Integrate ISO 14001 with Existing procedures

Much of what an organization must do in an ISO 14001 EMS is probably already being done. No organization can operate without some environmental programs in place. These programs may need modification to comply with the ISO 14001 standard, but they serve as a good starting point to begin construction of an ISO compliant EMS. In fact, a good way to look at your EMS Manual is to view it as a road map. It will tell people where to find programs the organization uses to handle environmental concerns such as: wastewater systems operational manuals, air permit operating requirements, hazardous wastes handling procedures, materials purchasing requirements, and so forth.

A well-conceived ISO 14001 EMS will use existing environmental programs and procedures as a foundation. It will also include the business management practices of the company wherever possible. An example of this would be tying environmental impacts of raw materials purchases into an existing procedure to review raw materials specifications for engineering requirements and consistency. Many firms already have such procedures in place.

Other types of program integration may include integrating cost accounting practices with environmental operational practices. Many organizations cannot actually determine where their environmental dollars go. As a result, they cannot identify opportunities for financial improvement in environmental practices. Without such information, the environmental management of an organization is difficult. If management cannot see any cost benefit in environmental decision making, the managers usually take the least costly option. Activitybased costing allows a more comprehensive understanding of how environmental expenses are accrued by process and product rather than by facility or region. Then process control and product design can be reviewed to see if costs associated with their environmental impacts can be minimized. This is a good example of what ISO 14001 hopes to accomplish–good financial management leading to better environmental control.

Initial Review Of Gap Analysis In ISO 14001

A fundamental concept of the ISO 14001 EMS Standard is continual improvement of environmental performance. Before you can plan for improvement, you must first determine the current state of the organization’s environmental programs.

The initial review or gap analysis is, in itself, a microcosm of a well-organized approach to the entire ISO 14001 EMS development process. Each specification of the standard must be reviewed, including policy, legal requirements, training, objectives and targets, operational control systems, document control, auditing, management review, and corrective action.

The review should take into account the culture, products, marketing strategies, and other specifics of the organization. In all cases, consideration should be given to the full range of operating conditions, including possible incidents and emergency situations that may be encountered.

The ability of suppliers and subcontractors to comply with the Organization’s EMS program and applicable regulatory requirements should also be evaluated. It is strongly recommended that the initial review consider energy use, financial accounting, and information systems so that these issues may be integrated into the EMS program.

To effectively begin the Initial Review, several things must happen. First, Management should issue a company-wide announcement of intent and endorsement. This should include estimates of the time required to complete the Initial Review, and time required to complete the entire project. Second, the project leader should be identified and vested with ample authority for completion of the project.

The Initial Review is a review of all pertinent documents, from which an accurate plan is designed for the EMS Gap Analysis.

All information from the review, including deviation from regulatory requirements and adverse impacts on the environment, should be identified along with policies, programs, procedures, training and work instructions, and operational controls.

A portion of the project team should begin to assemble a registry of appropriate regulations identified during the Initial Review. All pertinent national, state, local and self-subscribed requirements should be assembled. They should be compared with identified environmental impacts.

An Initial Review is also important in ensuring that EMS design is compatible with all current organizational management structures and operations wherever possible. This is especially important where the EMS interfaces with the site’s existing health and safety, accounting, computer systems, purchasing, energy utilization and other management programs. The focus will be to achieve operational efficiencies that ensure environmental improvements and maximize cost reductions.

Initial Review outputs will be:

· An EMS Gap Analysis Design that details where existing environmental management procedures must be further investigated to determine conformance with the Standard.

· A review of the site’s overall environmental management strengths/weaknesses.

· A schedule of events for the Gap Analysis.

The gap analysis allows for a quick but comprehensive assessment of the facility’s existing environmental management practices and procedures, and compares them

with the requirements of the Standard. To perform the Gap Analysis, a standard template tailored for that specific purpose is used. The template is a questionnaire with a three way scoring system, which develops a final rating of the current programs of the site as they compare with the sections of the Standard. The score from this questionnaire and investigative template identifies which areas of the EMS might be enhanced to improve environmental performance and comply with the Standard.

Based on the results of the Gap Analysis, the project schedule and design may require modifications. Modification should precede further systems development. Using the results of the Gap Analysis, the EMS developmental process can now begin.

This may involve modifying existing procedures, adapting other business procedures such as those designed for health and safety, accounting, or risk management to environmental utilization. At certain points, new procedures will be required.

Prior to embarking on EMS development, always remember that the more flexible your EMS is, the easier it will be to implement and the more flexible it will be in the future.

EMS AUDITING CONCEPTS AND ISO 14000

The Environmental Management System (EMS) audit is based on the generic concept of auditing. Simply put, an audit, any audit, is the comparison of actual conditions to expected conditions, and a determination as to whether one is in conformance or not in conformance. This is the same philosophy used to perform financial, quality, regulatory compliance, and systems audits. It is prudent to first review what the common elements are in order to better understand why audits are different.

There are several definitions of audit components that are common to any type of audit. ISO 14001 defines these terms for EMS audits, but they apply in other cases also. As a matter of fact, the ISO committee decided not to create auditing standards for other types of audits, such as compliance audits, although it was originally considered. The main reason for deleting the work items was because the concepts and processes defined in 14011, originally intended for EMS audits, were generic enough to be applied “as is” to other types of audits.

An audit is fundamentally a comparison of audit evidence to audit criteria to determine findings. The evidence is the objective information collected through interviews, visual reconnaissance, and documentation review. The audit criteria are the expectations or “rules” of how conditions should be. It is the criteria that distinguish one audit from the next. For example, in compliance auditing, the criteria are the regulations. With an EMS audit, the criteria would be the description of the expected system elements. In this case, the EMS criteria would be that described in ISO 14001, the specification standard.

When evidence is compared to criteria, one can determine whether the audited entity does or does not conform. This determination is a finding, and a finding can either be one of conformance, or non-conformance. Therefore, an audit will always produce findings, even if what is being audited is in full conformance with criteria.

Other key definitions to be aware of with auditing are: objectives, scope, auditee, client, and auditor. The audit objective(s) is simply why you are conducting an audit; usually the reason is to demonstrate conformance to stated criteria. The audit scope is what entity is being audited, and can be a company, a site, or unit within a site or company.

In the ISO 14000 realm, there is a clear distinction between the auditee and client. The auditee is the entity being audited. The client is the party commissioning the audit. For example, a client can be the customer, and the auditee a supplier to that customer. In ISO 14000, this distinction is important because the client sets the scope, objectives, and plan for an audit, not the auditee, although it is expected the auditee will be involved and cooperate.

The auditor is the one actually collecting evidence and determining findings. The auditor can be comprised of several individuals on a team. There are requirements in ISO 14001 that state that those performing functions within the EMS, such as the auditors, be qualified in their tasks. This means the auditors must have received training in EMS auditing. However, there may be audit team members who do not have the training, but are on the team because of some unique expertise, such as process, language, or regulatory knowledge.

The Difference Between Compliance Auditing and Systems Auditing In ISO 14001

Often however, there is confusion between regulatory compliance auditing and EMS auditing. This is because there are many elements of regulatory compliance that overlap with the EMS. Recall that the criteria in a compliance audit are the applicable regulations, whereas the criteria in an EMS audit would be ISO 14001. But does not ISO 14001 address compliance? The answer is yes, but from a system standpoint, not performance.

In other words, the standard requires that certain procedures exist regarding identification of legal and other requirements, that periodic compliance assessments be performed, that legal requirements be considered in setting objectives and targets, and that there be a commitment to compliance. However, actually being in compliance is a performance issue, and out of the purview of ISO 14001.

Of course, a system that is constantly out of compliance or does not identify and initiate action to correct noncompliances, will eventually fail due to system failure. The subtle, yet important point is that during an EMS audit, identified regulatory noncompliances are relevant only to the extent that they reflect a potential system problem. The finding therefore is not that the site is out of compliance with a given regulation, but that the noncompliance means some EMS element is not conformed to. For example, a regulatory noncompliance can be related to a problem with training, recordkeeping, or monitoring and measurement.

The EMS auditor is not to do a compliance audit as part of the EMS audit. If, as part of the statistical sampling to verify EMS element requirements, the auditor identifies a regulatory noncompliance, he or she treats it as any other evidence.

This point has been difficult to accept, especially in U.S. industry because of our long history of regulatory enforcement. The EMS auditor needs to constantly remember that compliance auditing is being done separately as part of the EMS requirements itself (4.5.1, paragraph 3) and to stay focused on the criteria at hand – ISO 14001 and the site’s EMS. There may be legal requirements regarding noncompliances encountered during the EMS audit, but this should be decided and addressed in the audit plan.

In summary, the goal of the compliance audit is to verify compliance with regulations, whereas the EMS audit’s goal is to verify that the EMS conforms to planned arrangements, including ISO 14001.

ISO 14001 Standard & Environmental Issues

ISO 14001 Standard & Environmental Issues

ISO 14001 is a systematic tool that enables an organization in any market sector to focus on their situation, identify the relevant environmental issues and to lessen their impact to their benefit and the environment. It is part of a global response to the recognition that we are damaging the environment in which we all live. The cause and effect of the foremost world environmental issues, which are all due to mankind, are generally too vast and too intangible for us to grasp and so the slightly cliché expression ‘think global, act local’ is very relevant. Once the EMS is implemented and to become registered to ISO 14001, the external auditor will assess your EMS in two separate stages, on site. The first stage to understand your business activities and determine formal readiness for assessment and the second to check practical compliance with ISO 14001. After registration he will return at regular intervals every year to verify continual improvement and regulatory compliance, against your set objectives and your EMS. The external auditor should be seen as a wise friend, not a policeman. He should certainly explain his findings and assist the company to find ISO 14001 registration is not a cure for all environmental problems but I hope I’ve demonstrated that it is a worthwhile, if not essential business initiative that could enable your management to better manage your business, gain commercial advantage and minimize its environmental impact.

Environmental Policy In iSO 14001 Standard

Environmental Policy In ISO 14001 Standard

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.

Changes to ISO 9000

Changes in titles
The titles have changed – moving away from models to requirements andguidance.

Changes in scope
The scope of the standard has changed from those activities that impact theproduct to embrace all activities
in an organization that serve the satisfaction of customers. This leaves little if any activity of an organization that would be
outside the scope of the quality management system.

Changes in structure

By far the most significant change is the change in structure – away from 20elements to a model based on five elements.
The ISO 9000:2000 family of standard is based on a process model.
Changes in content
The content has changed from 20 elements organized on the basis of whatcould go wrong to four groups of requirements
that focus on elements of process management. It is however, not the fact that the original elements have
been placed onto a new structure, but that the principles upon which the standard has been based have changed.
Changes in intent
The intent of ISO 9001 has changed from a model for quality assurance to a setof requirements for an effective quality
management. The standard is now based on eight management principles not on what requirements were
necessary to prevent failures that experience had shown led to poor product quality.
The forgotten standard ISO 8402 is brought into the family of ISO 9000 thus making it more likely that people will use it.
However, in the author ’s opinion, all three standards should have been merged into one standard thus
ensuring that everyone who possessed the requirements also possessed the concepts, terminology and
guidelines to refer to as necessary.
Much damage can be done when the requirements of ISO 9000 are taken out
of context, taken in isolation and taken literally. ISO 9000 is not a productstandard therefore it is subject to
interpretation as appropriate to the conditions
in which it is being used. Whatever the initial understanding of a requirement
of ISO 9001 might be, the intent is that:
organizations design and manage their processes effectively to achievecorporate objectives, not that they create functional
silos that compete for resources.
organizations choose the right things to do based on an objective analysis of
the environment in which they operate, not slavishly follow procedures that
serve no practical purpose.
management create an environment in which people will be motivated, not
create bureaucratic systems of documentation that stifle initiative and
creativity.
Changes in language
The language in ISO 9000 has changed to reflect pressure from the usercommunity for a user-friendlier standard.
In some cases the changes are insignificant but in others the changes have a wider impact as indicated
below:
Subcontractor has changed to supplier and supplier changed to organizationso that there is now a supply
chain represented by customer – organization – supplier.
In ISO 9001 the term customer is used but in ISO 9004 the term, interested party
is used in order to embrace customers, employees, investors and otherparties.
Executive management has been changed to Top Management indicating thatwhen the standard uses
the term management responsibility it is the people who direct the organization that should address
these requirements.
Specified requirements have changed to customer and regulatory require-ments or product requirements
depending on the context.
Procedures have not exactly been changed to processes but presented in adifferent way that makes
procedures only one element of managing an effective process. Procedures have lost their dominance in
the standard to be replaced by the concept of managed processes.
Changes in requirement
ISO 9001 still contains 136 ‘shall’ statements, 2 less than the 1994 version so insome respects it is no different.
There were roughly 323 requirements in ISO 9001:1994 (Hoyle, David, 1996)6 . In ISO 9001:2000 there are roughly 250
requirements. This is still too many especially if we are trying to get across the
fundamental requirements of the standard. The following summarizes the
requirement of ISO 9001 at two levels: firstly as a single requirement, secondly
as a series of generic requirements.