EMS Auditing Overview

8/10/2019 EMS Auditing Overview

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ISO 14001

Environmental Management System (EMS)Auditing Overview for the

Department of Interior

Linda Baetz, EMS-LA and Jim Wood, P.E., EMS-LA

U.S. Army Center for Health Promotion and Preventive Medicine


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Discussion Topics

EMS RequirementBackground

Preparing for External EMS Audits

Joint Compliance/EMS Audits Evolution of Army EMS Auditing

Army EMS AuditsLessons

Learned Army EMS Auditor Training

(External & Internal Auditors)


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EMS Requirement - Background

EO 13148Required Federal

Agencies to implement EMS

EO 13423Reinforced EMS

implementation at all appropriate

levels and EMS use as primary

management approach

OFEE EO 13423 Instructions

Requires external audits [initial &

follow-up (3-yr cycle)]


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(Phase I - Document Review Phase)

Understand ISO 14001 Standard

Review EMS Gap Analysis

Results (and determine if gaps

resolved)

Understand your DOI-Agency

specific EMS Manual/procedures

Review of DOI-Agency specific

EMS Manual/procedures (ISO

14001 conformance)


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(Phase IIInternal Audit Phase)

Conduct an internal EMS audit

(using trained auditors)

Implement corrective/preventive

action(s) based on internal audit

Understand the different types of

nonconformance (i.e., major vs.

minor) and the level of resources &

commitment for resolution


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(Common Nonconformance Issues)

ISO 14001, 4.1 (General

Requirements)

Has the scope of the EMS been

documented?


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ISO 14001, 4.2 (Environmental

Policy)

Does the policy address all of the

mandatory commitments?

Has the policy been communicated

to all persons working on behalf

of the organization (i.e.,

contractors & subcontractors)?


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ISO 14001, 4.3.1 (Environmental

Aspects)

Are the aspects documented and

kept up-to-date?

Are the significant aspects taken

into account in the EMS?


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ISO 14001, 4.3.2 (Legal and Other

Requirements)

Do the legal and other

requirements apply to the

environmental aspects?


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ISO 14001, 4.3.3 (Objectives,

Targets, and Programs)

Have significant environmental

aspects been considered when

establishing objectives/targets?

Do the programs designate

responsibilities, means, and

time-frames to achieve

objectives & targets?


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ISO 14001, 4.4.1 (Resources,

Roles, Responsibility and

Authority)

Has EMS Management Rep. been

appointed?

Have roles, responsibilities, and

authorities been documented

and communicated?


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ISO 14001, 4.4.2 (Competence,

Training, and Awareness)

Has competence been

determined for persons with

potential to cause significant

environ. impacts?

Are training needs identified?

Has awareness been provided to

persons working on behalf of the

organization?


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ISO 14001, 4.4.3 (Communication)

Do external communication

procedures match actual

business practices?

Has the record of decision

(regarding external communication

of significant environmental

aspects) been documented?


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ISO 14001, 4.4.4 (Documentation)

Does the EMS documentation

include all of the mandatory

requirements?


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ISO 14001, 4.4.5 (Control of

Documents)

Do procedures (e.g., approval,

review, update/re-approval,

revision, removal of obsolete

documents, etc.) match actual

business practices?

Are documents of external origin

addressed?


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ISO 14001, 4.4.6 (Operational

Control)

Have operational controls been

developed for those activities &

operations with significant

environmental aspects?

Are those operational controls

being implemented at the user

level?


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ISO 14001, 4.4.7 (Emergency

Preparedness and Response)

Are emergency preparedness &

response procedures periodically

tested (where practicable)?


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ISO 14001, 4.5.1 (Monitoring and

Measurement)

Are key characteristics of

operations (that can have

significant environmental impact)

being monitored and measured?

Are there calibration records for

any associated monitoring and

measurement equipment?


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ISO 14001, 4.5.2 (Evaluation of

Compliance)

Is there a process for the periodic

evaluation of compliance with

legal and other requirements?

Are records available of those

periodic compliance evaluations?


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ISO 14001, 4.5.3 (Nonconformity,

Corrective Action & Preventive

Action)

Do procedures also address

preventive actions?

Do procedures address corrective

& prev. action effectiveness?

Do the procedures match the

actual business practices?


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ISO 14001, 4.5.4 (Control of

Records)

Do procedures address the

retention times & disposal of

records?

Are records legible, identifiable,

and retrievable?


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ISO 14001, 4.6 (Management

Review)

Has the management review

process been implemented?

Does the management review

process incorporate all of the

required inputs?


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Joint Compliance/EMS Audits

(Different Approaches)

Army Environmental Performance

Assessment System (EPAS)

External AuditsActive

Component Installations

Concurrent Compliance/EMS

Audit

Dedicated EMS Audit Team

Separate Compliance & EMS Audit

Reports


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[Different Approaches (Cont.)]

Army EPAS External Audits

Reserve Component Installations

Installation Compliance Audit is

Conducted First

Follow-up EMS Audit (conducted

months after the compliance audit)

Root Cause Analysis (from

compliance audit) is used to

Formulate EMS Audit Plan


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(Key Points)

Compliance auditing and

conformance auditing are VERY

different skills sets

If joint compliance/EMS audits are

conducted, the audit team needs

to include dedicated EMS

auditor(s) (with no complianceaudit responsibilities)


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[Key Points (Cont.)]

EMS Lead Auditor needs to have

full responsibility for conduct of

the EMS portion of the audit (e.g.,

preparing EMS audit, briefingresults, preparing report, etc.)

Compliance auditors may provide

site-specific feedback (e.g.,training records, current

plans/procedures, operational

controls, etc.)


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Joint Compliance/EMS Audits [


If contractor EMS auditors are

used, consider specifying that the

auditors be RABQSA-certified

(ensures level of competence)

If contractor EMS auditors are

used, consider Nondisclosure

Agreements (prevents contractorfrom using DOI EMS practices in

support of other clients)


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If EMS support contractors have

assisted with the implementation

of the EMS, do NOT use those

same contractors to audit theEMS (avoids conflicts of interest)

EMS support contractors can still

be used to address audit findings(if needed), but they need to be

independent of the audit


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Evolution of Army EMS Auditing

FY 8591: Army Environmental

Audit Program (multiple protocols,

compliance medias only)

FY 9200: Army Environmental

Compliance Assessment System

(ECAS) Program [standard

protocol (TEAM Guide); ArmySupplement to TEAM Guide

(included Env. Program Mgt.)]


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Evolution of Army EMS Auditing

(Cont.)

ECAS Env. Program Mgt.

evaluations included several

components of an EMS audit

FY 01Present: Army EPAS

Program [Army Supplement to

TEAM Guide revised to include

EMS section (ISO 14001)] Env. Program Mgt. assessors

trained as EMS auditors


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Army EMS AuditsLessons Learned

Many contractor-prepared EMS

manuals/procedures do not reflect

installation business practices

Some Army Commanders equate

EMS nonconformance to

regulatory noncompliance

Some Army installations tend toregard EMS as a Program vs. a

management system


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Army EMS AuditsLessons Learned

(Cont.)

Command emphasis on EMS can

vary with changes in installation

leadership (integration of EMS with

sustainability has worked well atsome installations)

Incorporation of tenants into

host installation EMS can provechallenging.


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Army EMS Auditor Training

(Training External Auditors)

Army Environmental Command

(AEC) hosts ISO 14001 Lead

Auditor Course (open to potential

auditors & funds attendance)

EMS auditor trainees are assigned

to participate in EMS audits (AEC

funds travel) with experienced(e.g., USCCHPPM) EMS auditors

until capable of serving as auditor


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(Training External Auditors)

Core Group of Experienced EMS

Auditors Still Conduct the Majority

of Army EMS Audits

Expanding the Army Pool of

Experienced Auditors is a Major

Challenge (multi-year effort)

EMS Auditor Pool MUST beExpanded (Core Group cannot

support all Army EMS audits)


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(Training Internal Auditors)

General EMS internal auditor

training (interview techniques,

reviewing objective evidence,

preparing findings, and practicalexercise using generic manual)

Installation-specific EMS internal

auditor training (above basics ofinternal EMS audits & practical

exercise using installation manual)


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Questions

Linda L. Baetz, EMS-LA

(410) 436-5234

[email protected]

James D. Wood, P.E., EMS-LA

(410) [email protected]
mailto:[email protected]:[email protected]:[email protected]:[email protected]