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ISO14001 Seminar-Michigan Chamber of CommerceMarch 14, 2007
ASTI Environmental 1.800.395.ASTI 1
Environmental Management Systems
March 2007
Welcome
Investigations, Compliance, Investigations, Compliance, Remediation, and RestorationRemediation, and Restoration
Presenters
Thomas Wackerman, ASTI
Investigations, Compliance, Investigations, Compliance, Remediation, and RestorationRemediation, and Restoration
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Overview
Background
Benefits
The ISO14001 Elements
Break
Implementation and Management
Baseline Audits
Gap Assessments
Lunch
EMS Requirements
Aspects
Legal Issues
Planning
Break
Implementation and Management
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Supporting the Program
Implementing Programs
Scheduling and Costs
Training
Annual Audits
Questions and Answers
Adjourn
Other Materials
Binder
Exercises
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the Attachment
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Indicates new or modified materials
Web Resources
www.asti-env.com/isochamber.html
Investigations, Compliance, Investigations, Compliance, Remediation, and RestorationRemediation, and Restoration
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IntroductionInformation Session
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The structure, responsibilities, plans, procedures, processes, and resources used by an organization to develop and achieve its environmental policy.
What is an EMS?
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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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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?
..part of an organizations management system used to develop and implement its environmental policy and manage its environmental aspects.
- ISO 14001:2004(E)
An organizational structure, incorporating responsibilities, practices, procedures, processes and resources, for implementing and maintaining environmental management
- ISO 14001:1996
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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
What is ISO 14001?
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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
DoCheck
Act
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PDCA
Plan
DoCheck
Act
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Establish the objectives and processes necessary to deliver results in accordance with the
organizations environmental policy.
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PDCA
Plan
DoCheck
Act
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Implement the process.
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PDCA
Plan
DoCheck
Act
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Monitor and measure processes against environmental policy,
objectives, targets, legal and other requirements and report results.
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PDCA
Plan
DoCheck
Act
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Take actions to continually improve performance of the
environmental system.
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The Five Principles
Environmental Policy
Planning
Implementation & Operation
Checking & Corrective Action
Management Review
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Milestones
Implement EMS
Participate in Registration Audit
Continual Improvement Identify Requirements
Maintenance, Training, Awareness, Competence
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Overview Of ISO14001:2004(E)Information Session
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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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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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14001:1996 Environmental Management Systems - Specification with Guidance for Use14004:1996 Environmental Management Systems - General Guidelines on Principles,
Systems and Supporting Techniques 14010:1996 Guidelines for Environmental Auditing - General Principles14011:1996 Guidelines for Environmental Auditing - Audit Procedures - Auditing of
Environmental Management Systems14012:1996 Guidelines for Environmental Auditing - Qualification Criteria for
Environmental Auditors14020:1998 Environmental Labels and Declarations - General Principles14021:1999 Environmental Labels and Declarations - Self-declared Environmental Claims
(Type II Environmental Labeling)14024:1999 Environmental Labels and Declarations - Type I Environmental Labeling -
Principles and Procedures14031:1999 Environmental Management - Environmental Performance Evaluation - Guidelines14032:1999 Environmental Management Examples of Environmental Performance Evaluation (EPE) 14040:1997 Environmental Management - Life Cycle Assessment Principles and Framework14041:1998 Environmental Management - Life Cycle Assessment - Goal and Scope
Definition and Inventory Analysis14042/43 Environmental Management - Life Cycle Assessment - Life Cycle Impact
Assessment/Interpretation14050:1998 Environmental Management - Vocabulary14061:1998 Information to Assist Forestry Organizations in the Use of Environmental
Management System Standards ISO 14001and ISO 14004
ISO 14000 Series of Standards
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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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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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Drivers
International Trade
Customers
Marketing
Investment
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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-certifiedthrough 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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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
Adequate Resources
Structure & Responsibility
Training
System Documentation
Process Controls
System Audits
Management Review
Environmental Policy
Adequate Resources
Structure & Responsibility
Training
System Documentation
Operational Controls
System Audits
Management Review
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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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Combining QMS and EMS
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The ISO14001 Elements
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Environmental Management Systems (EMS) and ISO 14001
Brief Overview
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1 Scope
2 Normative References
3 Terms and Definitions
4 Environmental Management Systems Requirements
Organization
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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
Organization
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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.
1 Scope
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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.IS
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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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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
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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 objectivesIS
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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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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.
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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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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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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.
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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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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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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.
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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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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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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.
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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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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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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
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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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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.
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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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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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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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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.I
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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.
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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
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Appendix A: Guidance
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Appendix B: ISO14001:2004 v ISO9001:2001
Break Time 15 Minutes
Investigations, Compliance, Investigations, Compliance, Remediation, and RestorationRemediation, and Restoration
Implementation and ManagementInformation Session
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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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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
Audits Legal Considerations
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Why Perform an Audit?
Compliance Auditing as Part of EMS, including
Baseline Audit/Gap Analysis
Audits Legal Considerations
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Compliance Audit Project Team and Functions
Corporate Officer
Environmental Manager
Legal Counsel (In-house vs. Outside Lawyer)
Environmental Consultant/Technical
Audits Legal Considerations
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Consultant Retention
Selection and Contracting
Scope of Work
Audits Legal Considerations
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Protecting the Confidentiality of Audits
Attorney-Client Privilege
Anticipation of Litigation Work-Product
Self-Audit Privilege?
Address with ISO Registrar
Audits Legal Considerations
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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).
Audits Legal Considerations
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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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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 non-compliance.
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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 non-compliance found during the audit.
Those findings of the environmental audit for which immunity is desired also need to be reported to MDEQ.
Audits Legal Considerations
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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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EPA remains staunchly opposed to state audit laws from a policy perspective, which continues to cause a serious chilling effect on companies undertaking self-audits. 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)
Audits Legal Considerations
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MDEQ-EAD Administers State Part 148 Audit Program
Further information: http://www.michigan.gov/deq/0,1607,7-135-3307_3666_4135---,00.html
Audits Legal Considerations
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REPORTING OBLIGATIONS FROM AUDITS
Spills/Accidental Releases
Unpermitted Discharges
Permit Exceedances
Audits Legal Considerations
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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.
Audits Legal Considerations
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U.S. EPA Voluntary Environmental Self-Policing and Self-Disclosure Policy, see 60 Fed. Reg. 66706 (Dec. 22, 1995)
Audits Legal Considerations
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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 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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Response # Question (Y, N, DK, n/a) Finding Source Recommendation Comments
1
Has generator generated morethan 100 kilograms (220pounds) of hazardous waste permonth, or accumulated morethan 1,000 kilograms? (if YES,comply with SQG or LQGrequirements, see SQG or LQGchecklists)
2Have all wastes been classified,e.g., hazardous or non-hazardous? 40 CFR 262.11
3Have there been any State orFederal agency inspectionssince the previous audit?
4
Are there any citations, noticesof violation, or notices of non-compliance that have not beenresolved by the facility? (if yes,explain)
Example Audit Evaluation
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Baseline Audits
Consider all media for actual or potential impacts.
Air
Water
Soil
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Baseline Audits
Identify aspects and the impacts on the environment.
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Aspects
Waste generation
Wastewater discharge
Stormwater discharge
Air emissions
Point source
Fugitive
Automotive
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Aspects (Cont.)
Chemical operations
Water use operations
Energy use operations
Use of natural resources
Out-dated product
Product disposal
110
Objectives
Reduce effluents and emissions
Increase material and product recycling and use of recycled products
Reduce unplanned releases
Reduce energy consumption
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Gap Assessments
112
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.
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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.
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Gap Analysis (Cont.)
Provisions for EMS maintenance.
Review of modified activities, products & services.
Provisions to amend EMS.
Lunch 60 Minutes
Investigations, Compliance, Investigations, Compliance, Remediation, and RestorationRemediation, and Restoration
Implementation and ManagementInformation Session
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Agenda
EMS Requirements
Aspects
Legal Issues
Planning
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EMS Requirements
119
Key ingredient to success
Executive Management Commitment
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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
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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.
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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
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ISO 14001 Percent Complete TableFOR: Company
ELEMENT ELEMENT DESCRIPTION POINTSRECEIVED
POINTSPOSSIBLE
PERCENTCOMPLETE
1 ENVIRONMENTAL POLICY 13 30 43%2 ENVIRONMENTAL ASPECTS 2 10 20%3 LEGAL & OTHER
REQUIREMENTS11 14 79%
4 OBJECTIVES & TARGETS 7 10 70%5 ENVIRO. MGT. PROGRAMS 7 8 88%6 STRUCTURE &
RESPONSIBILITY3 8 38%
7 TRAINING AWARENESS &COMPETENCE
4 16 25%
8 COMMUNICATION 6 14 43%9 EMS DOCUMENTATION 1 4 25%
10 DOCUMENT CONTROL 6 14 43%11 OPERATIONAL CONTROL 5 10 50%12 EMERGENCY PREP. &
RESPONSE6 8 75%
13 MONITORING & MEASUREMENT 6 8 75%14 NON-CONF, CORRECTIVE &
PREVENT. ACTION3 6 50%
15 RECORDS 7 10 70%16 EMS AUDIT 4 8 50%17 MANAGEMENT REVIEW 3 12 25%
GRAND TOTAL 94 190
PERCENT COMPLETE 49%
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I S O 1 4 0 0 1 P e r c e n t C o m p l e t e G r a p h
4 3 %
2 0 %
7 9 %
7 0 %
8 8 %
3 8 %
2 5 %
4 3 %
2 5 %
4 3 %
5 0 %
7 5 %
7 5 %
5 0 %
7 0 %
5 0 %
2 5 %0 % 2 0 % 4 0 % 6 0 % 8 0 % 1 0 0 %
E N V IR O N M E N T A L P O L IC Y
E N V IR O N M E N T A L A S P E C T S
L E G A L & O T H E R R E Q U IR E M E N T S
O B J E C T IV E S & T A R G E T S
E N V IR O . M G T . P R O G R A M S
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 &C O M P E T E N C E
C O M M U N IC A T IO N
E M S D O C U M E N T A T IO N
D O C U M E N T C O N T R O L
O P E R A T IO N A L C O N T R O L
E M E R G E N C Y P R E P . & R E S P O N S E
M O N IT 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
R E C O R D S
E M S A U D IT
M A N A G E M E N T R E V IE W
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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.
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Assign EMS Management Representativeand Steering Team:
Engineering QS-9000 Human Resources Maintenence Training
EMS ManagementRepresentative
General Manager
Start
4.2 Environmental Policy
4.6 Management Review
4.5 Checking/Corrective Action
4.5.1 Monitoring and Measurement
4.5.2 Nonconformance andCorrective & Preventive Action
4.5.3 Records4.5.4 EMS Audits
4.3 Planning4.3.1 Environmental Aspects
4.3.2 Legal/Other Requirements
4.3.3 Objectives and Targets
4.3.4 Environmental ManagementProgram
4.4 Implementation4.4.1 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
ContinualImprovement
The 14001 EMS Element Cycle
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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
3. Continual ImprovementEMS
Policy
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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 followingprinciples:
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.
Honda Environmental Policy
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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
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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.
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Aspects
134
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
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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
136
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
137
Identifying and Evaluating Environmental Aspects/Impacts
IdentifyEnvironmental
Aspect
Determine Impactto Environment
Aspect isThereforeSignificant
Is ImpactSignificant?
Control, Study, or Improve Aspect viaEnvironmental Management Programs
and Operational Controls
Stop(Record)
YesNo
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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
139
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)
Environmental Aspects
INPUTS OUTPUT
Transportation
Chemicals
Oil/Fuels
Electricity
HazardousWaste
Water
Raw Materials/Consumables
Air Emissions
WaterDischarges
Solid Waste
Transportation
Property
Other Outputs
FACILITY
Other Inputs
SpillPotential
GroundwaterWetlands, etc.
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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
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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.
143
Examples From Steps 1-3
Activity, Productor Service
Aspect Impact
1 - Paint Line2 - Welding
Air Emissions Degradation of AirQuality
New or ModifiedConstruction
Land Use(wetlands)
Depletion ofWetlands
Scrap generation Solid Waste Landfill Use/Natural Resources
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Results From Steps 1-3
Activity, Productor Service
Aspect Impact
Paint Line 4 Solid waste,parts scrapped
Landfill waste,depletion ofresources
Paint Line 4 Haz waste,obsolescent orrejected paint
Air quality,resource depletion
Shipping Air Emissionsfromwarehouseoperations
Humanhealth/ecology
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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
RegulatedActivity/Department Aspect Description Severity Likelihood Detection SF Y= x 1.5
S x L x D x Yes/No
Shipping Air Emissions Tow motor operation 4 3 3 54 Y
Paint Line 4 Solid WasteScrap plastice parts falling off paint rack 4 3 3 36 N
Paint Line 4 Hazardous Waste
Discarded paint from Obsolesence or
quality 4 4 2 54 Y
Paint Line 4 Air EmissionsVOC from Paint Mixing 5 3 2 45 Y
Paint Line 4 Air EmissionsHAPS from Paint
Mixing 3 5 2 45 Y
Paint Line 4 Employee Safety
Exposure from coating/part
preparation/mixing 5 3 2 45 Y
Environmental Significance of Impact
Environmental Aspect Evaluation
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Environmental Aspect Evaluation
NEW
A B C D (A+B)*(C+D)
Aspect
Sensitivity of the Affected Medium
or PopulationToxicity / Hazard Quantity
Frequency of Occurrence IP Regulated? Adj. IP
heating imbalance fuel consumption 1 2 1 1 6 Y 9ventilation fuel consumption 1 2 1 1 6 N 6flourescent bulbs special waste disposal 0 0maintenance welding operatio visual impairment 0 0maintenance welding operatio air quality 0 0
Activity
Assessment Criteria - Normal Situations
Facility Maintenance
A B C D (A+B)*(C+D)
Aspect Area AffectedRelevance
(Importance)Frequency of Occurrence Unpreparedness IP Regulated? Adj. IP
raw material storage (particul surface water 0 0flammable material storage air quality 1 1 1 1 4 4flammable material storage health & safety 0 0flammable material storage stormwater 0 0
Activity
Assessment Criteria - Abnormal or Emergency Situations
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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
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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
ConsiderSeparate
Ranking forNormal andAbnormalOperations
NEW
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Environmental Aspect/Impact Evaluation
15 Minute Exercise
Investigations, Compliance, Investigations, Compliance, Remediation, and RestorationRemediation, and Restoration
3.3 Environmental Aspect - element of an
organization's activities, products or services that
can interact with the environment
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EMS Legal Requirements
152
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
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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
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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
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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
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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
157
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)
158
Voluntary Environmental Requirements
U.S. EPA Project XL
MDEQ Clean Corporate Citizen (C3)
PERI Principles
CMA CARE Program
Michigan Business Pollution Prevention Partnership (MBP3)
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Voluntary Environmental Requirements
Customer Requirements
Lender Conditions
Industry Codes of Practice
Non-Regulatory Guidelines
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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?
Aspect/Issue Legal or Other Requirement Reference ExplanationCompliance
Evaluation/ReviewOil Leaks and Spills
Managing Used Oil: Advice for Small Businesses
Monitor significant spill frequency
Used Oil Dry and "Pigs"
Managing Used Oil: Advice for Small Businesses
Monitor significant spill frequency
Waste OilPART 279 (Updated 1999) -
STANDARDS FOR THE MANAGEMENT OF USED OIL
Ensure total volume of oil remains below the threshold for implementation of a SPCC Plan
Ensure total volume of oil remains below the threshold for implementation of a SPCC Plan
Noise Occupational noise exposure. - 1926.52 Access to the Pump Room is restricted to personnel with hearing protection.
Sewer Discharge City of Toledo No permit required at this time.Storage of Metal to be Recycled
No Exposure Guidance Document and Forms)
Initiate CAR for the outside storage area. Confirm no exposure
AC Refridgerants EPA Requirements for Servicing Air Conditioners and Refrigeration Equipment Handled by Vendor.
Disposal of Computers and CRT
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 Bulbs
The Management of Fluorescent Lamps and PCB Ballasts in Ohio Recycled through Waste Management
Chemical Hygiene Plan
Occupational exposure to hazardous chemicals in laboratories. - 1910.1450 Metrology Lab Annual Review
Hazard Communication Program
Hazard Communication. - 1910.1200 Annual Review
MSDS Requirements Hazard Communication. - 1910.1200 Annual Audit
Emergency Action Plan Emergency action plans. - 1917.30 Annual Review
Forklifts Powered industrial trucks. - 1917.43 Annual Training
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Summary of Legal and Other RequirementsABC Plant
ASPECT DEPT(S) FEDERAL CITATION STATE CITATION OTHERAboveground Storage Tanks ALL 40 CFR 112 SPCC & SWPP Plan & ISO 14001Aboveground Storage Tanks Plant 40 CFR 60 Subpart Kb ISO 14001
CO Emissions FAC OAC 3745-21-08(B) PTI 01-3194 & ISO 14001CO Emissions FAC OAC 3745-31-05 PTI 01-177 & ISO 14001CO Emissions FAC OAC 3745-31-05 PTI 01-7350 & ISO 14001CO Emissions PA OAC 3745-21-08(B) PTI 01-0362 & ISO 14001CO Emissions PA OAC 3745-21-08(B) PTI 01-2259 & ISO 14001CO Emissions PA OAC 3745-21-08(B) PTI 01-3474 & ISO 14001CO Emissions PA OAC 3745-21-08(B) PTI 01-6743 & ISO 14001CO Emissions PL OAC 3745-21-08(B) PTI 01-0512 & ISO 14001CO Emissions PL OAC 3745-21-08(B) PTI 01-0999 & ISO 14001
Electricity Plant Energy Conservation & ISO 14001Hazardous Waste PA & PL 40 CFR 265 Subpart BB OPFP* & ISO 14001Hazardous Waste PA & PL 40 CFR 265 Subpart CC OPFP* & ISO 14001Hazardous Waste Plant 40 CFR 260.10 OAC 3745-50-10 OPFP* & ISO 14001Hazardous Waste Plant 40 CFR 261 OAC 3745-51 OPFP* & ISO 14001Hazardous Waste Plant 40 CFR 262 OAC 3745-52 OPFP* & ISO 14001Hazardous Waste Plant 40 CFR 268 OAC 3745-59 OPFP* & ISO 14001Hazardous Waste Plant 40 CFR 265 OAC 3745-65 OPFP* & ISO 14001Hazardous Waste Plant OAC 3745-66 OPFP* & ISO 14001Infectious Waste Medical OAC 3745-27 ISO 14001
Natural Gas Plant Energy Conservation & ISO 14001NOx Emissions FAC OAC 3745-23-06(B) PTI 01-3194 & OPFP* & ISO 14001NOx Emissions FAC OAC 3745-31-05 PTI 01-177 & ISO 14001
Approval Issuer
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Planning and Documentation
164
Activities, Products orServices (over which theCompany has control andinfluence) that interactwith the environment
Legal & OtherRequirements
EnvironmentalAspects
4.3.1 4.3.2
Objectives& Targets
4.3.3
EnvironmentalManagement
Program
Views of InterestedParties
4.3 Planning
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P6
Proper Planning Prevents Piss Poor Performance
SMART
Specific, Measurable, Achievable, Results Oriented, Time Framed
4.3 Planning
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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.
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Issue Objectives TargetsPressLubricatingOil Use
Reduce OilUse
Reduce oil use by 20% by 2002
Solid Waste Reducesolid wastesent tolandfill
Reduce solid waste disposal costs by20% by the end of 2001
1) Reduce use of energy plant wide by10% by 2002
Resources ConserveNaturalResources
2) Reduce water consumption by 20%per by 2002
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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.
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Objectives Targets Environmental Program ResponsibilityConserveResources
IdentifyOpportunitiesfor ChemicalUseReductions byend of 2001
1) Develop chemical use inventory forfacility. Use MSDS book as basis ofinventory. Monitor chemical usage.
2) Update MSDS book and add/removesheets as needed.
3) Develop and implement action plan todispose of or use dated chemicals.
4) Identify opportunity areas for chemicaluse reduction.
EMS SteeringCommittee by10/2001
ReduceElectricity Useby 5% peremployee bythe end of2004 versus1999 energyusage
1) Evaluate electricity use facility wide.Ask utility to conduct energy audit.
2) Identify opportunities for electricity usereductions. Results from energy audit.
3) Develop and implement action plan toreduce energy use.
John Doe by8/2001
Reduce waterconsumptionby 5 % peremployee byend of 2004versus 1999usage
1) Implement monthly water usemonitoring on a per employee basisversus 1999.
2) Identify opportunities for water usereductions.
3) Develop and implement action plan toreduce water use.
John Doe by4/2003
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Objectives Targets Environmental Program ResponsibilityConserveResources
Reduce fuel oil,gas, otherheating relatedmedium by 5 %per employee byend of 2004versus 1999
1) Implement monthly fuel usemonitoring on a per employee basisversus 1999.
2) Identify opportunities for fuel usereductions.
3) Develop and implement action planto reduce fuel use.
John Doe by4/2003
Reduce solidwaste to thelandfill by 4% peremployee verses1999 by end of2001 Versus1999
1) Develop operation controls for wastesegregation program. DevelopMonitoring and measurementmetrics.
2) Develop training on wastesegregation operational controls.
3) Train all employees on wastesegregation.
Jane Doe by12/2000
IncorporateEMS into APQPby 12/2000
Amend APQP process to includeconsideration of EMS in new productand process planning.
QualityManager by12/2000
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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 abasis for improvement of the EMS
* Management Representative
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EMS Responsibilities
Functions Possible RolesPurchasing Develop & implement controls for chemical & other
purchasesHumanResources
Define competency requirements & job descriptions forEMS roles
Integrate EM into reward/discipline systemFinance Track data on EM costs
Prepare budget for EM program Evaluate economic feasibility of projects
Engineering/Environmental
Consider impacts of new or modifiedproducts/processes
Identify pollution prevention opportunityTopManagement
Communicate importance of EMS Provide necessary resources Track & review EMS performance
GeneralAssociates
Knowledge of environmental aspects of their job Support training of new employees Know Environmental Policy
173
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 significantaspects and record its decision.
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Environmental Communications Log
Date Recd
Originator
Int?
Ext?
Response Summary
Date
Closed
10/20/00
USEPA Letter from John Doe dated 10/15/00
X Prepare and mailed response letter 10/25/00
11/15/00
Odor complaint call from Jane Deer
X Inspected property and provided letter response
12/25/00
1/5/01
Car paint damage claim call from Joe Worker
X Inspected car, provided picture documentation
1/9/01
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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
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EMS Documentation Needs
Is it a core element of the EMS?
Can you demonstrate objective evidence of a procedure if it is not documented?
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EMS Documentation
EnvironmentalPolicy
Procedures
Work Instructions
Records
Why you do it
What you do
How you do it
Evidence ofwhat you do
Intent
What, when, where & who
How
A 4-Tier System: International StandardsISO 14001
178
EMS Documentation Road MapElement Number
Element/Issue Level 1 Manual Level 2, Procedures
Level 3, WI Level 4, Forms
EMS Scope Section 4.1 Quality Manual
4.2 Environmental Policy
Section 4.1 Quality Manual
EP3.1-1 Environmental Aspects
P2-1 APQP Procedure
4.3.1 Environmental Aspects
EP3.2-1 Legal
and Other Requirements
P9-5 Environmental /Safety
EF3.2-1, Legal and Other Requirements
4.3.2 Legal and Other Requirements
P3-1 Contract Review
EP3.3-1 Objectives and Targets
4.3.3 Objectives and Targets
179
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)
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Approval Issuer
TitlePurpose:Scope:Responsibilities:Definitions:Impelementation:Associated Documents:
Revisionhistory
The following indicates the revision level date and reason for the revisions tothis document.
No. Date Revision history0 5/11/98 Document creation.
Document Number: MAP 01 69 003 Page 1 of 1Revision Number: 0Revision Date: 5/11/98 MAP Significant Aspects procedure.doc
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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.
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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
4.4.6 Operational Control
ISO14001 Seminar-Michigan Chamber of CommerceMarch 14, 2007
ASTI Environmental 1.800.395.ASTI 62
Cost Level Regulated Program/Activity Aspect Impact Severity Likelihood Detection SF to of Response
S L D SxLxD Address Control Yes/No Reference
Painting-Dept 57 Solvent evaporation VOC Emissions 4 5 2 40 3 3 Y EPI-019Sump tanks / pits Leaks to soil Contaminated Soil 4 3 3 36 3 2 Y EPI-008Painting-Dept 45 Solvent evaporation VOC Emissions 4 4 2 32 3 3 Y EPI-019
Outside equipmentstorage
Oil leaks from equip.being stored Storm Drain Pollution 4 4 2 32 3 3 Y EPI-017
Machinery Waste Coolants Liquid Waste 3 5 2 30 1 3 Y EPI-020Sump tanks / pits Coolants & oils Oily Waste Water 3 4 2 24 2 2 Y EPI-020
Rust Protection-D55 Solvents in RP VOC Emissions 2 4 3 24 1 3 Y Planning
Outside UnloadingBulk fuel, solvent,
or paint leaksPotential Liquid Spills
to Stormdrain 4 3 2 24 3 2 Y EPI-004Aerosol Can
DisposalDisposal of solvents
and propellantsHazardous Liquid
Wastes 4 3 2 24 1 3 Y EPI-001
Chip Dock DrainageOil leakagefrom trailers Soil Contamination 3 3 2 18 2 2 Y EPI-005
Chip Dock Drainage Sump leaks to soil Soil Contamination 3 2 3 18 3 2 Y EPI-008Machinery Glycol Liquid Waste 4 4 1 16 2 3 Y EPI-021Machinery Oil Leaks/Spills Oily Waste Water 4 4 1 16 2 2 Y EPI-020
Parking Lot Automotive fuel, oil,or antifreeze leaks Soil Contamination 2 4 2 16 2 1 Y Planning
Asbestos Materials Disturbance Air or Water Release 5 3 1 15 2 2 Y EPI-022
Environmental Significance of Impact
Break Time 15 Minutes
Investigations, Compliance, Investigations, Compliance, Remediation, and RestorationRemediation, and Restoration
Supporting the ProgramInformation Session
ISO14001 Seminar-Michigan Chamber of CommerceMarch 14, 2007
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Agenda
Implementing Programs
Scheduling and Costs
Training
Annual Audits
187
Implementing Programs
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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.
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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.
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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.
Compliance with relevant environmental legislation and regulations must be evaluated.
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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
ISO14001 Seminar-Michigan Chamber of CommerceMarch 14, 2007
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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
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Monitoring and MeasurementIdentify monitoring needed for significant aspects
Effluent/Emission Monitoring
Regulatory required routinely reported to
agencies
material usage logs (CAA) waste characterization
Verify operating criteria/limits
Identify monitoring requirements
id organizational responsibility
id data and/or records needed
id internal processes needed
Trends in Achieving Objectives
Identify measures for selected goals/objectives
id organizational responsibility
id data and/or records needed
System for tracking & reporting progress
Can accounting help? Take action on data results
to improve performance
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P3 SOLID WASTE
0
50
100
150
200
250
Q4 ' 99 Jan-00Feb-00Mar-00Apr-00 May-00
Jun-00 Jul-00 Aug-00
Sep-00
Oct-00 Nov-00
Dec-00
YEAR 2000 (MONTHS)
SOLI
D W
ASTE
,CU.
M.,
KK54
11
0.000
0.500
1.000
1.500
2.000
2.500
3.000
SOLI
D W
ASTE
,CU.
M. /
KK5
411 SOLID WASTE, cu.m.
KK5411
Solid Waste, Cu.M./KK5411(actual)Solid Waste, Cu.M./KK5411(target)
ISO14001 Seminar-Michigan Chamber of CommerceMarch 14, 2007
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Compliance Evaluation
RCRA Inspection
Fire Extinguisher Inspections
Facility Compliance Audit
SARA Reporting Schedule
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4.5.3 Non Conformance and Corrective and Preventative Action
...establish and maintain procedures for defining responsibilityand 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)
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A. Audited Area/Department:
Audit Date:Auditee(s):
Auditor(s):Date:C. Root CauseAnalysis:
B. Description of Non-Conformance:
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:
ISO14001 Seminar-Michigan Chamber of CommerceMarch 14, 2007
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Nonconformance and Corrective/Preventative Action
Ways to identify EMS Nonconformances
Audit Monitoring Employee Suggestions
Other Sources
Corrective ActionProcess
Management Review
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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.
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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.
ISO14001 Seminar-Michigan Chamber of CommerceMarch 14, 2007
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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
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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
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Audit Life Cycle (Process Flow)
Audit Process
Audit Team Selected
Team Prepares Audit
Checklist
Opening Meeting with Dept./Mgt.
Team
Trained Auditors
A
Conduct Audit
Assessment
Compile Preliminary
Audit Findings
Perform Verification Activities
Corrective Action
Developed
Prepare and Distribute
Report
Closing Meeting with Dept./Mgt.
Team
Audit Closed
Verify Corrective
Action
A
ISO14001 Seminar-Michigan Chamber of CommerceMarch 14, 2007
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EMS Internal Audit Plan
Company/dept. Plan for Internal EMS Auditfor year:
Form No.Date:
Team/personresponsible
Months
Area/procedure to be audited JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
Week no. of planned environmental audit Environmental audit completed Follow-up on corrective actions Date: Signature: Position:
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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.
Management must review the EMS for changes related to:
EMS audit results.
Changing circumstances.
Continual improvement.
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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:
- Identifying Significant Environmental Aspects and Impacts?
- Resource Allocation?
- Information Systems?
- Staff Expertise?
- Procedural Requirements?
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?
Internal Organizational or Process Changes?
Should additional internal performance measures be established?
Recommended Revisions to:
Environmental Policy and Commitments?
Objectives and Performance Measures?
Elements of EMS?
ISO14001 Seminar-Michigan Chamber of CommerceMarch 14, 2007
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Steps to Implementing
ExecutiveManagementCommitment
Select a GuidanceTeam or Champion
Develop an ActionPlan
BudgetResponsibility MatrixMilestone Schedule
Conduct InitialEnvironmental Review
A
START
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Steps to Implementing
Build Project Team
Involve Employees
Train Procedure Writers
Prepare Procedures
Pollution Prevention
Train Employees &Start Using EMS
DocumentedProcedures
Train InternalAuditors
A
B
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Registration Process
On-Site EMSReadiness Review
Yes
No
Registration Audit
RegistrationDetermination
Correct anyDeficiencies
Surveillance Audits
Pass
Conditional
B
END
Fail
On-SiteAssessment1-4 (auditor)
days
On-SiteAssessment2-8 (auditor)
days
On-SiteAssessment1-2 (auditor)
days
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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
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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?
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Scheduling and Costs
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ISO 14001 Implementation Schedule
ID Task Name Duration1 ISO 14001 Gap Analysis 1 day2 ISO 14001 Implementation 275 days3 Project Kickoff Meeting 6 days4 Project Planning/Facilitation 6 days5 Assign Management Representative 1 day6 Assign Steering Committee 1 day7 Environmental Aspects 105 days8 Legal and Other Requirements 39 days9 Review Environmental Policy 28 days10 Objectives and Targets 84 days11 Environmental Programs 21.47 days12 EMS Manual/Documentation 70 days13 Organize Vs. QS-9000 22 days14 Inventory Existing Procedures 1 day15 Review EMS Operational Procedures 69 days16 Review Updated Quality Manual 62 days17 Training on Operational Controls 8 days18 Internal Auditor Training (Classroom) 1 day19 Internal Audit (Hands-on) 1 day20 Corrective Action 11 days21 Project Review/Status 1 day
100%
100%100%100%100%
64%97%
8/158/22
88%23%
67%70%
20%11%
0
Jun Jul Aug Sep Oct Nov Dec Jan Febr 3rd Quarter 4th Quarter 1st Quarter
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ISO 14001 Implementation Schedule
Task Duration Task DurationISO 14001 Gap Analysis 1 day Review Updated Quality Manual 62 daysISO 14001 Implementation 275 days Training on Operational Controls 8 daysProject Kickoff Meeting 6 days Internal Auditor Training (Classroom) 1 dayProject Planning/Facilitation 6 days Internal Audit (Hands-on) 1 dayAssign Management Representative 1 day Corrective Action 11 daysAssign Steering Committee 1 day Project Review/Status 1 dayEnvironmental Aspects 105 days General Awareness Training 4 daysLegal and Other Requirements 39 days Internal Audit (off-site review) 4 daysReview Environmental Policy 28 days Corrective Action (off-site review) 16 daysObjectives and Targets 84 days Management Review 1 dayEnvironmental Programs 21 days Pre-registration Audit 2 daysEMS Manual/Documentation 70 days Corrective Action 8 daysOrganize Vs. QS-9000 22 days Registration Audit 3 daysInventory Existing Procedures 1 day ISO 14001 Registration 1 dayReview EMS Operational Procedures 69 days
Total Above 14 months
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Costs of ISO 14001 Implementation
Gap Analysis $2,500 - $3,000
Implementation $20K - $30K
Internal 1,500 hrs = $60,000
Registration $12K - $15K
Gap Analysis $2,500 - $3,000
Implementation $35K - $45K
500 hrs = $20,000
Registration $12K - $15K
Facilitation Full Implementation
Note: Rough cost for facility of approximately 200 employees
ISO14001 Seminar-Michigan Chamber of CommerceMarch 14, 2007
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Implementation Costs
From: Environmental Management System Demonstration Project, NSF International 1996
NEW
217
CertificatedEntity:
Number ofEmployees
Initial Assessment(Man days)
Annual surveillancevisits (Man days)
Total
(IAFGuide toISO/IECGuide
62)
On-siteminm(IAF
Guide toISO/IECGuide
62)
Total
(IAFGuide toISO/IECGuide
62)
On-siteminm
(IAF Guideto ISO/IECGuide 62)
Less than 5 2 1 1 0,55-9 2,5 1,5 1 0,5
10-19 3 2 1 120-29 4 2,5 1,5 130-59 6 4,5 2 1
60-100 7 5 2 1,5100-250 8 6 2,5 2250-500 10 7 3 2
Registration Costs
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Training
ISO14001 Seminar-Michigan Chamber of CommerceMarch 14, 2007
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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.
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Training Needs Assessment
Steering Team Procedures Internal Auditors Employee Overviews
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Training Topic Trai
ning
In
terv
al
All E
mpl
oyee
s
Prod
uctio
n Em
ploy
ees
Mai
nten
ance
Em
ploy
ees
Sala
ried
and
Non-
Pr
oduc
tion
Empl
oyee
s
Mat
eria
l Ha
ndle
rs
EMS Awareness I YR XHaz Com xEWI-01 Empty Aerosol Can xEWI-02 Empty Drum Handling xEWI-03 Spill Clean-up xEWI-04 Waste SegregationEWI-05 Haz Waste ManifestingEWI-06 Waste Water TreatmentEWI-07 Solid Waste QWI-01 Preventative Maintenance xInternal Auditor TrainingForklift Training x
EMS Training Matrix
ISO14001 Seminar-Michigan Chamber of CommerceMarch 14, 2007
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