Operational Control In Environmental Management System (EMS)

Operational Control In ISO 14001 Standards Environmental Management System EMS

Operational Controls over Significant Environmental Aspect Activities, ?4.4.6.a&b – ISO 14001requires the organization to identify and plan the operations associated with its identified significant environmental aspects in order to establish documented operational control procedures that preclude deviation from the Environmental Policy or not achieving objectives and targets.

Opportunities to apply operational controls can be found by reviewing operations. As shown in the accompanying text box, once the operations that can produce significant impacts are identified, it is a relatively simple step to establish operational control procedures that are consistent with the aims of the Environmental Policy and the objectives and targets and that stipulate operating criteria.

Significant Environmental Aspects of Goods and Services, §4.4.6.c – This requirement of ISO 14001 requires careful reading. Here is a parsed interpretation of the Operational Control requirement as it relates to goods and services furnished by others:

“The organization shall identify those operations that are associated with [its] identified significant environmental aspects… The organization shall plan these operations in order to ensure that they are carried out under specified conditions by… [1] establishing and maintaining procedures related to the identifiable significant environmental aspects of goods and services used by the organization and [2] communicating relevant procedures and requirements to suppliers and contractors.”

An easy way to conform to this requirement is to:

1. Identify the operations associated with the significant environmental aspects;

2. Identify the environmental aspects of goods and services furnished by others;

3. Determine how these aspects contribute to the organization’s significant aspect operations;

4. Establish appropriate/relevant requirements for the providers of these services; and

5. Communicate the requirements to suppliers and contractors.

Confusion in conforming to this requirement can arise because it is easy to read sub-clause c) independently of the first sentence of §4.4.6.

This first sentence gives context to the rest of the section in that it requires that we first “identify those operations… associated with the identified significant environmental aspects.” Once we have identified these operations, we look to the significant aspects of goods and services supplied by others and assess their contribution to the potential environmental impact. The accompanying example is offered to help clarify the intent of the requirement.

Monitoring and Measurement In Environmental Management System (EMS)

Monitoring and Measurement In ISO 14001 Environemntal Management System Standards

The Monitoring and Measurement section contains two requirements:

1) Measurement and monitoring of environmental performance associated with operations that can have a significant impact on the environment; and

2) Calibration and maintenance of equipment used for environmental monitoring and measurement.

Monitoring and Measuring of Performance — This section calls for a“procedure to monitor and measure… key characteristics of… operations that can have a significant impact on the environment.”

Note that the section does not specifically require the organization to monitor and measure the significant environmental impacts of its products or services. As a practical matter, however, organizations should establish measurements over all environmental aspects that they determine are significant irrespective of whether the impacts relate to an activity, product, or service.

This section also requires the documentation“of information to monitor performance, applicable operational controls, and… environmental objectives and targets.” §4.6,

Management Review, requires that environmental performance and achievement of objectives and targets become inputs into the Management Review (sub-sections c & d).

Calibration and Maintenance — The requirement of having a calibration system is to ensure that measurements are reliable and accurate. A calibration system may be developed following these steps:

· Identification of measurements to be made;

· Identification of equipment, instruments, hardware and software to be used;

· Identification of the testing methods to be used;

· Determination of the accuracy and precision required or desired;

· Definition of calibration procedures;

· Use of the system;

· Establishment of records;

· If equipment is found to be out of calibration, corrective action; and

· Improvement of the system as necessary.

DOE Policy on ISO 14001

DOE Policy on ISO 14001

An early approach on ISO 14001 was to require DOE contractors to develop an ISO 14000-like EMS through a DOE-wide Order. Some contractors did not like the implication of the draft Order would ‘require’ a ‘voluntary’ standard. Although some viewed the draft Order as broad and flexible, the Order was never finalized. Likewise, largely due to a change of administration,DOE was not able to establish a formal Policy regarding ISO 14001.

The current approach within DOE is to encourage voluntary implementation of an environmental management system as an integrated component of the contractually-required Integrated Safety Management System (62 FR 34841).4 Further, DOE encourages implementation of an environmental management system where it makes good business sense for the individual site. The voluntary approach is supported by the White House Office of Science and Technology Policy,5 and the integrated approach has been recognized as acceptable by EPA.6 DOE is also actively involved with the standard both at DOE sites and through an Interagency Working Group on ISO 14000. In addition, many DOE contractors are implementing ISO 14001 where it makes business sense for their individual site. Implementation is seen in a variety of ways from full third-party certification to implementation of various aspects of the standard.

INTEGRATING THE NATURAL STEP ELEMENTS INTO ENVIRONMENTAL MANAGEMENT SYSTEMS

In 1988, Dr. Karl-Henrik Robert began the process of developing the principles and objectives that have become known as The Natural Step.

Robert convened a group of over 100 Swedish scientists and asked them to develop a vision for a sustainable society based on the scientific principles. The Natural Step framework (Robert, 1991) was the result of this effort and is becoming widely recognized.

In this framework, there are four underlying principles or conditions and four guiding objectives.

These system conditions are:

Nature should not be subject to systematically increasing concentrations of substances extracted from the Earth’s crust;

Nature should not be subject to increasing concentrations of substances produced by society;

Nature should not be subject to systematically increasing degradation by physical means; and

People should not be subject to conditions that systematically undermine their capacity to meet their needs.

These conditions can be converted to four objectives that are more easily understood:

Eliminate our community’s contribution to fossil fuel dependency and to the wasteful use of scarce metals and minerals;

Eliminate our community’s contribution to dependency upon persistent chemicals and the wasteful use of synthetic substances;

Eliminate our community’s contribution to encroachment upon nature; and Meet human needs fairly and efficiently.

To apply The Natural Step, Boisvert et al. (1999) recommend an A-B-C-D approach: Awareness, Baseline Analysis, Compelling Vision, and Down to Action. Kent County chose to align its program with The Natural Step because of its simplicity and scientific basis.

An environmental management system (EMS) is a set of processes and practices that enable an organization to reduce the environmental impacts from its operations and increase efficiency. It helps the organization to systematically manage its environmental “footprint.” Alternatively, according to the ISO definition (ISO, 2004) an EMS is “a part of an organization’s management system used to develop and implement its environmental policy and manage its environmental aspects.” It is built upon the concept of continuous improvement and follows a four element Plan-Do-Check-Act cycle. The EMS is an evolving process and is consistently modified to accommodate new information, changing circumstances and changes in organization priorities.

The critical components of each of the four elements are:

Planning, includes identifying environmental aspects and establishing goals [Plan];

Implementing, includes training and operational controls [Do];

Checking, includes monitoring and corrective action [Check]; and

Reviewing, includes progress reviews and acting to make needed changes to the EMS [Act].

There are a variety of reasons that an organization may develop and implement an EMS. The reasons are many and varied and often depend upon the type of organization. A business with international offices has different reasons than a public agency to develop and implement an EMS. Table 1 provides a list of the most common of these reasons.

Some disadvantages to developing and implementing an EMS relate to the costs associated with development of the program and include:

An investment of internal resources, including staff/employee time;

Costs for training of personnel;

Costs associated with hiring consulting assistance, if needed; and

Costs for technical resources to analyze environmental impacts and improvement options, if needed.

Critical factors that assure the success of any management system include:

Commitment from senior management;

Designated staff including a Core team to act as a cheerleader and a representative trained in the program;

Involvement of all employees in the covered fenceline;

Dedicated resources;

A link to the overall strategic planning of the organization;

Sufficient time to develop and implement the program;

Proper follow through on the checking and acting components; and

A willingness to make the cultural shift required for the program to succeed.

The ISO 14001 guidance lists 17 elements, shown in Table 2, as the foundation of an EMS.

Several documents and publications cover the various elements of an EMS in detail. One of these is the US EPA publication “Achieving Environmental Excellence: An Environmental Management Systems (EMS) Handbook for Wastewater Utilities,”