Environment Management System Clause 4.5

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    4.5 Checking

    4.5.1 Monitoring and measurement

    This procedure describes the process for the scheduled monitoring and

    measurement of key characteristics of the organizations environmentalmanagement system activities. It also addresses collection of environmental

    data associated with operations and activities that have the potential to have a

    significant environmental impact. The procedure addresses collection of

    environmental data associated with operations and activities that have the

    potential to have a significant environmental impact.

    a) The department head is responsible for submitting a monthly operating

    report (MOR) which describes the key characteristics of the EMS and the

    status of the objectives and targets and associated improvement

    programs.

    b) The department supervisor(s) are responsible for generating

    environmental monitoring and measurement data to be submitted in the

    Monthly Operating Report (MOR).

    c) Executive management shall review the monthly operating reports to

    assure continuing suitability and effectiveness of the EMS.

    Procedure

    1. Monthly Operating Report (MOR)

    A monthly report shall be established for department heads/supervisors to

    submit monitoring and measuring information to support performance ofthe EMS. The report is to be structured as a minimum to: Provide status of environmental management programs designed to

    fulfil environmental objectives and targets, Provide status of performance indicators as related to targeted

    timeframes, Provide compliance status of environmental operating permits issued

    by environmental regulatory agencies.

    1. Performance Tracking

    Environmental data collected to reflect environmental performance is to

    be maintained in such a manner to allow the evaluation of progresstoward realizing environmental objectives and targets.

    4.5.2 Evaluation of Compliance

    The purpose of this procedure is to describe the method by which Idex Corp willperiodically evaluate its compliance with applicable legal and other requirementsto which Idex Corp subscribes, and record the results of these evaluations.

    Head of Quality and Environment Compliance is responsible for communicatingrelevant and pertinent information about the requirements to the President andChief Operating Officer (COO). The Director of Quality and EnvironmentalCompliance shall, at a minimum, keep the COO informed of foreseen, potential,and/or current nonconformities with the requirements.

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    The Environmental Manager is responsible for ensuring that all activities andobligations i.e. Track changes to the requirements; and communicate relevantand pertinent information about the changes to the requirements, tomanagement and employees.

    Procedure

    Periodically evaluating compliance with the requirements and communicating tomanagement and employees

    All provincial/state and federal requirements will be reviewed on amonthly basis. Idex Corporation receives monthly alerts and updates ofamendments to state/provincial and federal environmental legislation andthe passing of new state/provincial and federal environmental legislationfrom a reliable legislative service.

    Municipal environmental by-laws will be reviewed on a monthly basis to

    identify amendments to municipal by-laws or the passing of new municipalby-laws.

    Non-regulatory requirements will be reviewed to identify amendments tononregulatory requirements or the passing of non-regulatoryrequirements. The frequency of reviews will depend on ACME Co.'s level ofcommitment, possible liabilities, and the ranking of the associatedsignificant aspect

    All required components of Idex Corps EMS will be updated within anappropriatetime frame, to ensure compliance with the amendment(s) orthe new requirement(s).

    4.5.3 Nonconformity, corrective action and preventive action

    This procedure describes a controlled process for initiating corrective andpreventive action in response to externally or internally reported non-conformances pertaining to the EMS of Idex Corporation

    Department staff are responsible for bringing suspected non-conformances tothe attention oftheir assigned Section Managers, or to the EMR.

    The Environment Management Representative is responsible for evaluatingpotential non-conforming conditions noted in internal or external

    communications, EMS audits, management review, or third-party registrar auditsand surveillance activities, and for initiating the Corrective and Preventive ActionRequest (C/PAR) process where non-conformances are determined to exist. TheEMR shall actively participate in the resolution of the non-conformance and shallwork with the responsible Section manager or section supervisor to identifyappropriate corrective and preventive actions. The EMR is responsible forpreparing corrective and preventive action requests, verifying completion, andlogging of the issuance and closure. The EMR shall prepare and present a reportto management on a monthly basis identifying the current status and resolutionof all C/PARs.

    Section Managers or Supervisors determined to have primary responsibility for a

    non-conformance shall participate with the EMR in the evaluation of the non-conformance, determination of the root cause of the non-conformance,

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    determination of appropriate measures to be taken to correct the immediatesituation, and the determination of appropriate preventive measures that couldreasonably be taken to reduce or preclude the likelihood for recurrence of thenon-conformance. It is the responsibility of the Section Manager, Supervisor orassigned management to ensure these corrective and preventive actions arecompleted within the determined time frame or report the progress and therevised completion dates to the EMR, prior to the original completion date.

    Procedure

    Steps to follow for investigating, correcting and preventing non-conformanceinclude:

    1. Identifying the root cause of the non-conformance,2. Identifying and implementing the necessary corrective action,3. Implementing new or modifying existing controls to prevent a recurrence

    of the non-conformance,

    4. Reviewing the effectiveness of corrective and preventive actions,5. Recording changes to procedures resulting from the corrective and

    preventive action6. Documenting all steps

    4.5.4 Control of records

    This procedure describes policies for identification, maintenance and disposal ofIdex Corporations Environmental Management System records. This procedurecovers all environmental records, both hardcopy and electronic or other mediaform, required for effective operation of this facilitys EnvironmentalManagement System. These records are managed at the department level and

    at the facility level. Records include but are not limited to: forms (when filledin), reports, training, audit results, inspection results, maintenance andcalibration records, emergency response records, information on significantenvironmental aspects, and management reviews.

    It is the responsibility of the Environmental Office to identify environmentalrecords and retention periods required by environmental regulations forenvironmental records that are maintained for the facility.

    It is the responsibility of the Department Head or designee to identify andmaintain environmental records, and their retention times, specific to the

    department's significant environmental aspects.

    It is the responsibility of the EMR Designee to identify and maintain recordsassociated with the EMS at the facility level. The EMR Designee identifiesretention times for these records.

    Procedure

    1. The Environmental Office maintains a documented procedure for theidentification, collection, indexing, access, filing, storage, maintenance,and disposition of facility level environmental records.

    2. Departments maintain a process for the identification, collection, indexing,

    access, filing, storage, maintenance, and disposition of department levelenvironmental records.

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    1. All environmental records are legible, retrievable, and maintained in asuitable environment to prevent deterioration, damage, or loss.

    2. Retention of records is in accordance with regulatory requirements unlessotherwise specified in the procedure producing the record.

    3. Obsolete records are disposed of by the record owner or designee.4. Appropriate security and backup controls are in place to ensure the

    reliability, security, and availability of electronic environmental records forwhich no hard copy is retained.

    4.5.5 Internal Audit

    This procedure establishes minimum requirements for planning, performing, anddocumenting periodic internal audits of the ISO 14001-based environmentalmanagement system (EMS) established for Idex Corporation

    The Environmental Management Representative (EMR) is responsible forestablishing audit schedules and for designation or selection of Lead EMSAuditors who are independent of the day-to-day management of the plant

    functions to be audited. The EMR shall also review and approve EMS audit plansand reports.

    The Lead EMS Auditor is responsible to the EMR for the organization, planning,and direction of EMS audits, as well as the selection, training, and supervision ofthe audit team. The Lead EMS Auditor prepares audit plans and reports, and isresponsible for evaluating and recommending any required corrective andpreventive action responses resulting from audit findings.

    Auditors are responsible for assisting in audit preparation, conducting auditinvestigations, and reporting results in compliance with this procedure, under thedirection of the Lead EMS Auditor. When requested, audit observers shall assist

    in audit preparation and in conducting audit activities in areas in which theyhave specific expertise.

    Section Managers of audited section or group shall provide time, work space, andpersonnel as necessary to support the performance of EMS audits, and areresponsible for supervising the prompt and effective resolution of any auditfindings.

    Procedure

    The audit process is described in the following steps:1. Audit Scheduling, to be conducted at least annually.2. Audit Notification, the Lead auditor must notify the relevant people at

    least 10 days prior to the audit about the projected audit date.3. Audit Plan prepared by the Lead Auditor detailing the audit number,

    objectives, date of audit, team members and their assigned roles etc.4. Audit Checklist Preparation, as per the ISO 14001 standards5. Opening Meeting, prior to the audit convened by the Lead Auditor in

    presence of the Audit Team and representatives of the Audited section.Discussions on the audit process and communication channels are to beestablished

    6. Conducting the audit, as per the ISO 14001 standards using the Audit

    Checklist

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    7. Closing Meeting, post the audit to share a draft list of findings andobservations with the audited section. Clarification of misunderstandingsmay take place.

    8. Audit Report Preparation9. Review of Corrective/Preventive Action Responses by the lead auditor,

    once this is approved by the lead auditor, it is communicated to the EMRand the Audit is considered closed.

    10.Audit Documentation, to be done once the Audit is closed, by the leadauditor.