ECSI Blog

 The choice to implement an ISO-type management system (14001, 9001, OHSAS 18001) is an important step for management to take toward sustainability. Mature and ready organizations understand that a proactive approach to managing risk is almost always the best approach for the business.  Managers also understand that any investment made in a management system needs to provide an attractive return, just like any other investment the organization might make.  Organizations need to avoid making mistakes while implementing a management system—mistakes that can dramatically limit the ability of the system to pay off.  Here are a few common misunderstandings/mistakes that often hinder organizations.

Misunderstanding the Purpose

The purpose of a management system should be to help an organization in systematically managing risks that threaten the organization.  Often, we find that organizations believe that the purpose of the management system is to “pass an audit” and satisfy customers’ or other stakeholders’ needs.

Organizations that recognize the value in investing in a management system to help them improve performance are much more likely to implement an effective system that easily passes audits.  Organizations that view the purpose of the of the management system as simply to pass an audit, on the other hand, usually implement an ineffective system that makes passing the audit more difficult.

Operating the System in Silo

Organizations new to management systems sometimes unknowingly establish the system in a “silo.” As a result, the system is operated almost in isolation from other business processes. This silo system is most common in organizations where the primary objective of implementing a system was to pass an audit rather than to enable to organization to continually improve its performance. 

Over-Documenting the System

In the past, the management system mantra was “Document what you do and do what you document.”  This led some organizations to over-document their systems to the point that they were overwhelmed with too many documents, many of which did not have a clear purpose.  Today, each document in the system needs to have a clear purpose and communicate important information like who does what, when, where, and how.

Investing Too Little in the Internal Audit Process

A good internal audit is key to an effective management system.  Skilled auditors can assist an organization in identifying potential risks before they turn into real problems.  Some organizations view internal audits as something they need to do to meet a requirement of a particular standard and to maintain their certification.  They put too little effort into training auditors, and as a result, the audits performed provide little or no information about the performance of the system.  Investing in auditor competence is a must if the system is to be effective, and if it is to provide an attractive return on investment.  Not all organizations have persons who are interested or capable of performing good audits, and the investment of achieving and sustaining an adequate level of competence is not cost-effective.  For this reason, some organizations are choosing to out-source their internal auditing needs, and with excellent results.

Misunderstanding the Corrective Action Process

Internal and external audits discover potential problems, and the corrective action process should fix them.  However, misunderstanding the corrective action process can  lead to the inability of an organization to address the problems or to take actions to permanently fix the problems.  Corrective actions need to be tracked and reviewed frequently, and the actions taken need to be based on the root cause of the problem and cannot be just a band-aid to temporarily stop the bleeding.  Many organizations find value in some type of corrective action tracking software that will help them keep on top of open corrective actions.

Reviewing Management Inputs Too Infrequently

A well-engineered management system collects information about the performance of the organization and presents it to top management in an “actionable” form.  If management review is viewed as a once- or twice-per-year activity that  needs to be done only to satisfy an auditor, the system is likely to fail to achieve its objective.  Elements of management review should be integrated with the other regular business management meetings, where the financial performance of the organization is reviewed.  Management review inputs like the status of corrective actions or the progress toward meeting system objectives should be reviewed more frequently than once or twice a year to avoid surprises. 

Poorly Defining Performance Objectives and Measurements

Performance measurements are sometimes referred to as “metrics.”  These metrics are measurements an organization makes to periodically check how well it is doing toward achieving performance objectives.  The performance objectives must be chosen carefully and must have extended duration for performance improvements.  An example of a poor objective would be “replace all lights.”  An objective like this is not measureable. It is actually a task to be performed as part of a larger objective, which is “to reduce energy consumption.” 

Performance measurements should also be tied to some measure of production.  This is sometimes called “normalizing the measurement” to adjust for increased or decreased production levels.  Normalizing the measurement makes it more meaningful to management. 

By ML Juszczak, Project Manager, ECSI GHG Programs

The USEPA has issued its Greenhouse Gas Rule in the form of 40 CFR Part 98.  Companies subject to the rule must begin reporting annual greenhouse gas emissions for the year beginning on January 1, 2010.   Although the rule fills hundreds of pages in the Federal Regiater,  it still leaves important questions unanswered.  For example, what is  the proper way to sample coal for laboratory analysis?

Coal must be analyzed for calorific value to determine the fuel’s high heat value, or HHV, in two of the four CO2 emission calculation methodologies defined in the rule (specifically, Tier 2 and Tier 3).  A facility choosing either of these methodologies must sample and analyze each lot of coal that it receives (a lot being a “shipment or delivery of a single fuel comprised of a shipload, barge load, group of trucks, or group of rail cars”.)   The rule also specifies in §98.34 that ASTM D 5865-

07a – Standard Test Method for Gross Calorific Value of Coal and Coke be used.  If you read no further, you may think this is a fairly simple and straightforward matter.  As is often the case, however, this matter is neither simple nor straightforward.

The difficulty that arises does not concern the analysis of the sample, but rather how to compose a sample, how often to compose it and, how to prepare it prior to analysis.  Two other ASTM standards enter the picture:

• ASTM D 2013-07 – Standard Practice for Preparing Coal Samples for Analysis
• ASTM D2234/D2234M-09a – Standard Practice for Collection of a Gross Sample of Coal

 These are incorporated into the rule by reference in §98.7(e), and they are interrelated as follows:

• ASTM Method D5865-07 references  ASTM D 2013-07, and
• ASTM D 2013-07 in turn references ASTM D2234/D2234M-09a.

ASTM D2234 requires that 15 “increments” of mechanically cleaned coal, or

35 “increments” of raw coal, be gathered at separate times from each lot to form a “gross sample.”  There are three increment quantities:

1 pound for coal with a top size of ?“

 3 pounds for coal with a top size of 2“

 7 pounds for coal with a top size of 6“

Therefore, a gross sample can be from 15 pounds all the way up to 245 pounds. 

ASTM D2234 also defines a lot as 1,000 tons of coal.  If a true lot is larger than

1,000 tons, sampling increments are either increased proportionately, or the total quantity is subdivided and each sub-lot is sampled individually.  This is a significant difference from the EPA’s definition of a lot found in §98.34.

ASTM D 2013-07 prescribes how the gross sample is to be ground, mixed, and divided using milling and rifling equipment (rifling is a type of sorting process) to yield a quantity that remains representative of the whole, while being suitable in size for analysis.  The test method in ASTM D 5865-07a calls for 0.8 grams to 1.2 grams of material with a particle size of ?250 micrometers. 

The simple matter of gathering a sample of coal and sending it to the laboratory now has become quite an arduous procedure requiring some sophisticated and specialized apparatus—apparatus that many facilities may not have access to.  And, it may need to be done much more frequently than once per shipment.   While

40 CFR Part 98 does not specifically prescribe the above sampling and preparation methods, it names no alternative protocol either.  A valid conclusion would then be that the ASTM standards are intended to be part of the rule, and not adhering to them could result in a violation of the law.  Alternative interpretations will no doubt be made as the regulated community grapples with this new rule.  What procedures a company ultimately uses will need to be supported by sound reason, and tempered by its tolerance for risk. 

Here is the text of the USEPA’s response to our comments on their mandatory inventory rule.  This is not what we had hoped for but a least we were able to provide our viewpoint. 

Commenter Name: Kevin A. Lehner

Commenter Affiliation: Environmental Compliance Systems, Inc.

Document Control Number: EPA-HQ-OAR-2008-0508-0673

Comment Excerpt Number: 1

Comment: With regard to verification of inventory reports we believe USEPA has overlooked an important potential option and should review this option before selecting their final method for performing inventory reporting and verification activities. We believe USEPA should consider allowing reporters the option to either report directly to USEPA or to provide inventory reports verified by ANSI accredited ISO 14065 Verification and Validation Bodies through existing voluntary reporting organizations such as The Climate Registry. We believe that a thorough evaluation of this additional option for reporting and verification of inventory reports would show that most of the negative consequences of each of the three potential reporting options considered by USEPA could be avoided if this alternate approach were adopted by USEPA. With little additional effort, most voluntary GHG registries can adapt their reporting protocol to accommodate USEPA reporting requirements and emission calculation methods and transmit the data to US EPA on behalf of the reporter in a format acceptable to USEPA. USEPA would simply need to verify that the registries reporting protocol was consistent with USEPA’s and that the data reporting methods were in a format that could be easily accepted into USEPA’s recordkeeping and data analysis systems. Benefits of this alternate approach include; elimination of duplication of reporting by organizations already providing their inventories to the voluntary registries, overall reductions in effort and cost to USEPA for verification activities, higher stakeholder confidence in the accuracy of the inventory reports and, the flexibility for reporters to choose how they will transact required reports with USEPA.

Response: During the development of the rule, EPA considered a number of different options for verification of the reported data. EPA selected the self certification with EPA verification approach based on a number of factors that are discussed in detail in Section II.N of the preamble. Although we considered the hybrid approach suggested by commenter, we concluded this approach would not meet the needs of this program. First, in order to be relevant and applicable to the unique scope and specific requirements of this reporting rule, verification and accreditation systems would require substantial customization to this rule. Most programs that adopted a third party verification approach (e.g., CARB) found that they had to adapt existing programs to meet the specific needs of their program. Second, a reporting program with two or more different methods of verification would be more difficult to administer and place a greater burden on EPA resources. Third, receipt of emissions data from reporters selecting third party verification would likely be delayed due to the extra time required for third party verification. EPA has determined that direct submittal to EPA of annual emissions information and the data necessary to verify emissions will best ensure the availability of consistent, verified data for use in a timely fashion. EPA intends to work with the States to develop an efficient and timely system to share data and reduce the burden on reporters. See the preamble for the full responses on the emissions verification approach, the role of States, and relationship of this rule to other programs. For the memorandum “Review of Verification Systems in Environmental Reporting Programs” (EPA-HQ-OAR-2008-0508-047)

Recently we were asked to deliver an encore edition of a four day IMS Internal Auditor training course for one of our clients. They are a large manufacturing facility surviving the recession and gaining market share, in part because of their robust management systems. This organization has chosen to invest in the competence of their internal auditor staff,  recognizing the value and importance of the “checking” part of their management system.

The course is three days of intense classroom and actual on the floor auditing. This learn-by- doing course includes review of the similarities and differences of the ISO14001, 9001 and OHSAS 18001 standards and includes numerous activities. Actual department audits are performed, findings written and a closing meeting with management is held at the end of the course actual audit. Student competence is evaluated during the course through observation of each individual’s performance by the course instructors.

This updated version of the course includes a new section focusing on the Lean Six Sigma programs used at the facility and what internal auditors need to know to ensure the gains made from Lean Six Sigma projects are sustained by the organization. The fourth day of the training is targeted to the more experienced Lead Auditors and helps develop leadership skills and attributes. The course includes a test at the end to check the auditor’s knowledge of the subject matter and to help confirm that the auditors possess  adequate competence to perform value-added effective IMS audits.

One of the biggest obstacles organizations face when “going green” is where to start.  If not approached systematically the process can be frustrating and costly with  the end result not meeting the original objective.  Obtaining competent advice on where to begin will ensure that the end result (an effective EMS) will provide a good return on investment.

Some organizations are finding that over the years their EMS has become stale, ineffective,  and costly to operate. The typical reaction to this discovery is  “that ISO stuff is a waste of time and money”.  Unfortunately,  what they do not realize is that the failure of the EMS is largely due to misconception or misinformation of how to build and operate an effective EMS.

What is Enviro-Lean?

Enviro-Lean is based on the principals of continual improvement found in Six Sigma, Lean Manufacturing, and ISO. Enviro-Lean creates results and discourages non-value added bureaucracy.

Who can use Enviro-Lean?

The Enviro-Lean process can be used by any organization.  It is particularly well suited for small-to-medium sized businesses and government entities because these organizations are nimble and able to act quickly to take advantage of Enviro-Lean opportunities. Large organizations can also use Enviro-Lean to supplement in house Six-Sigma and lean processes to investigate and implement incremental performance improvements.

How long does it take to see results?

Enviro-Lean results are immediate.  The first step in the process assesses areas of potential risk and controls unacceptable risks to a tolerable level.  These could include risk from unplanned releases, regulatory non-compliance or other financial exposure.  The second Enviro-Lean step identifies improvement areas within the organization  where significant cost reduction could be achieved.  The Enviro-Lean process systematically investigates these areas, identifies feasible options with attractive ROIs,  and presents these to management for review and approval.  When implemented these improvements prevent pollution.

How much does it cost?

Enviro-Lean requires some investment of effort by an organizaiton but that investment pays for itself in a short period of time (usually 6 months or less).  Contact us for more information at envirolean@envcompsys.com

You are performing an audit at a manufacturing facility that has been registered to ISO 14001 for over 4 years. While touring the facility grounds you observe several industrial sized chillers that appear to be out of commission. When interviewed the environmental manager indicates that these contain CFC and were decommissioned about six months ago and are in the process of being sold to another organizations. You are unable to find any information in the EMS regarding the legal status of these units or evidence of records of CFC removal.

What clause of the standard applies?
What’s the problem?
How would you write the non-conformance?

A recent conference in Milwaukee held by the U.S. State Department received public comments on the U.S. position on global warming to be presented by the U.S  State Department at the United Nations Framework Convention on Climate Change in Copenhagen, Denmark this December (see http://unfccc.int/2860.php). This is an important convention where the U.S.  along with other nations may commit to reducing global GHG emissions. From the tone of the meeting it sounds like the State Department is more willing to cooperate with global GHG emission reduction initiatives than it was at previous meetings but very few details were provided on what the U.S. was willing to try to negotiate in Copenhagen.

The conference audience was a good mix between manufacturing, business and academic interests. The meeting began with the State Department representatives making a statement to the effect that there was “no longer any reason to doubt the scientific basis for global warming and the role GHG emissions play”. Many in the audience were  quick to challenge this statement insisting that the science was not at all-conclusive and expressing the opinion that there was little evidence that GHG emission cause global warming.  Most in the audience also expressed the concern that cap and trade regulation would seriously damage affected U.S. businesses’ competiveness with developing nations who would not likely adhere to GHG control requirements.

This is the same debate that has persisted for at least the last 30 years and is likely to continue for at least another 30. Personally,  I am not convinced that there is a concrete, demonstrable link between GHG emissions and global warming. I think it is plausible that such a link exists but have not yet seen compelling indisputable evidence of the connection. But I really don’t think that a concrete link is needed for us to want to control GHG emissions, especially those associated with energy use.

There are other strategic issues with potential global warming that I believe should be driving our efforts to reduce these emissions. I believe that the security of our nation, which relies heavily on non-renewable sources of energy to sustain its standard of living,  is not as strong as a nation that is less reliant on non-renewable energy. If the United States continues to delay development of technology to improve our use of renewable energy, and we continue to deplete limited supplies of non-renewable energy, there may come a time when we have reached the  tipping point. A point where we are unable to sustain our standard of living and no longer have the resources to invest in development of alternate renewable energy sources

If cap and trade is able to create additional incentive to limit the use of non-renewable energy in this country I believe that may be a good thing. If we can also hedge our bets about whether or not GHG emissions are causing global warming it seems like a no-lose strategy. It seems there is more to gain than to lose by controlling the use of non-renewable energy and if cap and trade will help us we should look past fears of change and move ahead on reducing GHG emissions here in the U.S. and around the world.

Organizations wanting to be prepared for the USEPA mandatory GHG Emission Inventory requirements coming this  November now have a source of information and assistance to guide their efforts.  Our role  as ANSI GHG Verification and Validation program Lead Auditors has given us unique insight into how USEPA and others will be operating GHG inventory and Cap and Trade programs.  Equipped with our unique insight we are now offering assistance to organizations for submission to the following GHG Inventory and Offset Trading programs:

• The Climate Registry (TCR), 
• The Climate Action Reserve (CAR), 
• The Chicago Climate Exchange (CCX)
• Midwest GHG Reduction (Cap and Trade) Accord
• Western Climate Initiative
• Regional Greenhouse Gas Initiative
• Voluntary Carbon Standard

 Call us for more information at 920-648-4134 or email us at ghgprograms@envcompsys.com

Dear Friends, 

I want to thank our loyal clients and customers who we have continued to assist through these difficult economic times.  I look forward to improved conditions when their investments pay off with a competitive advantage.  The slower-than-usual period has been used to carefully examine our service mix, how we market services,  and how we deliver them to our clients.  Environ-Lean^® and our GHG climate change programs discussed in this  issue are examples of additions and changes we have made. We are keenly aware of and focused on how our management system consulting, training, and auditing services integrate with emerging GHG and climate change national and international regulatory initiatives.

The good news is that despite the economy all of our associates are still with us and I was able to find the time to guide several sea kayak trips on Lakes Superior and Michigan this summer.  The trips are actually a lot of physical work for not much pay but it’s sort of like getting a paid vacation, which is something most small business owners don’t often experience.

 I hope you find the articles in this issue valuable and apologize for the rather large size (300 kb) of the file that gets delivered to your inbox.  We hope to make it smaller soon. As always please, provide your feedback on our blog www.envcompsys.com/blog or email us at kalehner@envcompsys.com

 Kevin A. Lehner, EMS-LA, CHMM
President
ECSI

Newsletter Format and Distribution

 Dear Friends & Colleges,

 After some internal debate around the virtual conference table here at ECSI we have decided to distribute our second newsletter the same way as the first.  We were considering using a email distribution company, either Constant Contact or My Emma but found that, although the content formatting was a bit easier to control and the size of the emails delivered to your inboxes was only 20 percent of the size of this email, some email programs excluded important content.  In addition there is a monthly fee for this service and we did not plan to use many of the behind the scenes features such as tracking who opens the email when and did they forward it to someone else. 

 At present we use a program called Microsoft Publisher to create the newsletter and then Jennifer and I email it out to each an every one of you, one at a time to prevent some of the negative consequences of batch emailing it.  So it is really a home cooking (slow cooking) sort of process that is done over several weeks.  It can be frustrating at times to have to focus so much attention on the process of the newsletter rather than the content but we are confident that as we learn more and grow the list of those wishing to receive it we will also find the right solution for delivery.

Send us any comments or questions you have about the newsletter content, format or delivery or post a comment on the ECSI blog. Have a great rest of the spring and expect the next letter later this summer.

Kevin A. Lehner, EMS-LA, CHMM
President
Environmental Compliance Systems, Inc.

Wendy Ward joins ECSI

Wendy joined the team in late April as an auditor, project manager and will be assisting with business development.  Wendy’s has a marketing degree from Marquette University.  Her most recent professional experience was with Veyance Technologies (Formerly Goodyear Engineered Products) as their Internal Audit Coordinator.  Veyance is registered to TS 16949, ISO 14001 and OHSAS 18001.

 Mike Juszczak Joins ECSI

 Mike joined us in early May of this year as a Project Manager and Auditor.  Mike has an Industrial Engineering degree from the University of Wisconsin.  His past experience includes positions with American Packaging in Columbus, WI and Uniroyal, Stoughton, WI where he was a Production Superintendent and Safety Manager.  He has experience in environmental regulatory compliance including emission inventory, air permitting, hazardous waste, and wastewater management.  This experience will help us expand our ability to help our clients in the area of environmental and health and safety compliance and auditing.  Mike recently assisted us in an OHSAS 18001 internal audit for one of our clients.

Jennifer Miller Returns to the Audit Trail!

 As some of you know Jennifer Miller (Smith) gave birth to a baby girl in November 2008 resulting in a brief interruption in here ability to perform audits with us.  In April, Jennifer returned to what we auditors fondly refer to as “the audit trail”.  Last month Jennifer waded back into the water when she helped us with an ISO 9001:2008 internal audit we performed for one of our clients.  We are pleased to have her back as she manages the challenges of raising a family and being on the road to help our clients perform audits.