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

ISO 14001Environmental Management System (EMS)

Auditing Overview for the Department of Interior

Linda Baetz, EMS-LA and Jim Wood, P.E., EMS-LAU.S. Army Center for Health Promotion and Preventive Medicine

Discussion Topics

• EMS Requirement – Background

• Preparing for External EMS Audits

• Joint Compliance/EMS Audits

• Evolution of Army EMS Auditing

• Army EMS Audits – Lessons Learned

• Army EMS Auditor Training (External & Internal Auditors)

EMS Requirement - Background

• EO 13148 – Required Federal Agencies to implement EMS

• EO 13423 – Reinforced 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)]

Preparing for External EMS Audits(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)

Preparing for External EMS Audits(Phase II – Internal 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

Preparing for External EMS Audits(“Common” Nonconformance Issues)

• ISO 14001, 4.1 (General Requirements)

• Has the “scope” of the EMS been documented?


• 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)?


• 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?


• ISO 14001, 4.3.2 (Legal and Other Requirements)

• Do the “legal and other requirements” apply to the “environmental aspects”?


• 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?


• 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”?


• 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”?


• 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”?


• ISO 14001, 4.4.4 (Documentation)

• Does the EMS documentation include all of the mandatory requirements?


• 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?


• 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”?


• ISO 14001, 4.4.7 (Emergency Preparedness and Response)

• Are emergency preparedness & response procedures periodically tested (where practicable)?


• 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?


• 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?


• 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”?


• ISO 14001, 4.5.4 (Control of Records)

• Do procedures address the “retention times” & “disposal” of records?

• Are records legible, identifiable, and retrievable?


• ISO 14001, 4.5.5 (Internal Audit)

• Has an Internal Audit Program been implemented (e.g., schedule established; auditors identified & trained; audits conducted)?

• Does the selection of auditors & the conduct of the audits ensure objectivity & impartiality of the audit process?


• ISO 14001, 4.6 (Management Review)

• Has the management review process been implemented?

• Does the management review process incorporate all of the required inputs?

Joint Compliance/EMS Audits(Different Approaches)

• Army Environmental Performance Assessment System (EPAS) External Audits – Active Component Installations

• Concurrent Compliance/EMS Audit• Dedicated EMS Audit Team • Separate Compliance & EMS Audit

Reports

Joint Compliance/EMS Audits[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

Joint Compliance/EMS Audits[Different Approaches (Cont.)]

• Defense Logistics Agency (DLA) Compliance and EMS Audit Programs

• Separate Compliance & EMS Audit Schedules (no integration between compliance & EMS audits)

• DLA EMS Focus – “Multi-site Organizational EMS” vs. “Facility-specific EMS”

Joint Compliance/EMS Audits (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 compliance audit responsibilities)

Joint Compliance/EMS Audits [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, briefing results, preparing report, etc.)

• Compliance auditors may provide site-specific “feedback” (e.g., training records, current plans/procedures, operational controls, etc.)

Joint Compliance/EMS Audits [ [Key Points (Cont.)]

• 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 contractor from using DOI EMS practices in support of other clients)

Joint Compliance/EMS Audits [Key Points (Cont.)]

• If EMS support contractors have assisted with the “implementation” of the EMS, do NOT use those same contractors to “audit” the EMS (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

Evolution of Army EMS Auditing

• FY 85 – 91: Army Environmental Audit Program (multiple protocols, compliance medias only)

• FY 92 – 00: Army Environmental Compliance Assessment System (ECAS) Program [standard protocol (TEAM Guide); Army Supplement to TEAM Guide (included Env. Program Mgt.)]

Evolution of Army EMS Auditing(Cont.)

• ECAS Env. Program Mgt. evaluations included several components of an EMS audit

• FY 01 – Present: Army EPAS Program [Army Supplement to TEAM Guide revised to include “EMS” section (ISO 14001)]

• Env. Program Mgt. assessors trained as EMS auditors

Army EMS Audits – Lessons 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 to regard EMS as a “Program” vs. a “management system”

Army EMS Audits – Lessons Learned(Cont.)

• Command emphasis on EMS can vary with changes in installation leadership (integration of EMS with “sustainability” has worked well at some installations)

• Incorporation of “tenants” into host installation EMS can prove challenging.

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

Army EMS Auditor Training(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 be Expanded (“Core Group” cannot support all Army EMS audits)

Army EMS Auditor Training(Training Internal Auditors)

• General EMS internal auditor training (interview techniques, reviewing objective evidence, preparing findings, and practical exercise using “generic manual”)

• Installation-specific EMS internal auditor training (above basics of internal EMS audits & practical exercise using installation manual)

Questions

Linda L. Baetz, EMS-LA

(410) 436-5234

[email protected]

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

(410) 569-3325

[email protected]

mailto:[email protected]

mailto:[email protected]