Checking & Corrective ActionEPA Regions 9 & 10andThe Federal Network for Sustainability

ISO 14001 ComponentsPolicyPlanningImplementation and OperationChecking and Corrective ActionManagement Review

ISO 14001 ElementsChecking and Corrective Action involves:

Monitoring and measurementNonconformance and corrective and preventive actionRecordsEMS Audits

Monitoring and MeasurementEPA Regions 9 & 10andThe Federal Network for Sustainability

RequirementsDocument procedures to routinely monitor and measure activities with significant impactsRecord progress on objectives & targetsCalibrate equipmentEvaluate complianceKeep records

Actions to Support MeasurementIdentify performance indicatorsEstablish schedules for monitoringEstablish record-keeping requirementsDocument measurement proceduresCommunicate to appropriate staff and managers

Nonconformance and Corrective and Preventive ActionEPA Regions 9 & 10andThe Federal Network for Sustainability

RequirementsEstablish procedures for detecting reporting investigating correcting preventingNon-conformance with the EMS

ActionsIdentify cause of nonconformanceDetermine appropriate responseEnsure actions are appropriate to the size of the problemIdentify personnel responsible for corrective action and their authoritiesImplement corrective action

Actions continuedInvestigate root cause to identify potential preventive actionImplement or modify controls to prevent repetition of the nonconformanceTrack progress on correction/preventionDocument changes in written proceduresRecord the changes made

RecordsEPA Regions 9 & 10andThe Federal Network for Sustainability

RequirementsIdentify records associated with environmental issues

Establish and maintain procedures for their identification, maintenance and disposal

Documents vs. RecordsDocumentsOffer guidance or explain actions to be carried outCan be changed RecordsProvide verification of things that have happenedCannot be changed

Documents are materials that provide management directions:environmental policyinternal standards and operating proceduresEMS proceduresorganization chartsemergency plans

Records includetraining recordsincident reportsproduct informationcomplaints and responsesaudit resultsmanagement review meeting minutesDocuments vs. Records

Scope of RecordsLegislative and regulatory requirementsPermitsEnvironmental aspects and their associated impactsEnvironmental training activityInspection, calibration and maintenance activity

Records should cover:Continued

Monitoring dataDetails of non-conformance: incidents, complaints and follow-up actionProduct identification: composition and property dataSupplier and contractor informationEnvironmental audits and management reviewsScope of RecordsRecords should cover:

IdentificationCollectionIndexingFilingStorage

Good environmental information management includes:MaintenanceRetrievalRetentionDisposalRequirements for Records Maintenance

EMS AuditsEPA Regions 9 & 10andThe Federal Network for Sustainability

RequirementsDetermine whether the system conformsAssess whether it has been properly implemented and maintainedProvide information to management

Types of EMS AuditCompletePartial

Certification auditSurveillance audit

InternalExternal

EMS Audit ProtocolEstablish procedures that coverScopeFrequencyMethodologiesAudit responsibilitiesReporting responsibilities

Audit Program Establish audit schedule Internal External

Base on environmental importance of the activity

Consider results of previous audits

Audit ProcessDocument and record reviewOpening meetingSite tourInterviewsAuditor conference(s)Findings developmentClosing meetingAudit report

Audit OutcomesReport to managementIdentify corrective actionsRecord audit results

Continual ImprovementIdentify areas for improvement of EMSDetermine root cause of nonconformanceDevelop corrective and preventive action planImplement corrective and preventive actionsVerify effectiveness of action plansMake changes to procedures

SummaryAn EMS involves checking and corrective action proceduresIdentifies nonconformances and opportunities for improvement

The system itself is auditedDocument changes in proceduresRecord changes made

Performance indicators should be objective, verifiable and reproducible. Should be relevant to the organizations activities, consistent with its environmental policy, practical, cost-effective, and technologically feasible.

ISO14001 4.5.3 specifically mentions including training records and results of audits and reviews.ISO14004 describes records as:Legislative and regulatory requirementsPermitsEnvironmental aspects and their associated impactsEnvironmental trainingInspection, calibration and maintenance activityMonitoring dataDetails of non-conformance: incidents, complaints and followup actionsProduct identification: composition and property dataSupplier and contractor informationEnvironmental audits and management reviewsRecords shall be legible, identifiable and traceable to the activity, product or service involved.E. Records shall be stored and maintained so they are readily retrievable and protected against damage, deterioration or loss.