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ISO 14001 Environmental Management System EMS

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Title: ISO 14001 Environmental Management System EMS


1
ISO 14001Environmental Management System
(EMS) Auditing Overview for the Department of
Interior
Linda Baetz, EMS-LA and Jim Wood, P.E.,
EMS-LA U.S. Army Center for Health Promotion and
Preventive Medicine
2
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)

3
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)

4
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)

5
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

6
Preparing for External EMS Audits(Common
Nonconformance Issues)
  • ISO 14001, 4.1 (General Requirements)
  • Has the scope of the EMS been documented?

7
Preparing for External EMS Audits(Common
Nonconformance Issues)
  • 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)?

8
Preparing for External EMS Audits(Common
Nonconformance Issues)
  • 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?

9
Preparing for External EMS Audits(Common
Nonconformance Issues)
  • ISO 14001, 4.3.2 (Legal and Other Requirements)
  • Do the legal and other requirements apply to
    the environmental aspects?

10
Preparing for External EMS Audits(Common
Nonconformance Issues)
  • 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?

11
Preparing for External EMS Audits(Common
Nonconformance Issues)
  • 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?

12
Preparing for External EMS Audits(Common
Nonconformance Issues)
  • 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?

13
Preparing for External EMS Audits(Common
Nonconformance Issues)
  • 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?

14
Preparing for External EMS Audits(Common
Nonconformance Issues)
  • ISO 14001, 4.4.4 (Documentation)
  • Does the EMS documentation include all of the
    mandatory requirements?

15
Preparing for External EMS Audits(Common
Nonconformance Issues)
  • 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?

16
Preparing for External EMS Audits(Common
Nonconformance Issues)
  • 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?

17
Preparing for External EMS Audits(Common
Nonconformance Issues)
  • ISO 14001, 4.4.7 (Emergency Preparedness and
    Response)
  • Are emergency preparedness response procedures
    periodically tested (where practicable)?

18
Preparing for External EMS Audits(Common
Nonconformance Issues)
  • 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?

19
Preparing for External EMS Audits(Common
Nonconformance Issues)
  • 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?

20
Preparing for External EMS Audits(Common
Nonconformance Issues)
  • 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?

21
Preparing for External EMS Audits(Common
Nonconformance Issues)
  • ISO 14001, 4.5.4 (Control of Records)
  • Do procedures address the retention times
    disposal of records?
  • Are records legible, identifiable, and
    retrievable?

22
Preparing for External EMS Audits(Common
Nonconformance Issues)
  • 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?

23
Preparing for External EMS Audits(Common
Nonconformance Issues)
  • ISO 14001, 4.6 (Management Review)
  • Has the management review process been
    implemented?
  • Does the management review process incorporate
    all of the required inputs?

24
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

25
Joint Compliance/EMS AuditsDifferent 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

26
Joint Compliance/EMS AuditsDifferent 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

27
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)

28
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.)

29
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)

30
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

31
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.)

32
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

33
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

34
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.

35
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

36
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)

37
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)

38
Questions
  • Linda L. Baetz, EMS-LA
  • (410) 436-5234
  • linda.baetz_at_us.army.mil
  • James D. Wood, P.E., EMS-LA
  • (410) 569-3325
  • jim.wood_at_us.army.mil
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