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ISO14001 Seminar-Michigan Chamber of Commerce

March 14, 2007

Environmental Management Systems

March 2007

Welcome

Investigations, Compliance,
Remediation, and Restoration

Presenters
Thomas Wackerman, ASTI

Investigations, Compliance,
Remediation, and Restoration

ASTI Environmental 1.800.395.ASTI

ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007

Overview
Background
Benefits
The ISO14001 Elements
Break

Implementation and Management


Baseline Audits
Gap Assessments
Lunch

Implementation and Management


EMS Requirements
Aspects
Legal Issues
Planning
Break

ASTI Environmental 1.800.395.ASTI

ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007

Supporting the Program


Implementing Programs
Scheduling and Costs
Training
Annual Audits
Questions and Answers
Adjourn

Other Materials
Binder
Exercises

Indicates new or
modified materials

Attachment

Indicates materials are


reproduced full size in
the Attachment

NEW

Web Resources
www.asti-env.com/isochamber.html

Investigations, Compliance,
Remediation, and Restoration

ASTI Environmental 1.800.395.ASTI

ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007

Introduction
Information Session

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

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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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ASTI Environmental 1.800.395.ASTI

ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
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?
An organizational structure, incorporating
responsibilities, practices, procedures, processes and
resources, for implementing and maintaining
environmental management
- ISO 14001:1996
..part of an organizations management system used to
develop and implement its environmental policy and
manage its environmental aspects.

- ISO 14001:2004(E)
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What is ISO 14001?


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
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ASTI Environmental 1.800.395.ASTI

ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
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

Act

Check

Do

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ASTI Environmental 1.800.395.ASTI

ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
PDCA
Establish the objectives and
processes necessary to deliver
results in accordance with the
organizations environmental policy.

Plan

Act

Check

Do

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NEW

PDCA
Implement the process.

Plan

Act

Check

Do

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NEW

PDCA
Monitor and measure processes
against environmental policy,
objectives, targets, legal and other
requirements and report results.

Plan

Act

Check

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Do

ASTI Environmental 1.800.395.ASTI

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ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
PDCA
Take actions to continually
improve performance of the
environmental system.

Plan

Act

Check

Do

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NEW

The Five Principles

Management Review

Environmental Policy

Planning

Checking &
Corrective Action

Implementation &
Operation

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Milestones

Continual Improvement

Identify Requirements

Implement EMS

Participate in
Registration Audit

Maintenance, Training,
Awareness, Competence

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ASTI Environmental 1.800.395.ASTI

ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007

Overview Of ISO14001:2004(E)
Information Session

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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ASTI Environmental 1.800.395.ASTI

ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
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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ISO 14000 Series of Standards


14001:1996
14004:1996
14010:1996
14011:1996
14012:1996
14020:1998
14021:1999

Attachment

14024:1999
14031:1999
14032:1999
14040:1997
14041:1998
14042/43
14050:1998
14061:1998

Environmental Management Systems - Specification with Guidance for Use


Environmental Management Systems - General Guidelines on Principles,
Systems and Supporting Techniques
Guidelines for Environmental Auditing - General Principles
Guidelines for Environmental Auditing - Audit Procedures - Auditing of
Environmental Management Systems
Guidelines for Environmental Auditing - Qualification Criteria for
Environmental Auditors
Environmental Labels and Declarations - General Principles
Environmental Labels and Declarations - Self-declared Environmental Claims
(Type II Environmental Labeling)
Environmental Labels and Declarations - Type I Environmental Labeling Principles and Procedures
Environmental Management - Environmental Performance Evaluation - Guidelines
Environmental Management Examples of Environmental Performance Evaluation (EPE)
Environmental Management - Life Cycle Assessment Principles and Framework
Environmental Management - Life Cycle Assessment - Goal and Scope
Definition and Inventory Analysis
Environmental Management - Life Cycle Assessment - Life Cycle Impact
Assessment/Interpretation
Environmental Management - Vocabulary
Information to Assist Forestry Organizations in the Use of Environmental
Management System Standards ISO 14001and ISO 14004
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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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ASTI Environmental 1.800.395.ASTI

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ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
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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ASTI Environmental 1.800.395.ASTI

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ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
Drivers
International Trade
Customers
Marketing
Investment

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NEW
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ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007

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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-certified


through 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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ASTI Environmental 1.800.395.ASTI

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ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
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

Environmental Policy

Adequate Resources

Adequate Resources

Structure & Responsibility

Structure & Responsibility

Training

Training

System Documentation

System Documentation

Process Controls

Operational Controls

System Audits

System Audits

Management Review

Management Review

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ASTI Environmental 1.800.395.ASTI

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ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007

Attachment

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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Attachment

Combining QMS and EMS

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ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007

The ISO14001 Elements

ISO 14001 Guidance Document

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Brief Overview
Environmental
Management Systems (EMS)
and
ISO 14001

Edited for 14001:2004

ISO 14001 Guidance Document

46

Organization
1 Scope
2 Normative References
3 Terms and Definitions
4 Environmental Management Systems

Requirements

NEW
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ISO 14001 Guidance Document

ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
Organization
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

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ISO 14001 Guidance Document

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1 Scope
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.

ISO 14001 Guidance Document

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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.

NEW
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ISO 14001 Guidance Document

ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
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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ISO 14001 Guidance Document

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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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ISO 14001 Guidance Document

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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

NEW
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ISO 14001 Guidance Document

ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
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 objectives

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ISO 14001 Guidance Document

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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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ISO 14001 Guidance Document

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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.

NEW
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ISO 14001 Guidance Document

ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
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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ISO 14001 Guidance Document

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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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ISO 14001 Guidance Document

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4.2 Environmental Policy


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.

NEW

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ISO 14001 Guidance Document

ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
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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ISO 14001 Guidance Document

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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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ISO 14001 Guidance Document

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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.

NEW
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ISO 14001 Guidance Document

ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
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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ISO 14001 Guidance Document

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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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ISO 14001 Guidance Document

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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.
NEW
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ISO 14001 Guidance Document

ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
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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ISO 14001 Guidance Document

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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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ISO 14001 Guidance Document

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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

NEW
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ISO 14001 Guidance Document

ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
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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ISO 14001 Guidance Document

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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.

ISO 14001 Guidance Document

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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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ISO 14001 Guidance Document

ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
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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ISO 14001 Guidance Document

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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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ISO 14001 Guidance Document

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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.

NEW
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ISO 14001 Guidance Document

ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
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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4.6 Management Review


Management must conduct scheduled reviews of the

EMS.
The review must ensure that necessary information is

provided to management.

ISO 14001 Guidance Document

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4.6 Management Review


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

NEW
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ISO 14001 Guidance Document

ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
Appendix A: Guidance
Appendix B: ISO14001:2004 v
ISO9001:2001

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Break Time 15 Minutes

Investigations, Compliance,
Remediation, and Restoration

Implementation and Management


Information Session

ASTI Environmental 1.800.395.ASTI

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ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
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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ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
Audits Legal Considerations
 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

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Audits Legal Considerations


 Why Perform an Audit?

 Compliance Auditing as Part of EMS, including


 Baseline Audit/Gap Analysis

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Audits Legal Considerations


 Compliance Audit Project Team and Functions
 Corporate Officer
 Environmental Manager
 Legal Counsel (In-house vs. Outside Lawyer)
 Environmental Consultant/Technical

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ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
Audits Legal Considerations
 Consultant Retention
 Selection and Contracting
 Scope of Work

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Audits Legal Considerations


 Protecting the Confidentiality of Audits
 Attorney-Client Privilege
 Anticipation of Litigation Work-Product
 Self-Audit Privilege?
 Address with ISO Registrar

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Audits Legal Considerations


 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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ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
Audits Legal Considerations
 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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Audits Legal Considerations


 Michigan Environmental Audit Privilege and Immunity

Legislation - Contd.

 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 noncompliance.
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Audits Legal Considerations


 Michigan Environmental Audit Privilege and Immunity

Legislation - Contd.

 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 noncompliance 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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Audits Legal Considerations
 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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Audits Legal Considerations


EPA remains staunchly opposed to state audit laws
from a policy perspective, which continues to cause a
serious chilling effect on companies undertaking selfaudits. 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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Audits Legal Considerations


 MDEQ-EAD Administers State Part 148 Audit

Program

 Further information:

http://www.michigan.gov/deq/0,1607,7-1353307_3666_4135---,00.html

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March 14, 2007
Audits Legal Considerations
 REPORTING OBLIGATIONS FROM AUDITS
 Spills/Accidental Releases
 Unpermitted Discharges
 Permit Exceedances

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Audits Legal Considerations


 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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Audits Legal Considerations


 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
Environmental Policy
Planning
Implementation & Operation
Checking & Corrective Action
Management Review.

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ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
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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March 14, 2007
Example Audit Evaluation

Attachment

Question
Has generator generated more
than 100 kilograms (220
pounds) of hazardous waste per
month, or accumulated more
than 1,000 kilograms? (if YES,
comply with SQG or LQG
requirements, see SQG or LQG
checklists)

Have all wastes been classified,


e.g., hazardous or nonhazardous? 40 CFR 262.11

Have there been any State or


Federal agency inspections
since the previous audit?

Are there any citations, notices


of violation, or notices of noncompliance that have not been
resolved by the facility? (if yes,
explain)

Response
(Y, N, DK, n/a)

Finding

Source

Recommendation

Comments

105

Baseline Audits
Consider all media for actual or potential impacts.
Air
Water
Soil

106

Baseline Audits

Identify aspects and the impacts on the environment.

107

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ISO14001 Seminar-Michigan Chamber of Commerce


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Aspects
Waste generation
Wastewater discharge
Stormwater discharge
Air emissions
Point source
Fugitive
Automotive

108

Aspects (Cont.)
Chemical operations
Water use operations
Energy use operations
Use of natural resources
Out-dated product
Product disposal

109

Objectives
Reduce effluents and emissions
Increase material and product recycling and use of

recycled products
Reduce unplanned releases
Reduce energy consumption

110

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ISO14001 Seminar-Michigan Chamber of Commerce


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Gap Assessments

111

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.

112

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.

113

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Gap Analysis (Cont.)
Provisions for EMS maintenance.
Review of modified activities, products &

services.
Provisions to amend EMS.

114

Lunch 60 Minutes

Investigations, Compliance,
Remediation, and Restoration

Implementation and Management


Information Session

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ISO14001 Seminar-Michigan Chamber of Commerce


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Agenda

EMS Requirements
Aspects
Legal Issues
Planning

117

EMS Requirements

118

Executive Management Commitment

Key ingredient to success

119

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ISO14001 Seminar-Michigan Chamber of Commerce


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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
120

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.

121

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
122

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ISO14001 Seminar-Michigan Chamber of Commerce


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ISO 14001 Percent Complete Table
FOR:

Company

ELEMENT ELEMENT DESCRIPTION

POINTS
RECEIVED

ENVIRONMENTAL POLICY

ENVIRONMENTAL ASPECTS

10

20%

LEGAL & OTHER


REQUIREMENTS
OBJECTIVES & TARGETS
ENVIRO. MGT. PROGRAMS

11

14

79%

7
7

10
8

70%
88%

38%

16

25%

STRUCTURE &
RESPONSIBILITY
TRAINING AWARENESS &
COMPETENCE
COMMUNICATION

14

EMS DOCUMENTATION

25%

10

DOCUMENT CONTROL

14

43%

11

OPERATIONAL CONTROL

10

50%

12

EMERGENCY PREP. &


RESPONSE
MONITORING & MEASUREMENT

75%

50%

15

NON-CONF, CORRECTIVE &


PREVENT. ACTION
RECORDS

10

70%

16

EMS AUDIT

50%

17

MANAGEMENT REVIEW

12

25%

GRAND TOTAL

94

4
5
6
7

13
14

13

POINTS
PERCENT
POSSIBLE COMPLETE

30

43%

43%

75%

190

PERCENT COMPLETE

49%
123

IS O 1 4 0 0 1 P e rc e n t C o m p le te G ra p h

43%

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

20%

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

79%

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

70%

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

88%

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

38%

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 &
COM PE T ENCE

25%
43%

C O M M U N IC A T IO N

25%

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

43%

DO CUM ENT CONT ROL

50%

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

75%

E M ERG ENCY P REP. & RESP ONSE

75%

M O N I T 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

50%
70%

RECORDS

50%

E M S A U D IT

25%

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

124

0%

20%

40%

60%

80%

100%

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.

125

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ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
Assign EMS Management Representative
and Steering Team:

General Manager

EMS Management
Representative

Engineering

QS-9000

Human Resources

Maintenence

Training

126

The 14001 EMS Element Cycle


Start

4.6 Management
Review

4.5 Checking/Corrective
Action
4.5.1 Monitoring and Measurement

4.2 Environmental
Policy

Continual
Improvement

4.3 Planning
4.3.1 Environmental Aspects
4.3.2 Legal/Other Requirements
4.3.3 Objectives and Targets

4.5.2 Nonconformance and


Corrective & Preventive Action

4.3.4 Environmental Management


Program

4.5.3 Records
4.5.4 EMS Audits

Attachment

4.4 Implementation
4.4.1 Structure and Responsibility
4.4.2 Training, Awareness, Competence
4.4.3 Communication
4.4.4 EMS Documentation
4.4.5 Document Control
4.4.6 Operational Control
4.4.7 Emergency Preparedness/Response

4.2 Environmental Policy


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

EMS

3. Continual Improvement

Policy

128

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ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
Honda Environmental Policy

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 following
principles:

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.
129

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

130

131

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ISO14001 Seminar-Michigan Chamber of Commerce


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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.


132

Aspects

133

4.3.1 Environmental Aspects


..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
134

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ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
4.3.1 Environmental Aspects
..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
135

4.3.1 Environmental Aspects


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
136

Identifying and Evaluating Environmental


Aspects/Impacts
Identify
Environmental
Aspect
Aspect is
Therefore
Significant

Determine Impact
to Environment

Yes

Is Impact
Significant?

Control, Study, or Improve Aspect via


Environmental Management Programs
and Operational Controls

No

Stop
(Record)

137

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ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
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

138

Identification of Aspects and Evaluation of Impacts


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)

139

Environmental Aspects

OUTPUT

INPUTS
Chemicals
Transportation
Oil/Fuels
Electricity
Water
Raw Materials/
Consumables
Other Inputs

FACILITY

Air Emissions

Hazardous
Waste

Spill
Potential

Groundwater
Wetlands, etc.

ASTI Environmental 1.800.395.ASTI

Water
Discharges

Solid Waste
Transportation
Property
Other Outputs

47

ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
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

141

Identification of Aspects and Evaluation of Impacts


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.

142

Examples From Steps 1-3

Activity, Product
or Service
1 - Paint Line
2 - Welding
New or Modified
Construction
Scrap generation

Aspect
Air Emissions
Land Use
(wetlands)
Solid Waste

Impact
Degradation of Air
Quality
Depletion of
Wetlands
Landfill Use/
Natural Resources

143

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ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
Results From Steps 1-3

Activity, Product
Aspect
Impact
or Service
Paint Line 4
Solid waste,
Landfill waste,
parts scrapped depletion of
resources
Paint Line 4
Haz waste,
Air quality,
obsolescent or resource depletion
rejected paint
Shipping
Air Emissions Human
from
health/ecology
warehouse
operations

144

Identification of Aspects and Evaluation of Impacts


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
145

Environmental Aspect Evaluation


Environmental
Description

Significance of Impact
Severity Likelihood Detection SF
Sx
Lx
Dx

Regulated
Y= x 1.5
Yes/No

Activity/Department

Aspect

Shipping

Air Emissions

54

Solid Waste

36

54

45

45

45

Paint Line 4

Paint Line 4
Paint Line 4
Paint Line 4

Paint Line 4

Tow motor operation


Scrap plastice parts
falling off paint rack
Discarded paint from
Obsolesence or
Hazardous Waste
quality
VOC from Paint
Mixing
Air Emissions
HAPS from Paint
Air Emissions
Mixing
Exposure from
coating/part
Employee Safety preparation/mixing

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ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
Environmental Aspect Evaluation
Facility Maintenance
A

Aspect
Activity
heating imbalance
fuel consumption
ventilation
fuel consumption
flourescent bulbs
special waste disposal
visual impairment
maintenance welding operatio
air quality
maintenance welding operatio

Assessment Criteria - Normal Situations


B
C

Sensitivity of the
Affected Medium
or Population
1
1

Toxicity /
Hazard
2
2

Quantity
1
1

(A+B)*(C+D)

Frequency of
Occurrence
1
1

Assessment Criteria - Abnormal or Emergency Situations


A
B
C
D

Activity
raw material storage (particul
flammable material storage
flammable material storage
flammable material storage

Aspect
surface water
air quality
health & safety
stormwater

Area Affected

IP
6
6
0
0
0

Adj. IP
9
6
0
0
0

Regulated?

Adj. IP
0
4
0
0

(A+B)*(C+D)

Relevance Frequency of
(Importance) Occurrence Unpreparedness

Regulated?
Y
N

IP
0
4
0
0

NEW

147

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

148

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

Consider
Separate
Ranking for
Normal and
Abnormal
Operations

149

ASTI Environmental 1.800.395.ASTI

NEW

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ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007

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

Investigations, Compliance,
Remediation, and Restoration

EMS Legal Requirements

151

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

152

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ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
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

153

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

154

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

155

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ISO14001 Seminar-Michigan Chamber of Commerce


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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


156

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)

157

Voluntary Environmental Requirements


U.S. EPA Project XL
MDEQ Clean Corporate Citizen (C3)
PERI Principles
CMA CARE Program
Michigan Business Pollution Prevention Partnership

(MBP3)

158

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ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
Voluntary Environmental Requirements

Customer Requirements
Lender Conditions
Industry Codes of Practice
Non-Regulatory Guidelines

159

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?

160

Aspect/Issue
Oil Leaks and
Spills
Used Oil Dry and
"Pigs"
Waste Oil

Noise
Sewer Discharge
Storage of Metal
to be Recycled
AC Refridgerants

Attachment

Disposal of
Computers and
CRT

Legal or Other Requirement


Reference
Managing Used Oil: Advice for Small
Businesses

Explanation

Compliance
Evaluation/Review
Monitor significant spill
frequency

Monitor significant spill


frequency
Ensure total volume of oil
Ensure total volume of oil remains
PART 279 (Updated 1999) remains below the threshold
STANDARDS FOR THE MANAGEMENT below the threshold for implementation
for implementation of a SPCC
OF USED OIL
of a SPCC Plan
Plan
Access to the Pump Room is restricted
Occupational noise exposure. - 1926.52
to personnel with hearing protection.
Managing Used Oil: Advice for Small
Businesses

City of Toledo
No Exposure Guidance Document and
Forms)

No permit required at this time.


Initiate CAR for the outside storage
area.

Confirm no exposure

EPA Requirements for Servicing Air


Handled by Vendor.
Conditioners and Refrigeration Equipment

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 The Management of Fluorescent Lamps


Recycled through Waste Management
and PCB Ballasts in Ohio
Bulbs
Chemical Hygiene
Occupational exposure to hazardous
Metrology Lab
chemicals in laboratories. - 1910.1450
Plan
Hazard
Communication
Hazard Communication. - 1910.1200
Program
MSDS
Hazard Communication. - 1910.1200
Requirements
Emergency Action
Emergency action plans. - 1917.30
Plan
Forklifts
Powered industrial trucks. - 1917.43

Annual Review
Annual Review
Annual Audit
Annual Review
Annual Training

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ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
Approval

Issuer

Attachment

Summary of Legal and Other Requirements


ABC Plant
ASPECT
Aboveground Storage Tanks
Aboveground Storage Tanks
CO Emissions
CO Emissions
CO Emissions
CO Emissions
CO Emissions
CO Emissions
CO Emissions
CO Emissions
CO Emissions
Electricity
Hazardous Waste
Hazardous Waste
Hazardous Waste
Hazardous Waste
Hazardous Waste
Hazardous Waste
Hazardous Waste
Hazardous Waste
Infectious Waste
Natural Gas
NOx Emissions
NOx Emissions

DEPT(S)
ALL
Plant
FAC
FAC
FAC
PA
PA
PA
PA
PL
PL
Plant
PA & PL
PA & PL
Plant
Plant
Plant
Plant
Plant
Plant
Medical
Plant
FAC
FAC

FEDERAL CITATION
40 CFR 112
40 CFR 60 Subpart Kb

STATE CITATION

OAC 3745-21-08(B)
OAC 3745-31-05
OAC 3745-31-05
OAC 3745-21-08(B)
OAC 3745-21-08(B)
OAC 3745-21-08(B)
OAC 3745-21-08(B)
OAC 3745-21-08(B)
OAC 3745-21-08(B)
40 CFR 265 Subpart BB
40 CFR 265 Subpart CC
40 CFR 260.10
40 CFR 261
40 CFR 262
40 CFR 268
40 CFR 265

OAC 3745-50-10
OAC 3745-51
OAC 3745-52
OAC 3745-59
OAC 3745-65
OAC 3745-66
OAC 3745-27
OAC 3745-23-06(B)
OAC 3745-31-05

OTHER
SPCC & SWPP Plan

& ISO 14001


ISO 14001
PTI 01-3194 & ISO 14001
PTI 01-177 & ISO 14001
PTI 01-7350 & ISO 14001
PTI 01-0362 & ISO 14001
PTI 01-2259 & ISO 14001
PTI 01-3474 & ISO 14001
PTI 01-6743 & ISO 14001
PTI 01-0512 & ISO 14001
PTI 01-0999 & ISO 14001
Energy Conservation & ISO 14001
OPFP* & ISO 14001
OPFP* & ISO 14001
OPFP* & ISO 14001
OPFP* & ISO 14001
OPFP* & ISO 14001
OPFP* & ISO 14001
OPFP* & ISO 14001
OPFP* & ISO 14001
ISO 14001
Energy Conservation & ISO 14001
PTI 01-3194 & OPFP* & ISO 14001
PTI 01-177 & ISO 14001

Planning and Documentation

163

4.3 Planning
Activities, Products or
Services (over which the
Company has control and
influence) that interact
with the environment

4.3.1
Environmental
Aspects

4.3.2
Legal & Other
Requirements

4.3.3
Objectives
& Targets

Views of
Interested
Parties

Environmental
Management
Program

164

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ISO14001 Seminar-Michigan Chamber of Commerce


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4.3 Planning

P6
Proper Planning Prevents Piss Poor Performance
SMART
Specific, Measurable, Achievable, Results

Oriented, Time Framed

165

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.

166

Issue
Press
Lubricating
Oil Use
Solid Waste

Resources

Objectives
Reduce Oil
Use

Targets
Reduce oil use by 20% by 2002

Reduce
solid waste
sent to
landfill
Conserve
Natural
Resources

Reduce solid waste disposal costs by


20% by the end of 2001

1)Reduce use of energy plant wide by


10% by 2002
2)Reduce water consumption by 20%
per by 2002

167

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ISO14001 Seminar-Michigan Chamber of Commerce


March 14, 2007
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.

168

Objectives Targets
Conserve
Identify
Resources Opportunities
for Chemical
Use
Reductions by
end of 2001

Environmental Program
1) Develop chemical use inventory for
facility. Use MSDS book as basis of
inventory. Monitor chemical usage.
2) Update MSDS book and add/remove
sheets as needed.
3) Develop and implement action plan to
dispose of or use dated chemicals.
4) Identify opportunity areas for chemical
use reduction.
Reduce
1) Evaluate electricity use facility wide.
Electricity Use
Ask utility to conduct energy audit.
by 5% per
2) Identify opportunities for electricity use
employee by
reductions. Results from energy audit.
the end of
3) Develop and implement action plan to
2004 versus
reduce energy use.
1999 energy
usage
Reduce water 1) Implement monthly water use
consumption
monitoring on a per employee basis
by 5 % per
versus 1999.
employee by 2) Identify opportunities for water use
end of 2004
reductions.
versus 1999
3) Develop and implement action plan to
usage
reduce water use.

Responsibility
EMS Steering
Committee by
10/2001

John Doe by
8/2001

John Doe by
4/2003

169

Objectives

Conserve
Resources

Targets

Environmental Program

Responsibility

Reduce fuel oil, 1) Implement monthly fuel use


monitoring on a per employee basis
gas, other
versus 1999.
heating related
medium by 5 % 2) Identify opportunities for fuel use
reductions.
per employee by
3) Develop and implement action plan
end of 2004
to reduce fuel use.
versus 1999

John Doe by
4/2003

Reduce solid
1) Develop operation controls for waste
waste to the
segregation program. Develop
landfill by 4% per
Monitoring and measurement
employee verses
metrics.
1999 by end of
2) Develop training on waste
2001 Versus
segregation operational controls.
1999
3) Train all employees on waste
segregation.

Jane Doe by
12/2000

Incorporate
EMS into APQP
by 12/2000

Amend APQP process to include


consideration of EMS in new product
and process planning.

Quality
Manager by
12/2000

170

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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 a
basis for improvement of the EMS

* Management Representative
171

EMS Responsibilities
Functions
Purchasing

Possible Roles
Develop & implement controls for chemical & other
purchases
Human
Define competency requirements & job descriptions for
Resources
EMS roles
Integrate EM into reward/discipline system
Finance
Track data on EM costs
Prepare budget for EM program
Evaluate economic feasibility of projects
Engineering/ Consider impacts of new or modified
Environmental
products/processes
Identify pollution prevention opportunity
Top
Communicate importance of EMS
Management Provide necessary resources
Track & review EMS performance
General
Knowledge of environmental aspects of their job
Associates
Support training of new employees
Know Environmental Policy

172

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 significant


aspects and record its decision.

173

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Environmental Communications Log
Date
Recd

Originator

10/20/00

USEPA Letter from


John Doe dated
10/15/00
Odor complaint call
from Jane Deer
Car paint damage
claim call from Joe
Worker

11/15/00
1/5/01

Int?

Ext?

Response Summary

Date
Closed

Prepare and mailed response letter

10/25/00

Inspected property and provided


letter response
Inspected car, provided picture
documentation

12/25/00

1/9/01

174

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

175

EMS Documentation Needs

Is it a core element of the EMS?

Can you demonstrate objective evidence of a

procedure if it is not documented?

176

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EMS Documentation
A 4-Tier System:

International
Standards
ISO 14001

Intent

Why you do it
Environmental
Policy
What you do

How you do it

Evidence of
what you do

What, when,
where & who

Procedures

How

Work Instructions

Records

177

EMS Documentation Road Map


Element
Number

4.2
4.3.1

Element/Issue

Level 1 Manual

EMS Scope

Section 4.1
Quality Manual
Section 4.1
Quality Manual

Environmental
Policy
Environmental
Aspects

4.3.2

Legal and Other


Requirements

4.3.3

Objectives and
Targets

Level 2,
Procedures

Level 3, WI

Level 4,
Forms

EP3.1-1
Environmental
Aspects
P2-1 APQP
Procedure

178

EP3.2-1 Legal
and Other
Requirements
P9-5
Environmental
/Safety
EF3.2-1, Legal
and Other
Requirements
P3-1 Contract
Review
EP3.3-1
Objectives and
Targets

4.4.5 Document Control

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)

179

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Approval

Issuer

Title
Purpose:
Scope:
Responsibilities:
Definitions:
Impelementation:
Associated Documents:
Revision
history

The following indicates the revision level date and reason for the revisions to
this document.
No.
0

Date
5/11/98

Document Number: MAP 01 69 003


Revision Number: 0
Revision Date: 5/11/98

Revision history
Document creation.

Page 1 of 1
MAP Significant Aspects procedure.doc
180

4.4.6 Operational Control

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.

181

4.4.6 Operational Control

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

182

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Activity

Painting-Dept 57
Sump tanks / pits
Painting-Dept 45
Outside equipment
storage

Environmental
Aspect
Impact

Solvent evaporation
Leaks to soil

VOC Emissions
Contaminated Soil

Solvent evaporation
VOC Emissions
Oil leaks from equip.
being stored
Storm Drain Pollution

Cost
Level Regulated Program/
Significance of Impact
Severity Likelihood Detection SF
to
of
Response
S
L
D
SxLxD Address Control Yes/No Reference
4
4

5
3

2
3

40
36

3
3

3
2

Y
Y

EPI-019
EPI-008

32

EPI-019

32

EPI-017

Machinery

Waste Coolants

Liquid Waste

30

EPI-020

Sump tanks / pits


Rust Protection-D55

Coolants & oils


Solvents in RP

Oily Waste Water


VOC Emissions

3
2

4
4

2
3

24
24

2
1

2
3

Y
Y

EPI-020
Planning

24

EPI-004

24

EPI-001
EPI-005
EPI-008

Outside Unloading
Aerosol Can
Disposal

Bulk fuel, solvent,


Potential Liquid Spills
or paint leaks
to Stormdrain
Disposal of solvents
Hazardous Liquid
and propellants
Wastes

Chip Dock Drainage


Chip Dock Drainage

Oil leakage
from trailers
Sump leaks to soil

Soil Contamination
Soil Contamination

3
3

3
2

2
3

18
18

2
3

2
2

Y
Y

Machinery

Glycol

Liquid Waste

16

Machinery

Oil Leaks/Spills
Automotive fuel, oil,
or antifreeze leaks
Disturbance

Oily Waste Water

16

EPI-020

Soil Contamination
Air or Water Release

2
5

4
3

2
1

16
15

2
2

1
2

Y
Y

Planning
EPI-022

Parking Lot
Asbestos Materials

EPI-021

Break Time 15 Minutes

Investigations, Compliance,
Remediation, and Restoration

Supporting the Program


Information Session

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Agenda

Implementing Programs
Scheduling and Costs
Training
Annual Audits

186

Implementing Programs

187

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.

188

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4.4.7 Emergency Preparedness and Response

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.

189

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.


Compliance with relevant environmental legislation

and regulations must be evaluated.

190

4.5.1 Monitoring and Measurement

Monitor key characteristics of processes

Track performance

Calibrate and maintain monitoring equipment

Evaluate compliance with environmental regulations

Documented procedures

Note: Coordinate with permit requirements

191

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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
192

Monitoring and Measurement


Identify monitoring needed for significant aspects
Trends in Achieving
Objectives

Effluent/Emission Monitoring

Regulatory required

routinely reported to
agencies

material usage logs (CAA)

waste characterization

responsibility

Verify operating criteria/limits

Identify monitoring requirements


id organizational
responsibility

id data and/or records


needed

id internal processes
needed

id organizational
id data and/or records

Identify measures for


selected goals/objectives

needed

System for tracking &


reporting progress

Take action on data results


to improve performance

Can accounting help?

193

P3 SOLID WASTE
3.000

2.500

200

2.000
150
1.500
100
1.000
50

0.500

S O LID W AS TE,CU .M . / K K 5 4 1 1

S O L ID W AS TE,CU .M ., K K 5 4 1 1

250

SOLID WASTE, cu.m.


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

0.000
Q4 ' 99 Jan-00Feb-00Mar-00Apr-00 May- Jun-00 Jul-00 Aug- Sep- Oct-00 Nov- Dec00
00
00
00
00

YEAR 2000 (MONTHS)


194

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Compliance Evaluation

RCRA Inspection
Fire Extinguisher Inspections
Facility Compliance Audit
SARA Reporting Schedule

195

4.5.3 Non Conformance and Corrective and


Preventative Action

...establish and maintain procedures for defining responsibility


and 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)

196

A. Audited Area/Department:
Audit Date:
Auditee(s):
B. Description of NonConformance:

Auditor(s):
Date:
C. Root Cause
Analysis:

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:
197

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Nonconformance and Corrective/Preventative Action

Ways to identify EMS Nonconformances

Audit

Employee
Suggestions

Monitoring

Other
Sources

Corrective Action
Process
Management
Review

198

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.

199

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.


200

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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

201

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

202

Audit Life Cycle (Process Flow)

Trained
Auditors

Audit
Process

Audit Team
Selected

Compile
Preliminary
Audit Findings

Opening
Meeting with
Dept./Mgt.
Team

Team
Prepares Audit
Checklist

Closing
Meeting with
Dept./Mgt.
Team

Prepare and
Distribute
Report

Conduct
Audit
Assessment

Corrective
Action
Developed

Perform
Verification
Activities

Verify
Corrective
Action

Audit
Closed

203

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EMS Internal Audit Plan
Company/dept.

Attachment

Area/procedure to be audited

Months
JAN

FEB

MAR

Week no. of planned environmental audit


Date:

Form No.
Date:

Plan for Internal EMS Audit


for year:
Team/person
responsible

Signature:

APR

MAY

JUN

JUL

AUG

Environmental audit completed

SEP

OCT

NOV

DEC

Follow-up on corrective actions

Position:

204

4.6 Management Review

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.
205

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:

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?

Identifying Significant
Environmental Aspects and
Impacts?

Internal Organizational or
Process Changes?

Resource Allocation?

Information Systems?

Should additional internal


performance measures be
established?

Staff Expertise?

Procedural Requirements?

Recommended Revisions to:

Environmental Policy and


Commitments?

Objectives and
Performance Measures?

Elements of EMS?

206

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Steps to Implementing
START
Executive
Management
Commitment
Select a Guidance
Team or Champion

Conduct Initial
Environmental Review
Budget
Responsibility Matrix
Milestone Schedule

Develop an Action
Plan

A
207

Steps to Implementing
A
Build Project
Team

Involve Employees

Train Procedure Writers


Pollution Prevention
Prepare
Procedures

Documented
Procedures

Train Employees &


Start Using EMS

Train Internal
Auditors

B
208

Registration Process
B
On-Site
Assessment
1-4 (auditor)
days

On-Site EMS
Readiness Review

On-Site
Assessment
2-8 (auditor)
days

Registration Audit

No

Yes

Correct any
Deficiencies

Fail
Conditional

Pass

Registration
Determination
On-Site
Assessment
1-2 (auditor)
days

Surveillance Audits

END
209

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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

210

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?

211

Scheduling and Costs

212

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ISO 14001 Implementation Schedule
ID
1

Task Name
ISO 14001 Gap Analysis

r
3rd Quarter
4th Quarter
1st Quarter
Duration
Jun Jul Aug Sep Oct Nov Dec Jan Feb
1 day 100%

ISO 14001 Implementation

275 days

Project Kickoff Meeting


Project Planning/Facilitation

Assign Management Representative

Attachment

6 days

Assign Steering Committee

100%

6 days

100%

1 day

100%

1 day

100%

Environmental Aspects

Legal and Other Requirements

39 days

Review Environmental Policy

28 days

10

Objectives and Targets

11

Environmental Programs

12

EMS Manual/Documentation

64%

105 days

84 days

97%
8/15
8/22
88%

21.47 days
23%

70 days
67%

13

Organize Vs. QS-9000

22 days

14

Inventory Existing Procedures

15

Review EMS Operational Procedures

69 days

20%

16

Review Updated Quality Manual

62 days

11%

1 day

17

Training on Operational Controls

18

Internal Auditor Training (Classroom)

1 day

19

Internal Audit (Hands-on)

1 day

20

Corrective Action

21

Project Review/Status

70%

8 days

11 days
1 day

213

ISO 14001 Implementation Schedule

Task
ISO 14001 Gap Analysis
ISO 14001 Implementation
Project Kickoff Meeting
Project Planning/Facilitation
Assign Management Representative
Assign Steering Committee
Environmental Aspects
Legal and Other Requirements
Review Environmental Policy
Objectives and Targets
Environmental Programs
EMS Manual/Documentation
Organize Vs. QS-9000
Inventory Existing Procedures
Review EMS Operational Procedures

Duration
1 day
275 days
6 days
6 days
1 day
1 day
105 days
39 days
28 days
84 days
21 days
70 days
22 days
1 day
69 days

Task
Review Updated Quality Manual
Training on Operational Controls
Internal Auditor Training (Classroom)
Internal Audit (Hands-on)
Corrective Action
Project Review/Status
General Awareness Training
Internal Audit (off-site review)
Corrective Action (off-site review)
Management Review
Pre-registration Audit
Corrective Action
Registration Audit
ISO 14001 Registration

14 months

Attachment

Total Above

Duration
62 days
8 days
1 day
1 day
11 days
1 day
4 days
4 days
16 days
1 day
2 days
8 days
3 days
1 day

214

Costs of ISO 14001 Implementation


Full Implementation

Facilitation

Gap Analysis $2,500 - $3,000

Gap Analysis $2,500 - $3,000

Implementation $20K - $30K

Implementation $35K - $45K

Internal 1,500 hrs = $60,000

500 hrs = $20,000

Registration $12K - $15K

Registration $12K - $15K

Note: Rough cost for facility of approximately 200 employees

215

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Implementation Costs

From: Environmental Management System Demonstration Project, NSF International 1996

NEW
216

Registration Costs
Certificated Initial Assessment Annual surveillance
(Man days)
visits (Man days)
Entity:
Number of
Employees
Total
On-site
Total
On-site
minm
minm
(IAF
(IAF
(IAF
(IAF Guide
Guide to Guide to Guide to to ISO/IEC
ISO/IEC ISO/IEC ISO/IEC Guide 62)
Guide
Guide
Guide
62)
62)
62)
Less than 5
2
1
1
0,5
5-9
2,5
1,5
1
0,5
10-19
3
2
1
1
20-29
4
2,5
1,5
1
30-59
6
4,5
2
1
60-100
7
5
2
1,5
100-250
8
6
2,5
2
250-500
10
7
3
2
217

Training

218

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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.

219

Training Needs Assessment

Steering Team
Procedures
Internal Auditors
Employee Overviews
220

M aterial
Handlers

Salaried and
NonProduction
Em ployees

M aintenance
Em ployees

I YR

Production
Em ployees

All Em ployees

Training Topic
EMS Awareness
Haz Com
EWI-01 Empty Aerosol Can
EWI-02 Empty Drum Handling
EWI-03 Spill Clean-up
EWI-04 Waste Segregation
EWI-05 Haz Waste Manifesting
EWI-06 Waste Water Treatment
EWI-07 Solid Waste
QWI-01 Preventative Maintenance
Internal Auditor Training
Forklift Training

T raining
Interval

EMS Training Matrix

x
x
x
x

x
x
221

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Training needs Matrix Environmental Courses
Course

Employees Requiring Training

Source of
Training

Duration
(Hours)

Frequency

A/C Refrigeration Servicing A/C Maintenance


(Stationary)
HAZWOPER: First
Security
Responder
Environmental Awareness (Bulk Materials, HAZWOPER 1st
Responder Awareness, Integrated
Emergency Response and Spill
Contingency Plan, Prevention
Plan, Waste Management, Energy
Management, Asbestos
Management)
Incident Command Training Security and Supervisors

Once, each new


maintenance staff
Annual

Fire Brigade Training

Emergency Response Team

RCRA Awareness Training


EMS Lead Auditor Training

Waste Management Coordinator


Environmental Coordinator, Lead
Internal Auditor
All employees & full time on-site
contractors
Employees and full time on-site
contractors whose work requires
knowledge of the document

For all new team


members
Annual
Initially

EMS Awareness Training


EMS Document Training
(see also "Applicable
Procedures by
Department"
EMS Implementation
Training
EMS Internal Auditor
Training

Every other year

Annual

Initially, New hires and


as necessary
Initially, New hires and
when document
changes occur

Cross Functional Team & EMR

Initially

EMS Internal Auditors

Initially and New


Auditors

222

Training
What are the needs of the organization at all relevant

levels.
Establish procedures for identifying training need.
Require contractors to document their employees

have required training.


Establish training skills of all necessary personnel and

complete gap analysis for EMS requirements.

223

Training
Design
Delivery
Documentation

224

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Design
Training needs analysis
Task analysis
Learning objectives
Testing & evaluation
Program validation

225

Design
Training needs analysis
Organization structure
Determine how training can improve
Safety
Effectiveness
Efficiency
Meet legal aspects

226

Design
Task analysis
Logical sequence
Total objective
Appropriate examples
Include all steps
Identify problems
Prerequisite skills or knowledge

227

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Design
Learning objectives
What should trainee be able to do as a result of

training
Specific
Trainees viewpoint
Observable
Measurable
LEARNING IS MEASURED BY A CHANGE IN

BEHAVIOR
228

Design
Testing & evaluation
Pre-testing
Entering competency
Formative testing
Identify strengths/weaknesses
Check for understanding

229

Design
Testing & evaluation
Summation testing
Evaluate achievement
Feedback
Evaluate effectiveness/efficiency of program

230

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Design
Program validation
Report results to ISO 14000 committee
Build on successful training
Evaluate trainees performance
Evaluation trainer & workshop effectiveness
Improve training program

231

Delivery
Adult learners
Learning styles
Instructional strategies
Instructional media
Delivery techniques

232

Delivery
Adult learners what to know
Why is the training important?
How can I apply what Ive learned?
What is the program outline?
What do I need to know?

233

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Delivery Retention Rates
Reading

10%

Hearing

20%

Seeing

30%

Seeing & hearing

50%

Saying

70%

Seeing & Doing

90%

234

Delivery
Learning styles
Passive
Active
Passive learning styles
Reading
Watching
Hearing
Observing
235

Delivery
Active learning styles
Participating
Role-playing
Field trips
Hands on
Practice scenarios
Making presentations

236

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Delivery
Instructional strategies
Lecture
Guided discussion
Demonstration
Scenarios
Role playing
Individual

237

Delivery
Instructional strategies
Strategy must match objective
Strategy must match learning styles
Multiple strategies should be used

238

Documentation
Plant Files
Verification of attendance
Verification of competency
Personnel Files
Verification of attendance
Verification of competency
Certifications

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Annual Reviews

240

Annual Reviews

Documents (permits, plans, procedures & training)


All that are required are completed.
Documents can be located.
Documents are at appropriate locations.
Documents are periodically reviewed for

adequacy, revisions, and required review periods.

241

Annual Reviews

Documents (permits, plans, procedures &

training)
Obsolete documents are removed.
Documents are legible, dated and readily

identifiable.
Documents are orderly and retained for

required periods.

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Annual Reviews
Emergency spill response
Post Certification reviews
Maintain a written program
Periodically test procedures
Review and revise following any responses.
Prepare for the obvious as well as the potential
Be proactive
Checking and corrective action.
243

Compliance and Legal Requirements


15 Minute Exercise

Environmental Legal Requirements


Identify legal and other requirements that are directly

applicable to the companys activities, products and


services.
Track changes in legal requirements.

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Aspects
Media
Regulations
Permits/Plans/Procedures
Regulatory reports/documentation
Certifications
Training

246

Media
Air
Chemicals
Transportation
Water
Waste

247

Regulations
CAAA-Clean Air Act Amendments 40 CFR 50-80
EPCRA-Emergency Planning and Community Right-

to-Know Act 40 CFR 372


HazCom-Hazard Communication 29 CFR

1910.1200
HAZWOPER-Hazardous Waste Operations and

Emergency Response 29 CFR 1910.120

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Regulations
CWA-Clean Water Act 40 CFR 110-140
RCRA-Resource Conservation and Recovery Act

40 CFR 260-270
HMTA-Hazardous Materials Transportation Act 49

CFR 171-180
TSCA-Toxic Substance Control Act 40 CFR 700-

760

249

Permits/Plans/Procedures
PTI-Permit to Install
ROP-Renewable Operating Permit
RMP-Risk Management Plan 40 CFR 68.112(r)
HazCom Program-29 CFR 1910.1200

250

Permits/Plans/Procedures
Emergency response-40 CFR 26.4
SWPPP-Storm Water Pollution Prevention Plan
SPCC-Spill Prevention Control and Countermeasures

40 CFR 112
PIPP-Pollution Incident Prevention Plan Act 451, Part

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Permits/Plans/Procedures
PPP (Washtenaw Co.)-Pollution Prevention Plan
NPDES-National Pollution Discharge and Elimination

System
SC/SPP-Slug Control/Spill Prevention Plan
WAP-Waste Analysis Plan

252

Reports
MAERS-Michigan Air Emissions Reporting System

March 15
Tier II-EPCRA March 1
Form R-EPCRA July 1
AWR/CMR- State of Michigan August 15
Biennial-RCRA March 1 every even year.

253

Documentation
Air permits/exemptions
Waste characterization
Manifest
LDRs
Waste minimization

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Certification
P.E.-SPCC
SWO-SWPPP
WWO-NPDES

255

Training
RMP-Initial and every 3 years
HazCom-Initial
HAZWOPER-Initial and annual
Emergency Response-Initial

256

Training
SPCC-Initial and process change
SWPPP-Initial and process change
HMTA-Initial and job change
RCRA-Initial and annual

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Summary
Information Session

ISO 14000 is
A series of international standards for building,
implementing, and maintaining an EMS.

259

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

261

Milestones
1. Understand the 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,

Registrar, etc.)
7. Develop an environmental policy
262

Milestones
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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Company Objectives

Regulatory Requirements

Environmental Policy

Operations

Legal Considerations

The 14001 EMS Element Cycle


Start

4.6 Management
Review

4.2 Environmental
Policy

4.5 Checking/Corrective
Action

Continual
Improvement

4.5.1 Monitoring and Measurement

4.3 Planning
4.3.1 Environmental Aspects
4.3.2 Legal/Other Requirements
4.3.3 Objectives and Targets

4.5.2 Nonconformance and


Corrective & Preventive Action

4.3.4 Environmental Management


Program

4.5.3 Records
4.5.4 EMS Audits

4.4 Implementation
4.4.1 Structure and Responsibility
4.4.2 Training, Awareness, Competence
4.4.3 Communication
4.4.4 EMS Documentation
4.4.5 Document Control
4.4.6 Operational Control
4.4.7 Emergency Preparedness/Response

Environmental Aspects

OUTPUT

INPUTS
Chemicals
Transportation
Oil/Fuels
Electricity
Water
Raw Materials/
Consumables
Other Inputs

FACILITY

Air Emissions

Hazardous
Waste

Spill
Potential

Groundwater
Wetlands, etc.

Water
Discharges

Solid Waste
Transportation
Property
Other Outputs

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EMS Documentation
A 4-Tier System:

International
Standards
ISO 14001

Intent

Why you do it
Environmental
Policy
What you do

How you do it

Evidence of
what you do

Procedures

What, when,
where & who

Work Instructions

How

Records

267

References and Additional Information


Information Session

Environmental Auditing and ISO 14000


Environmental Management Systems References
Environmental Management Systems: ISO Standard

14000, BNA International Environment Reporter


ASTM Provisional Standard PS 12-95 (Evaluation of

Organizations EMS)
ASTM Provisional Standard PS 11095

(Environmental Regulatory Compliance Audits)

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Environmental Auditing and ISO 14000


Environmental Management Systems References
Michigan Environmental Audit Privilege and Immunity

Act (NREPA Part 148)


Attorney General Opinion on NREPA Part 148

(6/11/97)
U.S. EPA Incentives for Self-Policing Policy, 60 Fed.

Reg. 66706 (12/22/95)


MDEQ Air Quality Division Part 14 Rules, Clean

Corporate Citizen Program

270

Environmental Auditing and ISO 14000


Environmental Management Systems References
ANSI/RAB

11 West 42nd St., New York, NY 10036


(212) 642-4900
http://www.ansi.org

271

Environmental Auditing and ISO 14000


Environmental Management Systems References
NSF

2100 Commonwealth Blvd., Suite 100,


Ann Arbor, MI 48105
(888) NSF-9000
http://www.nsf.org, or www.nsf-isr.org

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Environmental Auditing and ISO 14000


Environmental Management Systems References
ASTM

100 Barr Harbor Dr., West Conshohocken,


19428-2959

PA

(610) 832-9585
http://www.astm.org
U.S. EPA

http://www.es.epa.gov/elp/

273

Questions?

Investigations, Compliance,
Remediation, and Restoration

Thank You

Investigations, Compliance,
Remediation, and Restoration

ASTI Environmental 1.800.395.ASTI

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