Evaluation of Compliance In ISO 14001 Standards

Evaluation of Compliance In ISO 14001 Standards

The requirement to establish a procedure for periodically evaluating compliance with applicable legal and other requirements falls short of specifically requiring regulatory compliance audits but, in fact, a system of regular regulatory compliance audits may be the most practical means for meeting this requirement of the standard. In the U.S., determination of whether to conduct a compliance audit will be governed in part by the particular jurisdiction’s approach to allowing a legal privilege for the self-assessment audit.

Evaluation vs. Audit – The difference between an evaluation and audit can only be determined by looking outside of ISO 14001. Consulting a dictionary reveals that an evaluation involves a determination of value or worth and that an audit is an examination of accounts done by persons appointed for the purpose. A better definition `is the more specific ISO 19011:2002, Guidelines for Quality and/or Environmental Management Systems Auditing, which defines an audit as a “systematic, independent, and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which the audit criteria are fulfilled.” Many organizations do not have a system for evaluating regulatory compliance other than their own records and the inspections of regulatory officials. This lack of a verification system can be a risky way to operate. Reports of enforcement actions and consent agreements show that many organizations are blindsided by rogue employees who violate rules and falsify documents to cover up environmental misdeeds. Although ISO 14001 does not prescribe a specific approach to evaluation of regulatory compliance, organizations should consider methods for going beyond verification of records by collecting and evaluating physical evidence.

ISO 14001 Standards Certification

ISO 14001 Standards Certification

ISO 14001 sets out a system that can be audited and certified. In many cases, it is the issue of certification that is critical or controversial and is at the heart of the discussion about the trade implications.

The standard allows for “self-certification,” a declaration by an enterprise that it conforms toISO 14001. There is considerable skepticism as to whether this approach would be widely accepted, especially when certification has legal or commercial consequences. At the same time, obtaining certification can entail significant costs, and there are issues relating to the international acceptance of national certification that may make it particularly difficult for companies in some countries to achieve credible certification at a reasonable cost. For firms concerned about having certification that carries real credibility, the costs of bringing in international auditors are typically quite high, partly because the number of internationally recognized firms of certifiers is limited at present.

The issue of accreditation of certifiers is becoming increasingly important as the demand increases.

The ISO has outlined procedures for accreditation and certification (Guides 61 and 62), and a formal body, QSAR, has been established to operationalize the process. At the same time, a number of established national accreditation bodies heavily involved in ISO have set up the informal International Accreditation Forum (IAF) to examine mechanisms for achieving international reciprocity through multilateral agreements (MLAs). However, these systems are in the early stages, and many enterprises continue to use the established international certifiers, even at additional cost, because of lack of confidence in the acceptability of local certifiers.

Given the variability in the design of individual EMS and the substantial costs of the ISO 14000 certification process, there is a growing tendency for large companies that are implementing EMS approaches to pause before taking this last step. After implementing an EMS and confirming that the enterprise is broadly in conformance with ISO 14001, it is becoming routine to carry out a “gap analysis” to determine exactly what further actions would be required to achieve certification and to examine the benefits and costs of bringing in third-party certifiers.

Certification means that a qualified body (an “accredited certifier”) has inspected the EMS system that has been put in place and has made a formal declaration that the system is consistent with the requirements of ISO 14001.Countries that have adopted ISO 14001 as a national standard can accredit qualified companies as certifiers, and this will satisfy national legal or contractual requirements. However, the fundamental purpose of ISO is to achieve consistency internationally. If certificates from certain countries or agencies are not fully accepted or are regarded as “second class,” the goal will not have been achieved. It is probable that the international marketplace will eventually put a real commercial value on high-quality certificates, but this level of sophistication and discrimination has not yet been achieved. It is essential to the ultimate success of the whole system that there be a mechanism to ensure that certification in any one country has credibility and acceptability elsewhere.

Environmental Aspects In ISO 14001 Standards EMS

Environmental Aspects In ISO 14001 Standards EMS

First make lists of the environmental aspects (issues) that are relevant

to the business. The environmental review mentioned earlier should

provide most of this information and the Annex to ISO 14001 provides

guidance on the format for doing this.

Consider the inputs, outputs and processes/activities of the business in

relation to;

a) emissions to air

b) releases to water

c) waste management

d) contamination of land

e) use of raw materials and natural resources

f) other local environmental and community issues

Consider both site (direct) and offsite (ie. indirect) aspects that you

control or have influence over (such as suppliers) and in relation to

normal operations, shut-down and start-up conditions and reasonably

foreseeable and emergencies situations

A simple written procedure is then required to determine which of the

aspects identified are really or probably significant (important) and should

therefore be managed by the EMS. This process which is

similar to health and safety risk assessment ranks the aspects by order

of importance and the significant aspects identified are then the core

of the environmental management system.

There are various methods of determining significance but most are

based on the principle of attributing a relative value for the

environmental hazard or potential to cause harm (eg. on a scale of 1-

5) and the risk or likelihood of occurrence (eg. on a scale of 1-5). The

relative significance is then determined by multiplying the hazard by

the risk. (eg. max score of 25). An arbitrary but cautious threshold

value is then set above which environmental aspects are considered to

be significant. This threshold can be determined by a common sense

consideration of the aspects identified.

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.

Role of Governments in ISO 14001 Standards

Role of Governments in ISO 14001 Standards

Although ISO 14001 is a set of voluntary standards that individual companies may or may not choose to adopt, governments can clearly have a role in providing information, establishing the necessary framework and infrastructure, and, in some cases, helping companies to develop the
basic capabilities to adopt ISO 14001. There are wo particular areas in which government action would be useful:
(a) providing information on he sectors and markets where ISO 14001 certification s a significant issue and assisting sector rganizations to develop appropriate responses, and
(b) helping to establish a certification framework, ased on strengthening national standards organizations and encouraging competitive private sector provision of auditing and certification
services. At present, the World Bank is having discussions with a number of countries about how assistance could be provided with these issues.

Governments should see EMS approaches as part of a broad environmental strategy that includes regulatory systems, appropriate financial incentives, and encouragement of improved industrial performance. Such encouragement can really only be effective where there is cooperation at the government level between the relevant departments, including industry and trade, as well as environment. There is a growing interest in integrating environmental management issues into productivity or competitiveness centers designed to promote SME performance, but little information exists on experience to date.

Emergency Preparedness and Response In ISO 14001

Emergency Preparedness and Response In ISO 14001

Under the Emergency Preparedness and Response requirement of ISO 14001:2004 (§4.4.7), the organization is required to establish procedures for identifying the potential for and responding to emergency situations and accidents that can have an impact on the environment.

Identification of Potential Emergency and Accident Situations – Experience indicates that organizations infrequently have a preexisting procedure for identifying potential emergency and accident situations.
The norm is to establish emergency and accident responses for a variety of emergency and accident situations irrespective of the potential for their occurrence. But ISO 14001 is specific about requiring a procedure to identify the potential for emergency situations and accidents. Adhering to the requirement of the procedure is a valuable exercise that helps organizations identify weaknesses in their own emergency planning and to plan for that which is most likely to occur.
Because many environmental impacts of an emergency or accident situation are secondary in nature, it appears that all potential emergency or accident situations need to be identified before a determination of environmental impacts can be made. An organization that attempts to identify potential emergency or accident situations based on a review of its environmental aspects would likely miss the environmental impact potential of, say, an automobile accident.

There are five steps implied by the emergency preparedness and response requirement:

1) Identify the potential for emergency situations and accidents of all kinds;
2) Paying particular attention to the potential environmental impacts of accidents and emergency situations, identify how the organization can prevent and mitigate associated adverse environmental impacts;
3) Determine how the organization and its employees should respond to emergency situations and accidents;
4) Periodically simulate emergency situations to test response capabilities; and,
5) Review and revise procedures based on experience derived from actual and simulated emergency situations and accidents.

Accident and Emergency Situation Identification – In order to identify potential for and responding to emergency situations and accidents, the organization should develop a procedure for systematically identifying accident and emergency situations, evaluating their probability of occurrence, their likely consequences, and their severity.
Organizations often engage risk management specialists to assist in the identification of potential emergency or accident situations that could lead to human injury, environmental damage, or economic loss. While many checklists are available to facilitate this kind of evaluation, there is virtually no substitute for physical evaluation of facilities by knowledgeable personnel, whether employees or outside professionals.

Emergency Response Procedures – The organization is required to develop procedures for responding to emergency situations and accidents when they occur. Typically, response procedures include identifying public emergency response agencies and their capabilities, identifying individuals within the organization who are trained and able to provide assistance in emergencies, establishing an emergency communications network, and providing emergency lighting, signage, and equipment. Because Emergency Response Procedures are based on identified potential emergency situations and accidents specific to the organization, the emergency response plan will be unique for each organization.

Periodic Testing – The value of conducting emergency response exercises lies not only with simulating situations that could occur but also in identifying flaws in the response plan. Practice drills can be the most effective test of the system to give employees, emergency response personnel, and management the opportunity to walk through the plan and gain familiarity with its procedures. While a full-dress response exercise is valuable, testing of procedures can be effectively done on much smaller scales and still provide the benefits of testing. Above all, the organization should not let the impracticality of a full-dress exercise keep it from testing sub elements of the emergency response plan.

Review and Revise – ISO 14001 calls for continual improvement of the EMS. Periodically reviewing and revising emergency response plans based on the experience gained from the occurrence of emergency situations or accidents or in testing response plans is an example of continual improvement.

Written Response Plans – Many written emergency response plans are too cumbersome to be of value in an emergency situation – their value depends entirely upon previous training of persons who will be called upon to execute them. Yet, many organizations fail to provide the emergency response training necessary to make the plans functional.
Keeping in mind that even the simplest, most direct emergency response plan requires training for effective implementation, an alternative for organizations to consider is establishment of abbreviated, readily available Immediate Response Directions established for each kind of potential emergency situation or accident. Such an emergency response plan might consist of a laminated card prepared for each potential emergency situation or accident and providing specific responsibilities and associated actions for employees and visitors, supervisors, emergency coordinators, and emergency directors.

Five Steps to Implementing ISO 14001:2004

ISO 14001 provides a logical, common-sense approach for

businesses to adopt. To start it is recommended to carry out an

environmental review of the business and the Annex to the Standard

provides guidance on the approach required. The Standard then

requires a management system to be developed that addresses the

key environmental issues that were identified by the review as being

relevant to the business, through a rational programme of control and

continual improvement.

There are five key steps to ISO 14001 EMS implementation, and

subsequent operation which are clearly laid out in just three pages of

text.

The five key steps are:

1. Environmental Policy

2. Planning

3. Implementation and Operation

4. Checking and Corrective Action

5. Management Review

Step 1. Environmental Policy

The company or organisation must write an environmental policy

statement which is relevant to the business activities and approved by

top management. Their full commitment is essential if environmental

management is to work. The ISO 14001 Standard clearly sets out

what to cover in the policy. Often a one page document is sufficient.

Produce a first issue and expect to amend it several times before

assessment and registration as knowledge grows in the company.

Step 2. Planning

Plan what the EMS is to address.

Environmental aspects

First make lists of the environmental aspects (issues) that are relevant

to the business. The environmental review mentioned earlier should

provide most of this information and the Annex to ISO 14001 provides

guidance on the format for doing this.

Consider the inputs, outputs and processes/activities of the business in

relation to;

a) emissions to air

b) releases to water

c) waste management

d) contamination of land

e) use of raw materials and natural resources

f) other local environmental and community issues

Consider both site (direct) and offsite (ie. indirect) aspects that you

control or have influence over (such as suppliers) and in relation to

normal operations, shut-down and start-up conditions and reasonably

foreseeable and emergencies situations.

A simple written procedure is then required to determine which of the

aspects identified are really or probably significant (important) and

training needs, outline the key stages of the project and dates that will

lead to the target achievement).

Gradually apply environmental management programme thinking to

such things as the introduction of new products, new or improved

processes and other key activities of the business. In particular,

ensure existing projects become environmental management projects

where there is a significant environmental impact involved, so that the

EMS becomes company wide. This is a frequent oversight found

during ISO 14001 assessments. The EMS must cover the whole

business – like a net thrown over the whole business and for example

including such things as engineering and maintenance

Step 3. Implementation and Operation

Structure and responsibility

Appoint one or more people, depending on the size of the business, to

have authority and responsibility for implementing and maintaining the

EMS and provide sufficient resources. (It’s worth monitoring costs

carefully and benchmarking these against key consumption figures so

that improvements delivered by the EMS become apparent).

Training, awareness and competence

Implement a procedure to provide environmental training appropriate

to identified needs for management, the general workforce, project

teams and key plant operators. This can have far reaching benefits

on employee motivation. The workforce is usually very supportive of

moves to achieve genuine environmental improvement. Every

company has its share of cynics but even some of these can be won

over with time. Training will vary from a general briefing for the

workforce to detailed environmental auditor training.

Communication

Implement procedures to establish a system of internal and external

communication to receive environmental information and respond to it

and to circulate new information to people that need to know. This will

include: new legislation, information from suppliers, customers and

neighbours and communications both with employees and for

employees about progress with the EMS. This process can often

generate worthwhile ideas from employees themselves for future

environmental improvements.

Environmental management system documentation

The EMS itself needs to be documented with a manual, procedures

and work instructions but keep it brief and simple. The Standard

clearly states where procedures are required. Eleven system

procedures are required to maintain the EMS, plus operating work

instructions but if you already have ISO 9000, this will cover most of six

of the procedures required and a quality system can certainly be

expanded to cover ISO 14001 as well. Cross reference the EMS

manual to other environmental and quality documents to link the EMS

and to integrate it with existing business practices.

Operational control

Implement additional operating procedures (work instructions) to

control the identified significant (important) aspects of production

processes and other activities. Some of these will already exist but

may need a ‘bit of polish’. Don’t forget significant aspects that relate to

goods and services from suppliers and contractors.

Emergency preparedness and response

Implement procedures to address reasonably foreseeable

emergencies and to minimise their impact should they occur. (eg. Fire,

major spillages of hazardous materials, explosion risks etc.)

Step 4. Checking and Corrective Action

Monitoring and measurement

Implement procedures to monitor and measure the progress of

projects against the targets which have been set, the performance of

processes against the written criteria using calibrated equipment (verify

monitoring records) and regularly check (audit) the company’s

compliance with legislation that has been identified as relevant to your

business. The most effective way of doing this is through regular

progress meetings.

Nonconformance and corrective and preventive action

Implement procedures to enable appropriate corrective and

subsequent preventive action to be taken where breaches of the EMS

occur (eg. process control problems, delays in project process, noncompliance

with legislation, incidents etc.).

Records

Implement procedures to keep records generated by the

environmental management system. The Annex to the Standard

suggests those that are likely to be required.

Environmental management system audit

Implement a procedure to carry out audits of each part of the EMS and

company activities and operations to verify both compliance with the

EMS and with ISO 14001. Audit results must be reported to top

management . A typical audit cycle is one year but more critical

activities will require auditing more frequently.

Step 5. Management Review

At regular intervals (typically annual), top management must conduct

through meetings and record minutes of a review of the EMS, to

determine that it is still appropriate and effective or to make changes

where necessary. Top management will need to consider audit

results, project progress, changing circumstances and the requirement

of ISO 14001 for continual improvement, through setting and achieving

further environmental targets.

Role of Governments in ISO 14001 Standards

Role of Governments in ISO 14001 Standards

Although ISO 14001 is a set of voluntary standards that individual companies may or may not choose to adopt, governments can clearly have a role in providing information, establishing the necessary framework and infrastructure, and, in some cases, helping companies to develop the
basic capabilities to adopt ISO 14001. There are wo particular areas in which government action would be useful:
(a) providing information on he sectors and markets where ISO 14001 certification s a significant issue and assisting sector rganizations to develop appropriate responses, and
(b) helping to establish a certification framework, ased on strengthening national standards organizations and encouraging competitive private sector provision of auditing and certification
services. At present, the World Bank is having discussions with a number of countries about how assistance could be provided with these issues.

Governments should see EMS approaches as part of a broad environmental strategy that includes regulatory systems, appropriate financial incentives, and encouragement of improved industrial performance. Such encouragement can really only be effective where there is cooperation at the government level between the relevant departments, including industry and trade, as well as environment. There is a growing interest in integrating environmental management issues into productivity or competitiveness centers designed to promote SME performance, but little information exists on experience to date.