environmental impacts.

Emergency preparedness and response procedures must be revised as appropriate after emergency situations.

Procedures must be periodically tested where applicable.

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4.5.1 Monitoring and Measurement

.establish and maintain documented procedures

Operations related to significant aspects must be monitored.

Progress toward achievement of objectives and target must be monitored.

Monitoring and measurement devices must be calibrated and maintained with records retained.

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4.5.2 Evaluation of Compliance

Compliance with relevant environmental legislation and regulations must be evaluated.

Keep records of periodic evaluations

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4.5.3 Nonconformance and Corrective and Preventive Action

Procedures must define responsibility and authority for:

Handling and investigating nonconformances.

Taking actions to mitigate any impacts caused.

Initiating and completing appropriate actions. Corrective and preventive action must be appropriate to the

magnitude of the problem.

Review effectiveness

Applicable documentation of investigations and changes must be recorded.

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4.5.4 Records

Records must be identified, maintained and disposed of per procedures.

Training and audit records are included.

Records must be legible, identifiable, traceable, retrievable, and prevented from loss, damage or deterioration.

Records must be maintained as appropriate to the EMS and organization.I

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4.5.5 Internal Audit

EMS audits must be conducted at planned intervals:

Determine if the EMS:

Conforms to the EMS plan and ISO standards.

Has been properly implemented and maintained.

Provide information to management.

Audits must be based on environmental importance of the operation and past audit results.

Audit scope, frequency, methods, reporting and responsibilities must be documented.

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Management must conduct scheduled reviews of the EMS.

The review must ensure that necessary information is provided to management.

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Management must review the EMS for changes related to:

Internal audit results.

Changing circumstances.

Continual improvement.

External Communications

The extent to which objectives and targets are met

Status of compliance and preventive actions

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Appendix A: Guidance

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Appendix B: ISO14001:2004 v ISO9001:2001

Break Time 15 Minutes


Implementation and ManagementInformation Session



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Agenda

Baseline Audits

Gap Assessments

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Baseline Audits Legal Considerations

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Environmental Compliance is Not Becoming any Easier!



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What is an Environmental Compliance Audit?

Manage risk posed by regulatory programs, on facility or corporate basis; i.e., identify, analyze, prioritize, and solve environmental issues

Distinguish environmental site assessments

Distinguish EMS Registration Audit

Audits Legal Considerations

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Why Perform an Audit?

Compliance Auditing as Part of EMS, including

Baseline Audit/Gap Analysis


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Compliance Audit Project Team and Functions

Corporate Officer

Environmental Manager

Legal Counsel (In-house vs. Outside Lawyer)

Environmental Consultant/Technical




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Consultant Retention

Selection and Contracting

Scope of Work


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Protecting the Confidentiality of Audits

Attorney-Client Privilege

Anticipation of Litigation Work-Product

Self-Audit Privilege?

Address with ISO Registrar


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Michigan Environmental Audit Privilege and Immunity Legislation

March 15, 1996, Governor Engler signed new law - Environmental Audit Privilege and Immunity.

The law became Part 148 of the Natural Resources and Environmental Protection Act (NREPA).




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Michigan Environmental Audit Privilege and Immunity Legislation - Contd.

Purpose of law is to encourage regulated community to conduct self-audits of environmental regulatory compliance, by providing privilege for confidentiality of audits and immunity from enforcement for certain newly discovered compliance problems.

Audit defined broadly to include EMS.


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First, the legislation creates an evidentiary privilege to allow facility owners to maintain as confidential environmental audit reports. (However, this legislation does not encompass OSHA issues.)

There are various requirements to establish the privilege, including that audit be conducted voluntarily; report be properly labeled; report not be disclosed to any third-party without a confidentiality agreement; and that corrective measures be promptly undertaken to address any non-compliance.


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Second, if an environmental audit is performed consistent with this legislation, and corrective action promptly instituted, new law provides for immunity from fines and penalties regarding non-compliance found during the audit.

Those findings of the environmental audit for which immunity is desired also need to be reported to MDEQ.




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December 1997 Michigan Part 148 Amendments

To appease U.S. EPA

Advance notice to MDEQ

Completion within 6 months

Corrective actions within 3 years

Immunity limited and conditional


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EPA remains staunchly opposed to state audit laws from a policy perspective, which continues to cause a serious chilling effect on companies undertaking self-audits. Companies that utilize Michigans law are still subject to all penalties and sanctions under federal law, and we remain concerned that EPAs position and future action may have an adverse effect on Michigans audit program.

-Russell Harding, MDEQ Director, U.S. Congressional Testimony (Nov. 4, 1997)


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MDEQ-EAD Administers State Part 148 Audit Program

Further information: http://www.michigan.gov/deq/0,1607,7-135-3307_3666_4135---,00.html




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REPORTING OBLIGATIONS FROM AUDITS

Spills/Accidental Releases

Unpermitted Discharges

Permit Exceedances


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ENFORCEMENT ISSUES WITH AUDITS

U.S. EPA Office of Criminal Enforcement (OCE), The Exercise of Investigative Discretion.

OCE should always investigate individual employees and their corporate employers who may be culpable.

Corporate culpability may also be indicated when a company performs an environmental compliance or management audit, and then knowingly fails to promptly remedy the noncompliance and correct any harm done.


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U.S. EPA Voluntary Environmental Self-Policing and Self-Disclosure Policy, see 60 Fed. Reg. 66706 (Dec. 22, 1995)




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Conducting the Audit

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Definitions

Any element of an organizations actual or potential activities, products or services, which can interact with the environment.

Any aspect that has or can have a significant environmental impact.

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EMS:

Environmental management system


Planning

Implementation & Operation

Checking & Corrective Action

Management Review.



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ISO14001 Philosophy

Reactive

Proactive

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Baseline Audits

Initial environmental review

Environmental concerns and impact of controls.

Identify significant aspects that can be controlled.

Procurement and contractors.

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Baseline Audits

A procedure to develop environmental aspects that apply to actual activities, products and services.

Facility inspection(s) (assessment).

Use checklists for guidance (example).



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Response # Question (Y, N, DK, n/a) Finding Source Recommendation Comments

1

Has generator generated morethan 100 kilograms (220pounds) of hazardous waste permonth, or accumulated morethan 1,000 kilograms? (if YES,comply with SQG or LQGrequirements, see SQG or LQGchecklists)

2Have all wastes been classified,e.g., hazardous or non-hazardous? 40 CFR 262.11

3Have there been any State orFederal agency inspectionssince the previous audit?

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Are there any citations, noticesof violation, or notices of non-compliance that have not beenresolved by the facility? (if yes,explain)

Example Audit Evaluation

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Baseline Audits

Consider all media for actual or potential impacts.

Air

Water

Soil

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Baseline Audits

Identify aspects and the impacts on the environment.



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Aspects

Waste generation

Wastewater discharge

Stormwater discharge

Air emissions

Point source

Fugitive

Automotive

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Aspects (Cont.)

Chemical operations

Water use operations

Energy use operations

Use of natural resources

Out-dated product

Product disposal

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Objectives

Reduce effluents and emissions

Increase material and product recycling and use of recycled products

Reduce unplanned releases

Reduce energy consumption



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Gap Assessments

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Gap Analysis

Collect and maintain required information.

Control that can be exerted over the aspects.

Current position.

Legislature and regulatory requirements.

All existing EMS practices and procedures

Feedback from previous incidents

Previous audits and agency inspections.

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Gap Analysis (Cont.)

Setting and achieving objectives for EMS.

Designate responsibility.

Establish priorities.

Description of how targets will be completed.

Identify responsible party.

Deadlines for achievements.



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Gap Analysis (Cont.)

Provisions for EMS maintenance.

Review of modified activities, products & services.

Provisions to amend EMS.

Lunch 60 Minutes


Implementation and ManagementInformation Session



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Agenda

EMS Requirements

Aspects

Legal Issues

Planning

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EMS Requirements

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Key ingredient to success

Executive Management Commitment



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Keys to Success

Top Management commitment & resources

First Step: Benchmark EMS to the standard

Implement an Action Plan

Attention to the Environmental Planning Process (Set realistic objectives and targets)

Leverage existing business practices & documentation

Remember, its your system

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Key Management Responsibilities

Spearhead employee involvement (notify employees of intent to implement ISO 14001)

Assign Management Representative

Assign Steering Committee

Approved Schedule

Level of Integration with Health & Safety and Quality

Approach communication as a way to sell employees on an enhance quality system.

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Benchmark Existing EMS

Opening Meeting

Assess EMS for conformance to ISO 14001

Identify QMS documentation that is similar to ISO 14000.

Preliminary Report

Closing Meeting

Detailed Report

- Observations

- Recommendations

- Action Plan



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ISO 14001 Percent Complete TableFOR: Company

ELEMENT ELEMENT DESCRIPTION POINTSRECEIVED

POINTSPOSSIBLE

PERCENTCOMPLETE

1 ENVIRONMENTAL POLICY 13 30 43%2 ENVIRONMENTAL ASPECTS 2 10 20%3 LEGAL & OTHER

REQUIREMENTS11 14 79%

4 OBJECTIVES & TARGETS 7 10 70%5 ENVIRO. MGT. PROGRAMS 7 8 88%6 STRUCTURE &

RESPONSIBILITY3 8 38%

7 TRAINING AWARENESS &COMPETENCE

4 16 25%

8 COMMUNICATION 6 14 43%9 EMS DOCUMENTATION 1 4 25%

10 DOCUMENT CONTROL 6 14 43%11 OPERATIONAL CONTROL 5 10 50%12 EMERGENCY PREP. &

RESPONSE6 8 75%

13 MONITORING & MEASUREMENT 6 8 75%14 NON-CONF, CORRECTIVE &

PREVENT. ACTION3 6 50%

15 RECORDS 7 10 70%16 EMS AUDIT 4 8 50%17 MANAGEMENT REVIEW 3 12 25%

GRAND TOTAL 94 190

PERCENT COMPLETE 49%

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I S O 1 4 0 0 1 P e r c e n t C o m p l e t e G r a p h

4 3 %

2 0 %

7 9 %

7 0 %

8 8 %

3 8 %

2 5 %

4 3 %

2 5 %

4 3 %

5 0 %

7 5 %

7 5 %

5 0 %

7 0 %

5 0 %

2 5 %0 % 2 0 % 4 0 % 6 0 % 8 0 % 1 0 0 %

E N V IR O N M E N T A L P O L IC Y

E N V IR O N M E N T A L A S P E C T S

L E G A L & O T H E R R E Q U IR E M E N T S

O B J E C T IV E S & T A R G E T S

E N V IR O . M G T . P R O G R A M S

S T R U C T U R E & R E S P O N S IB IL IT Y

T R A IN IN G A W A R E N E S S &C O M P E T E N C E

C O M M U N IC A T IO N

E M S D O C U M E N T A T IO N

D O C U M E N T C O N T R O L

O P E R A T IO N A L C O N T R O L

E M E R G E N C Y P R E P . & R E S P O N S E

M O N IT O R IN G & M E A S U R E M E N T

N O N - C O N F , C O R R E C T IV E & P R E V E N T .A C T IO N

R E C O R D S

E M S A U D IT

M A N A G E M E N T R E V IE W

125

Show top management commitment and get associate support

On February 7, 1997 Takeo Fukui, President of Honda of America issued a memo to all associates requesting them to fully support the ISO 14001 project team.

ISO 14001 certification is another example of our environmental leadership in industry.



126

Assign EMS Management Representativeand Steering Team:

Engineering QS-9000 Human Resources Maintenence Training

EMS ManagementRepresentative

General Manager

Start



4.5 Checking/Corrective Action


4.5.2 Nonconformance andCorrective & Preventive Action

4.5.3 Records4.5.4 EMS Audits

4.3 Planning4.3.1 Environmental Aspects

4.3.2 Legal/Other Requirements

4.3.3 Objectives and Targets

4.3.4 Environmental ManagementProgram

4.4 Implementation4.4.1 Structure and Responsibility

4.4.2 Training, Awareness, Competence

4.4.3 Communication

4.4.4 EMS Documentation



4.4.7 Emergency Preparedness/Response

ContinualImprovement

The 14001 EMS Element Cycle

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A statement of your organizations commitment to the environment, used as a framework for planning and action

Three things your policy must address:

1. Commitment to Compliance

2. Prevention of Pollution

3. Continual ImprovementEMS

Policy



129

HAM is committed to the protection of the environment and the conservation of natural resources, and will conduct its operations with the highest regard for the preservation of the environment. As a responsible corporate citizen, HAM recognizes that the environmental management of its operations is a fundamental obligation. Therefore, HAM will conduct its operations in accordance with the followingprinciples:

HAM will comply with all applicable environmental requirements mandated by federal, state, and local law, as well as HAM internal policies, and will meet or exceed all voluntary environmental commitments that it makes to federal, state, or local authorities.

HAM will operate and continually improve an environmental management system to monitor and control the environmental impacts of its operations.

HAM will implement methods to prevent pollution, conserve natural resources, and reduce waste.

Honda Environmental Policy

130

LDM Technologies is committed to quality excellence in manufacturing while protecting our global environment. Our philosophy of conserving natural resources, protection of our environment and our employees is demonstrated by our commitment through continuous improvements of

Prevention of Pollution

Compliance to all applicable regulations and other requirements

Health & safety

Quality Management System

131



132

Environmental Policy Tips

Include an opening paragraph that briefly describes the activities, products and/or services of the facility.

Also the facilitys philosophy on protection of the environmental.

Include the three commitments

Top plant management needs to approve the policy

All employees need to know the policy

Make the policy available by: posting it lobby, publishing, including in promotional materials, etc.

133

Aspects

134


..establish, implement and maintain a procedure(s)

a) to identify the environmental aspects of its activities, products and services within the defined scope of the EMS that it can control and those that it can be expected to have an influence taking into account planned or new developments, or new or modified activities, products, and services, and

NEW



135


..establish, implement and maintain a procedure(s)

b) to determine those aspects that have or can have significant impact(s) on the environment (i.e. significant environmental aspects).

NEW

136


The organization shall document this information and keep it up to date.

The organization shall ensure that the significant environmental aspects are taken into account in establishing, implementing and maintaining its environmental management system.

NEW

137

Identifying and Evaluating Environmental Aspects/Impacts

IdentifyEnvironmental

Aspect

Determine Impactto Environment

Aspect isThereforeSignificant

Is ImpactSignificant?

Control, Study, or Improve Aspect viaEnvironmental Management Programs

and Operational Controls

Stop(Record)

YesNo



138

Identification of Aspects and Evaluation of Impacts

Step 1, select an activity, product or service large enough for meaningful examination and small enough to be understood.

- Pre-production

- Assembly

- Material Handling

- Paint Line

139


Step 2, identify the environmental aspects of the activity, products or service.

- Use process flow charts

- Regulatory compliance audit reports

- Environmental site assessment reports

- Site walk or review

Consider normal & abnormal conditions (e.g.., startup, shutdown, emergencies)

Environmental Aspects

INPUTS OUTPUT

Transportation

Chemicals

Oil/Fuels

Electricity

HazardousWaste

Water

Raw Materials/Consumables

Air Emissions

WaterDischarges

Solid Waste

Transportation

Property

Other Outputs

FACILITY

Other Inputs

SpillPotential

GroundwaterWetlands, etc.



141

Possible Environmental Aspects

Air emissions (fugitive /point)

WW effluent

Electricity Use

Natural Gas Use

Lagoons/ponds

Land Use (wetlands)

Raw Material and Resource Use

Hazardous Waste

Solid Waste

142


Step 3, Identify environmental impacts associated with each aspect

Identify as many actual and potential, positive and negative, environmental impacts as possible associated with each identified aspect.

143

Examples From Steps 1-3

Activity, Productor Service

Aspect Impact

1 - Paint Line2 - Welding

Air Emissions Degradation of AirQuality

New or ModifiedConstruction

Land Use(wetlands)

Depletion ofWetlands

Scrap generation Solid Waste Landfill Use/Natural Resources



144

Results From Steps 1-3

Activity, Productor Service

Aspect Impact

Paint Line 4 Solid waste,parts scrapped

Landfill waste,depletion ofresources

Paint Line 4 Haz waste,obsolescent orrejected paint

Air quality,resource depletion

Shipping Air Emissionsfromwarehouseoperations

Humanhealth/ecology

145


Step 4, Evaluate the significance of impacts; evaluation can be facilitated by considering the following (Consider a scoring system to rank each aspect).

Environmental Concerns:- the scale of the impact- the severity- probability of occurrence- duration of impact

Business concerns:- potential regulatory and legal exposure- difficulty of changing the impact- cost of changing the impact- effect of change on other activities- concerns of interested parties- effect on public image of the organization

RegulatedActivity/Department Aspect Description Severity Likelihood Detection SF Y= x 1.5

S x L x D x Yes/No

Shipping Air Emissions Tow motor operation 4 3 3 54 Y

Paint Line 4 Solid WasteScrap plastice parts falling off paint rack 4 3 3 36 N

Paint Line 4 Hazardous Waste

Discarded paint from Obsolesence or

quality 4 4 2 54 Y

Paint Line 4 Air EmissionsVOC from Paint Mixing 5 3 2 45 Y

Paint Line 4 Air EmissionsHAPS from Paint

Mixing 3 5 2 45 Y

Paint Line 4 Employee Safety

Exposure from coating/part

preparation/mixing 5 3 2 45 Y

Environmental Significance of Impact

Environmental Aspect Evaluation



147

Environmental Aspect Evaluation

NEW

A B C D (A+B)*(C+D)

Aspect

Sensitivity of the Affected Medium

or PopulationToxicity / Hazard Quantity

Frequency of Occurrence IP Regulated? Adj. IP

heating imbalance fuel consumption 1 2 1 1 6 Y 9ventilation fuel consumption 1 2 1 1 6 N 6flourescent bulbs special waste disposal 0 0maintenance welding operatio visual impairment 0 0maintenance welding operatio air quality 0 0

Activity

Assessment Criteria - Normal Situations

Facility Maintenance

A B C D (A+B)*(C+D)

Aspect Area AffectedRelevance

(Importance)Frequency of Occurrence Unpreparedness IP Regulated? Adj. IP

raw material storage (particul surface water 0 0flammable material storage air quality 1 1 1 1 4 4flammable material storage health & safety 0 0flammable material storage stormwater 0 0

Activity

Assessment Criteria - Abnormal or Emergency Situations

148

Alternative Aspects Evaluation

SIGNIFICANCE CRITERIA

Does it fall under any obligation(s) under applicable environmental regulation?

Is it a company directive?

Using professional judgment, are there other factors that should be considered (i.e., volume, toxicity, spill potential)?

Note: A Formal Risk/Impact Assessment or Elaborate Matrices Are Not Required

149

Possible Significant Environmental Aspects

Oil Storage/Use

Noise

Sewer Discharge

Use of CFCs, Dye Penetrate Use

Electricity Use

Solid Waste Generation & Disposal

Oil absorbents and other landfilled wastes

ConsiderSeparate

Ranking forNormal andAbnormalOperations

NEW



Environmental Aspect/Impact Evaluation

15 Minute Exercise


3.3 Environmental Aspect - element of an

organization's activities, products or services that

can interact with the environment

151

EMS Legal Requirements

152

4.3.2 Legal and other requirements

establish and maintain a procedure to have access to legal and other requirements to which the organization subscribes. ISO 14001

how do you access legal requirements?

- Attorney/consultant on retainer

- Subscriptions

- Internet access to CFR and Federal Register

Recommend list of legal requirements

Other requirements include, ASTM, CMA,

GM Declaration of Conformance to GM W3059



153

EMS Legal Issues

Compliance with Applicable Laws and Requirements is Minimum Goal

Gap Analysis = Compliance Audit?

Environmental Policy May Expand Legal Obligations (public availability)

Document Retention/Destruction Policy; ISO Document Control

Monitor and Update Relevant Laws and Regulations

154

EMS Legal Issues - Contd.

Privilege/Immunity Issues

Compliance and Enforcement Issues; Distinguish Non-Conformance?

Audit Procedure Issues

Issues Basic to Development/ Implementation of EMS

Significant environmental aspects identification; cf. CAA inventory or compliance audit

155

ISO 14001: Legal and Other Requirements

ISO 14001 4.3.2

Establish and maintain procedure Identify and have access to: Legal requirements Other requirements to which organization

subscribes

Applicable to environmental aspects



156

Federal and State Legislation

Clean Air Act (CAA)/Michigan Part 55 Clean Water Act (CWA)/Michigan Part 31 Wastewater and stormwater

Comprehensive Environmental Response, Compensation and Liability Act (CERCLA or Superfund)/Michigan Part 201

Resource Conservation and Recovery Act (RCRA)/Michigan Parts 111 & 115

Solid and hazardous waste Underground Storage Tank (UST) Regulations/Michigan

Parts 211 & 213

157

Federal and State Legislation

Other Legal Requirements, e.g.: Safe Drinking Water Act (SDWA) Toxic Substances Control Act (TSCA) Emergency Planning and Community Right-to-Know

Act (EPCRA or SARA Title III)

Consent Decrees/Orders OSHA (?) Local Ordinances (e.g., IPP)

158

Voluntary Environmental Requirements

U.S. EPA Project XL

MDEQ Clean Corporate Citizen (C3)

PERI Principles

CMA CARE Program

Michigan Business Pollution Prevention Partnership (MBP3)



159

Voluntary Environmental Requirements

Customer Requirements

Lender Conditions

Industry Codes of Practice

Non-Regulatory Guidelines

160

ISO 14001 - Legal and Other Requirements

How to Identify Applicable Environmental Laws and Requirements?

Need to Periodically/Regularly Update

Access to Environmental Laws and Regulations?

Aspect/Issue Legal or Other Requirement Reference ExplanationCompliance

Evaluation/ReviewOil Leaks and Spills

Managing Used Oil: Advice for Small Businesses

Monitor significant spill frequency

Used Oil Dry and "Pigs"

Managing Used Oil: Advice for Small Businesses

Monitor significant spill frequency

Waste OilPART 279 (Updated 1999) -

STANDARDS FOR THE MANAGEMENT OF USED OIL

Ensure total volume of oil remains below the threshold for implementation of a SPCC Plan

Ensure total volume of oil remains below the threshold for implementation of a SPCC Plan

Noise Occupational noise exposure. - 1926.52 Access to the Pump Room is restricted to personnel with hearing protection.

Sewer Discharge City of Toledo No permit required at this time.Storage of Metal to be Recycled

No Exposure Guidance Document and Forms)

Initiate CAR for the outside storage area. Confirm no exposure

AC Refridgerants EPA Requirements for Servicing Air Conditioners and Refrigeration Equipment Handled by Vendor.

Disposal of Computers and CRT

A Guide to Computer Recycling in Ohio

All computer equipement is leased through DCC. DCC is repsonsible for collection of and recycling of unwanted computer equipement.

Fluorescent Light Bulbs

The Management of Fluorescent Lamps and PCB Ballasts in Ohio Recycled through Waste Management

Chemical Hygiene Plan

Occupational exposure to hazardous chemicals in laboratories. - 1910.1450 Metrology Lab Annual Review

Hazard Communication Program

Hazard Communication. - 1910.1200 Annual Review

MSDS Requirements Hazard Communication. - 1910.1200 Annual Audit

Emergency Action Plan Emergency action plans. - 1917.30 Annual Review

Forklifts Powered industrial trucks. - 1917.43 Annual Training

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Summary of Legal and Other RequirementsABC Plant

ASPECT DEPT(S) FEDERAL CITATION STATE CITATION OTHERAboveground Storage Tanks ALL 40 CFR 112 SPCC & SWPP Plan & ISO 14001Aboveground Storage Tanks Plant 40 CFR 60 Subpart Kb ISO 14001

CO Emissions FAC OAC 3745-21-08(B) PTI 01-3194 & ISO 14001CO Emissions FAC OAC 3745-31-05 PTI 01-177 & ISO 14001CO Emissions FAC OAC 3745-31-05 PTI 01-7350 & ISO 14001CO Emissions PA OAC 3745-21-08(B) PTI 01-0362 & ISO 14001CO Emissions PA OAC 3745-21-08(B) PTI 01-2259 & ISO 14001CO Emissions PA OAC 3745-21-08(B) PTI 01-3474 & ISO 14001CO Emissions PA OAC 3745-21-08(B) PTI 01-6743 & ISO 14001CO Emissions PL OAC 3745-21-08(B) PTI 01-0512 & ISO 14001CO Emissions PL OAC 3745-21-08(B) PTI 01-0999 & ISO 14001

Electricity Plant Energy Conservation & ISO 14001Hazardous Waste PA & PL 40 CFR 265 Subpart BB OPFP* & ISO 14001Hazardous Waste PA & PL 40 CFR 265 Subpart CC OPFP* & ISO 14001Hazardous Waste Plant 40 CFR 260.10 OAC 3745-50-10 OPFP* & ISO 14001Hazardous Waste Plant 40 CFR 261 OAC 3745-51 OPFP* & ISO 14001Hazardous Waste Plant 40 CFR 262 OAC 3745-52 OPFP* & ISO 14001Hazardous Waste Plant 40 CFR 268 OAC 3745-59 OPFP* & ISO 14001Hazardous Waste Plant 40 CFR 265 OAC 3745-65 OPFP* & ISO 14001Hazardous Waste Plant OAC 3745-66 OPFP* & ISO 14001Infectious Waste Medical OAC 3745-27 ISO 14001

Natural Gas Plant Energy Conservation & ISO 14001NOx Emissions FAC OAC 3745-23-06(B) PTI 01-3194 & OPFP* & ISO 14001NOx Emissions FAC OAC 3745-31-05 PTI 01-177 & ISO 14001

Approval Issuer

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Planning and Documentation

164

Activities, Products orServices (over which theCompany has control andinfluence) that interactwith the environment

Legal & OtherRequirements

EnvironmentalAspects

4.3.1 4.3.2

Objectives& Targets

4.3.3

EnvironmentalManagement

Program

Views of InterestedParties

4.3 Planning



165

P6

Proper Planning Prevents Piss Poor Performance

SMART

Specific, Measurable, Achievable, Results Oriented, Time Framed

4.3 Planning

166

4.3.3 Objectives & Targets

documented objectives and targets at each function and level within the organization. ISO 14001

Consider legal requirements, significant aspects, technological options, financial, operational and business requirements, and interested parties.

Consistent with policy including commitment to prevention of pollution.

167

Issue Objectives TargetsPressLubricatingOil Use

Reduce OilUse

Reduce oil use by 20% by 2002

Solid Waste Reducesolid wastesent tolandfill

Reduce solid waste disposal costs by20% by the end of 2001

1) Reduce use of energy plant wide by10% by 2002

Resources ConserveNaturalResources

2) Reduce water consumption by 20%per by 2002



168

Environmental Management Programs

Linked directly to objectives and targets

Projects implemented to achieve objectives and targets

Waste reduction assessments excellent way to identify these opportunities

Develop action plan including responsibilities, means and time lines

If a project relates to new developments and new or modified activities, products or services, program(s) shall be amended where relevant to ensure that environmental management applies to such projects.

169

Objectives Targets Environmental Program ResponsibilityConserveResources

IdentifyOpportunitiesfor ChemicalUseReductions byend of 2001

1) Develop chemical use inventory forfacility. Use MSDS book as basis ofinventory. Monitor chemical usage.

2) Update MSDS book and add/removesheets as needed.

3) Develop and implement action plan todispose of or use dated chemicals.

4) Identify opportunity areas for chemicaluse reduction.

EMS SteeringCommittee by10/2001

ReduceElectricity Useby 5% peremployee bythe end of2004 versus1999 energyusage

1) Evaluate electricity use facility wide.Ask utility to conduct energy audit.

2) Identify opportunities for electricity usereductions. Results from energy audit.

3) Develop and implement action plan toreduce energy use.

John Doe by8/2001

Reduce waterconsumptionby 5 % peremployee byend of 2004versus 1999usage

1) Implement monthly water usemonitoring on a per employee basisversus 1999.

2) Identify opportunities for water usereductions.

3) Develop and implement action plan toreduce water use.

John Doe by4/2003

170

Objectives Targets Environmental Program ResponsibilityConserveResources

Reduce fuel oil,gas, otherheating relatedmedium by 5 %per employee byend of 2004versus 1999

1) Implement monthly fuel usemonitoring on a per employee basisversus 1999.

2) Identify opportunities for fuel usereductions.

3) Develop and implement action planto reduce fuel use.

John Doe by4/2003

Reduce solidwaste to thelandfill by 4% peremployee verses1999 by end of2001 Versus1999

1) Develop operation controls for wastesegregation program. DevelopMonitoring and measurementmetrics.

2) Develop training on wastesegregation operational controls.

3) Train all employees on wastesegregation.

Jane Doe by12/2000

IncorporateEMS into APQPby 12/2000

Amend APQP process to includeconsideration of EMS in new productand process planning.

QualityManager by12/2000



171

4.4.1 Structure and Responsibility

Roles, responsibilities and authorities shall be defined, documented and communicated ISO 14001

Management shall provide human, technological and financial resources essential to the implementation and control of the EMS.

Top management appoints MR* with defined role, responsibility and authority for:

- ensuring that EMS requirements are established, implemented and maintained;

- reporting on the performance of the EMS to top management as abasis for improvement of the EMS

* Management Representative

172

EMS Responsibilities

Functions Possible RolesPurchasing Develop & implement controls for chemical & other

purchasesHumanResources

Define competency requirements & job descriptions forEMS roles

Integrate EM into reward/discipline systemFinance Track data on EM costs

Prepare budget for EM program Evaluate economic feasibility of projects

Engineering/Environmental

Consider impacts of new or modifiedproducts/processes

Identify pollution prevention opportunityTopManagement

Communicate importance of EMS Provide necessary resources Track & review EMS performance

GeneralAssociates

Knowledge of environmental aspects of their job Support training of new employees Know Environmental Policy

173

4.4.3 Communication

With regard to its environmental aspects and EMS, the organization shall establish and maintain procedures for

- internal communication between the various levels of the organization

- receiving, documenting and responding to relevant communication from external interested parties

Consider processes for external communication on its significantaspects and record its decision.



174

Environmental Communications Log

Date Recd

Originator

Int?

Ext?

Response Summary

Date

Closed

10/20/00

USEPA Letter from John Doe dated 10/15/00

X Prepare and mailed response letter 10/25/00

11/15/00

Odor complaint call from Jane Deer

X Inspected property and provided letter response

12/25/00

1/5/01

Car paint damage claim call from Joe Worker

X Inspected car, provided picture documentation

1/9/01

175

4.4.4 Documentation

Establish and maintain information, in paper or electronic form,to

- to describe the core elements of the management system and their interaction

- provide direction to related documentation

176

EMS Documentation Needs

Is it a core element of the EMS?

Can you demonstrate objective evidence of a procedure if it is not documented?



177

EMS Documentation

EnvironmentalPolicy

Procedures

Work Instructions

Records

Why you do it

What you do

How you do it

Evidence ofwhat you do

Intent

What, when, where & who

How

A 4-Tier System: International StandardsISO 14001

178

EMS Documentation Road MapElement Number

Element/Issue Level 1 Manual Level 2, Procedures

Level 3, WI Level 4, Forms

EMS Scope Section 4.1 Quality Manual


Section 4.1 Quality Manual

EP3.1-1 Environmental Aspects

P2-1 APQP Procedure


EP3.2-1 Legal

and Other Requirements

P9-5 Environmental /Safety

EF3.2-1, Legal and Other Requirements

4.3.2 Legal and Other Requirements

P3-1 Contract Review

EP3.3-1 Objectives and Targets

4.3.3 Objectives and Targets

179


Establish and maintain procedures for controlling all documents required by this international standard to ensure that

- they can be located; they are periodically reviewed, revised and approved;

- current versions are available where they are needed;

- obsolete documents are promptly removed to avoid unintended use

Documents shall be legible, dated and identifiable.

Note: Regulations may require specific document retention (e.g. waste manifests)



180

Approval Issuer

TitlePurpose:Scope:Responsibilities:Definitions:Impelementation:Associated Documents:

Revisionhistory

The following indicates the revision level date and reason for the revisions tothis document.

No. Date Revision history0 5/11/98 Document creation.

Document Number: MAP 01 69 003 Page 1 of 1Revision Number: 0Revision Date: 5/11/98 MAP Significant Aspects procedure.doc

181


Identify those operations and activities associated with the identified significant aspects in line with policy, objectives and targets. Plan these activities in order to ensure they are carried out under specified conditions.

- Establish and maintain documented procedures to cover situations where their absence could lead to deviations from policy and objectives and targets.

- Stipulate operating criteria in procedures.

- Procedures related to significant aspects of goods and services used by the organization need to be communicated to suppliers and subcontractors.

182

Complete Operational Controls Procedures

take credit for existing administrative and engineered controls

be sure to address all significant aspects and ensure they are specific to the activity

assess whether current controls are adequate

evaluate monitoring requirements and required record keeping

identify any mitigative actions expected by workers during emergency




Cost Level Regulated Program/Activity Aspect Impact Severity Likelihood Detection SF to of Response

S L D SxLxD Address Control Yes/No Reference

Painting-Dept 57 Solvent evaporation VOC Emissions 4 5 2 40 3 3 Y EPI-019Sump tanks / pits Leaks to soil Contaminated Soil 4 3 3 36 3 2 Y EPI-008Painting-Dept 45 Solvent evaporation VOC Emissions 4 4 2 32 3 3 Y EPI-019

Outside equipmentstorage

Oil leaks from equip.being stored Storm Drain Pollution 4 4 2 32 3 3 Y EPI-017

Machinery Waste Coolants Liquid Waste 3 5 2 30 1 3 Y EPI-020Sump tanks / pits Coolants & oils Oily Waste Water 3 4 2 24 2 2 Y EPI-020

Rust Protection-D55 Solvents in RP VOC Emissions 2 4 3 24 1 3 Y Planning

Outside UnloadingBulk fuel, solvent,

or paint leaksPotential Liquid Spills

to Stormdrain 4 3 2 24 3 2 Y EPI-004Aerosol Can

DisposalDisposal of solvents

and propellantsHazardous Liquid

Wastes 4 3 2 24 1 3 Y EPI-001

Chip Dock DrainageOil leakagefrom trailers Soil Contamination 3 3 2 18 2 2 Y EPI-005

Chip Dock Drainage Sump leaks to soil Soil Contamination 3 2 3 18 3 2 Y EPI-008Machinery Glycol Liquid Waste 4 4 1 16 2 3 Y EPI-021Machinery Oil Leaks/Spills Oily Waste Water 4 4 1 16 2 2 Y EPI-020

Parking Lot Automotive fuel, oil,or antifreeze leaks Soil Contamination 2 4 2 16 2 1 Y Planning

Asbestos Materials Disturbance Air or Water Release 5 3 1 15 2 2 Y EPI-022

Environmental Significance of Impact

Break Time 15 Minutes


Supporting the ProgramInformation Session



186

Agenda



Training

Annual Audits

187


188


Procedures must exist for emergency and accident situations, and how to prevent environmental impacts.

Emergency preparedness and response procedures must be revised as appropriate after emergency situations.

Procedures must be periodically tested where applicable.



189


Plan for and respond to potential accidents and emergency situations

Emergency Evacuation Plan

Severe Weather Plan

Tornado Warning Plan

Note: Incorporate PIPP, SPCC, SWPPP, etc.

190


.establish and maintain documented procedures

Operations related to significant aspects must be monitored.

Progress toward achievement of objectives and target must be monitored.

Monitoring and measurement devices must be calibrated and maintained with records retained.

Compliance with relevant environmental legislation and regulations must be evaluated.

191


Monitor key characteristics of processes

Track performance

Calibrate and maintain monitoring equipment

Evaluate compliance with environmental regulations

Documented procedures

Note: Coordinate with permit requirements



192

Monitor and Measure

WHY?

gauge your environmental performance

analyze root causes of problems

identify areas where corrective action is needed

improve performance & increase efficiency

If you cant measure it, you cant manage it.

WHAT?

Monitor key characteristics of operations/activities that can have significant impact

track performance on goals

calibrate & maintain monitoring equipment

evaluate compliance status

193

Monitoring and MeasurementIdentify monitoring needed for significant aspects

Effluent/Emission Monitoring

Regulatory required routinely reported to

agencies

material usage logs (CAA) waste characterization

Verify operating criteria/limits

Identify monitoring requirements

id organizational responsibility

id data and/or records needed

id internal processes needed

Trends in Achieving Objectives

Identify measures for selected goals/objectives

id organizational responsibility

id data and/or records needed

System for tracking & reporting progress

Can accounting help? Take action on data results

to improve performance

194

P3 SOLID WASTE

0

50

100

150

200

250

Q4 ' 99 Jan-00Feb-00Mar-00Apr-00 May-00

Jun-00 Jul-00 Aug-00

Sep-00

Oct-00 Nov-00

Dec-00

YEAR 2000 (MONTHS)

SOLI

D W

ASTE

,CU.

M.,

KK54

11

0.000

0.500

1.000

1.500

2.000

2.500

3.000

SOLI

D W

ASTE

,CU.

M. /

KK5

411 SOLID WASTE, cu.m.

KK5411

Solid Waste, Cu.M./KK5411(actual)Solid Waste, Cu.M./KK5411(target)



195

Compliance Evaluation

RCRA Inspection

Fire Extinguisher Inspections

Facility Compliance Audit

SARA Reporting Schedule

196

4.5.3 Non Conformance and Corrective and Preventative Action

...establish and maintain procedures for defining responsibilityand authority for handling and investigating nonconformance, taking action to mitigate impacts caused and for initiating and completing corrective and preventative action.

Corrective action shall be appropriate to the magnitude of problems encountered.

Implement and record any changes in procedures resulting from corrective or preventative action.

Use existing Root Cause process, such as 8D, 5P

Complete a Corrective Action Request (CAR)

197

A. Audited Area/Department:

Audit Date:Auditee(s):

Auditor(s):Date:C. Root CauseAnalysis:

B. Description of Non-Conformance:

Audit Criteria:Applicable ISO 14001 Element:D. Corrective Action:

Date of Implementation: E. Preventative Action:

Date of Implementation:F. Verification:

Date of Verification:Auditor (signed): Date:



198

Nonconformance and Corrective/Preventative Action

Ways to identify EMS Nonconformances

Audit Monitoring Employee Suggestions

Other Sources

Corrective ActionProcess

Management Review

199

4.5.4 Records

establish and maintain procedures for the identification, maintenance and disposition of environmental records.

Records shall be legible, identifiable and traceable. Retention times shall be established and recorded.

Records shall be maintained to demonstrate conformance to ISO 14001.

200

4.5.5 Internal Audit

EMS audits must be conducted to:

Determine if the EMS:

Conforms to the EMS plan.

Has been properly implemented and maintained.

Provide information to management.

Audits must be based on environmental importance and past audit results.

Audit scope, frequency, methods, reporting and responsibilities must be documented.



201

Reasons to Audit

Ensure compliance with environmental policies

Measure effectiveness of systems, including personnel

Maximize relationships

Identify weakness

Provide information

Promote intra-organization understanding

Contribute to technology & process improvement sharing

Reduce interested party complaints

202

Internal Audit Objectives

Determine compliance of the organizations environmental management system to defined requirements (desk audit):

ISO 14001

interested party

Local or corporate

Regulatory Determine system effectiveness

Provide for continual improvement

203

Audit Life Cycle (Process Flow)

Audit Process

Audit Team Selected

Team Prepares Audit

Checklist

Opening Meeting with Dept./Mgt.

Team

Trained Auditors

A

Conduct Audit

Assessment

Compile Preliminary

Audit Findings

Perform Verification Activities

Corrective Action

Developed

Prepare and Distribute

Report

Closing Meeting with Dept./Mgt.

Team

Audit Closed

Verify Corrective

Action

A



204

EMS Internal Audit Plan

Company/dept. Plan for Internal EMS Auditfor year:

Form No.Date:

Team/personresponsible

Months

Area/procedure to be audited JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC

Week no. of planned environmental audit Environmental audit completed Follow-up on corrective actions Date: Signature: Position:

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Management must conduct scheduled reviews of the EMS.

The review must ensure that necessary information is provided to management.

Management must review the EMS for changes related to:

EMS audit results.

Changing circumstances.

Continual improvement.

206

Management Review Is the EMS Program effective in

achieving

environmental policy commitments?

the objectives and performance measures?

Is the EMS Program adequate in terms of:

- Identifying Significant Environmental Aspects and Impacts?

- Resource Allocation?

- Information Systems?

- Staff Expertise?

- Procedural Requirements?

Are the Objectives and Performance Measures or EMS System suitable in terms of:

Environmental Impacts and Current Conditions?

Concerns of Stakeholders?

Current and Future Regulatory Requirements?

Business Interests; Technological Capability?

Internal Organizational or Process Changes?

Should additional internal performance measures be established?

Recommended Revisions to:

Environmental Policy and Commitments?

Objectives and Performance Measures?

Elements of EMS?



207

Steps to Implementing

ExecutiveManagementCommitment

Select a GuidanceTeam or Champion

Develop an ActionPlan

BudgetResponsibility MatrixMilestone Schedule

Conduct InitialEnvironmental Review

A

START

208

Steps to Implementing

Build Project Team

Involve Employees

Train Procedure Writers

Prepare Procedures

Pollution Prevention

Train Employees &Start Using EMS

DocumentedProcedures

Train InternalAuditors

A

B

209

Registration Process

On-Site EMSReadiness Review

Yes

No

Registration Audit

RegistrationDetermination

Correct anyDeficiencies

Surveillance Audits

Pass

Conditional

B

END

Fail

On-SiteAssessment1-4 (auditor)

days


days


days



210

What ISO 14001 is not!

Focused strictly on regulatory compliance

A process wherein you immediately address every single potential environmental impact

A performance standard

An occupational health and safety standard

211

ISO 14000 - Lite?

Will your organization benefit by an EMS? Do you already have building blocks of an EMS? Will management commit the resources to ISO 14000? Do you need formal registration? Now or later?

212




213

ISO 14001 Implementation Schedule

ID Task Name Duration1 ISO 14001 Gap Analysis 1 day2 ISO 14001 Implementation 275 days3 Project Kickoff Meeting 6 days4 Project Planning/Facilitation 6 days5 Assign Management Representative 1 day6 Assign Steering Committee 1 day7 Environmental Aspects 105 days8 Legal and Other Requirements 39 days9 Review Environmental Policy 28 days10 Objectives and Targets 84 days11 Environmental Programs 21.47 days12 EMS Manual/Documentation 70 days13 Organize Vs. QS-9000 22 days14 Inventory Existing Procedures 1 day15 Review EMS Operational Procedures 69 days16 Review Updated Quality Manual 62 days17 Training on Operational Controls 8 days18 Internal Auditor Training (Classroom) 1 day19 Internal Audit (Hands-on) 1 day20 Corrective Action 11 days21 Project Review/Status 1 day

100%

100%100%100%100%

64%97%

8/158/22

88%23%

67%70%

20%11%

0

Jun Jul Aug Sep Oct Nov Dec Jan Febr 3rd Quarter 4th Quarter 1st Quarter

Atta

chm

ent

214

ISO 14001 Implementation Schedule

Task Duration Task DurationISO 14001 Gap Analysis 1 day Review Updated Quality Manual 62 daysISO 14001 Implementation 275 days Training on Operational Controls 8 daysProject Kickoff Meeting 6 days Internal Auditor Training (Classroom) 1 dayProject Planning/Facilitation 6 days Internal Audit (Hands-on) 1 dayAssign Management Representative 1 day Corrective Action 11 daysAssign Steering Committee 1 day Project Review/Status 1 dayEnvironmental Aspects 105 days General Awareness Training 4 daysLegal and Other Requirements 39 days Internal Audit (off-site review) 4 daysReview Environmental Policy 28 days Corrective Action (off-site review) 16 daysObjectives and Targets 84 days Management Review 1 dayEnvironmental Programs 21 days Pre-registration Audit 2 daysEMS Manual/Documentation 70 days Corrective Action 8 daysOrganize Vs. QS-9000 22 days Registration Audit 3 daysInventory Existing Procedures 1 day ISO 14001 Registration 1 dayReview EMS Operational Procedures 69 days

Total Above 14 months

Atta

chm

ent

215

Costs of ISO 14001 Implementation

Gap Analysis $2,500 - $3,000

Implementation $20K - $30K

Internal 1,500 hrs = $60,000

Registration $12K - $15K

Gap Analysis $2,500 - $3,000

Implementation $35K - $45K

500 hrs = $20,000

Registration $12K - $15K

Facilitation Full Implementation

Note: Rough cost for facility of approximately 200 employees



216

Implementation Costs

From: Environmental Management System Demonstration Project, NSF International 1996

NEW

217

CertificatedEntity:

Number ofEmployees

Initial Assessment(Man days)

Annual surveillancevisits (Man days)

Total

(IAFGuide toISO/IECGuide

62)

On-siteminm(IAF

Guide toISO/IECGuide

62)

Total

(IAFGuide toISO/IECGuide

62)

On-siteminm

(IAF Guideto ISO/IECGuide 62)

Less than 5 2 1 1 0,55-9 2,5 1,5 1 0,5

10-19 3 2 1 120-29 4 2,5 1,5 130-59 6 4,5 2 1

60-100 7 5 2 1,5100-250 8 6 2,5 2250-500 10 7 3 2

Registration Costs

218

Training



219

4.4.2 Training Awareness and Competency

The organization shall identify training needs.

It shall establish and maintain procedures to make its employees at each relevant level aware of

- importance of conformance with the policy and procedures and with EMS requirements;

- significant impacts, actual or potential, of their work activities and benefits of improved personal performance;

- their roles and responsibilities in achieving conformance to policy, procedures and EMS, including emergency preparedness and response requirements.

- Consequences of departure from operating procedures

Personnel performing tasks that can have a significant impact shall be competent on basis of education, training or experience.

220

Training Needs Assessment

Steering Team Procedures Internal Auditors Employee Overviews

221

Training Topic Trai

ning

In

terv

al

All E

mpl

oyee

s

Prod

uctio

n Em

ploy

ees

Mai

nten

ance

Em

ploy

ees

Sala

ried

and

Non-

Pr

oduc

tion

Empl

oyee

s

Mat

eria

l Ha

ndle

rs

EMS Awareness I YR XHaz Com xEWI-01 Empty Aerosol Can xEWI-02 Empty Drum Handling xEWI-03 Spill Clean-up xEWI-04 Waste SegregationEWI-05 Haz Waste ManifestingEWI-06 Waste Water TreatmentEWI-07 Solid Waste QWI-01 Preventative Maintenance xInternal Auditor TrainingForklift Training x

EMS Training Matrix


ASTI Environmental 1.800.

ISO 14001-2004 Handoutv2

Documents

Transcript of ISO 14001-2004 Handoutv2