Posts filed under 'ISO 14001'
Enviro-Lean® – Next Generation EMS
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’re the Auditor – Fall 2009
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?
Green House Gas, ISO 14000 and USEPA
ISO 14001 is widely recognized but many environmental professionals may be less familiar with the other ISO 14000 series. This article discusses the ISO 14000 standards that cover Green House Gas emissions (ISO 14064-1, 14064-2, 14064-3 and 14065) and provides some insight into how these standards are influencing USEPA GHG rule making.
A basic understanding of the principals of these documents and their interaction is a great place to start for those wanting to learn more about the technical and aspects of GHG inventories and reductions projects. They have also been used by USEPA as they begin to grapple with the task of creating a framework to ultimately regulate GHG emissions in the US.
Recently USEPA has published proposed rules for regulating GHG emissions. You can download the proposed rules from our website at http://www.envcompsys.com/ghg/EPA_ghg_041009.pdf . The proposed rules will require facilities emitting 25000 tons per year of GHG’s to report these emissions to USEPA. These are some of the first GHG rules proposed by USEPA and comments by interested parties are due by June 9, 2009 ECSI intends to submit comments specifically on how EPA intends to verify that the inventories submitted by reporters are accurate. A summary of our comments is at the end of this article.
ISO 14064 Series
The following is a brief summary of each of the ISO GHG standards and guidance.
ISO 14064-1 — Greenhouse gases —Part 1: Specification with guidance at the organization level for quantification and reporting of greenhouse gas emissions and removals
This part of ISO 14064 describes principles and requirements for designing, developing, managing and reporting organization- or company-level GHG inventories. It includes requirements for determining GHG emission boundaries, quantifying an organization’s GHG emissions and removals, and identifying specific company actions or activities aimed at improving GHG management. It also includes requirements and guidance on inventory quality management, reporting, internal auditing and the organization’s responsibilities for verification activities.
These inventories are similar to the annual air emission inventories that many states already require but are more detailed in their required approach and include different emissions (GHG chemicals) and calculation methods.
ISO 14064-2 — Greenhouse gases — Part 2: Specification with guidance at the project level for quantification, monitoring and reporting of greenhouse gas emission reductions or removal enhancements
ISO 14064-2 focuses on GHG projects or project-based activities specifically designed to reduce GHG emissions or increase GHG removals. It describes how an organization should proceed when it is trying to do a project that will actually reduce the amount of carbon equivalents that have already entered the atmosphere or are likely to enter the atmosphere. Projects are important because the can create carbon credits that can be potentially sold to others on carbon exchanges like the Chicago Climate Exchange.
Examples of GHG projects would be planting trees (or preventing harvest) for long term carbon sequestration. Burning landfill methane rather than emitting it directly to the atmosphere is another example of a potential GHG project. A consistent (standard) approach to calculating emission reductions from projects is important for the confidence of those buying the credits as being “real” reductions. Carbon credits have value and the potential exists for those claiming emission reductions to inflate the amount of the reductions. Standardization in calculation methods will help to limit the potential for inflated emission reduction estimates
ISO 14064-3 — Greenhouse gases — Part 3: Specification with guidance for the validation and verification of greenhouse gas assertions
ISO 14064-3 details principles and requirements for verifying GHG inventories and validating or verifying GHG projects. It describes the process for GHG-related validation or verification and specifies components such as validation or verification planning, assessment procedures and the evaluation of organization or project GHG assertions. ISO 14064-3 can be used by organizations or independent parties to validate or verify GHG assertions.
Validation and verification bodies (VV’s) provide an independent opinion of the accuracy of the GHG inventories and GHG reduction projects which improves confidence to others like customers or regulatory agencies who rely on these statements and assertions. This is accomplished by the VV’s performing an audit according to this part of the ISO 14064 series and issuing a statements as to the accuracy of the organizations assertions about their GHG performance.
ISO 14065 — Greenhouse gases — Requirements for greenhouse gas validation and verification bodies for use in accreditation or other forms of recognition
This standard describes how organizations (such as ANSI) accrediting validations and verification bodies (VVs) must perform the accredition process including accreditation audits. The American National Standards Institute is currently the only organizations in the US authorized by the International Accreditation Forum to provide these accreditations to VVs. A list of the VVs accredited by ANSI is posted on their website at https://www.ansica.org/wwwversion2/ALLdirectoryListing.asp?menuID=200&prgID=200&status=4
ECSI is currently under contract to ANSI to perform audit services on ANSI’s behalf of the VVs they are in the process of accrediting. This is the area that we will focus our comments on in our comments to the USEPA proposed GHG rules. The following is a brief summary of or comments
ECSI Comments on USEPA Proposed Mandatory GHG Inventory Reporting Rules
J. Rationale for Verification Requirements
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 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 USEPA 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.
You’re the Auditor
Here is a chance to put yourself in the auditor’s shoes and identify potential nonconformances. The objective of this exercise is to review the situation presented and determine if a nonconformance to the ISO 14001 standard exists. For those of you who have not committed the standard to memory, you may want to pull out your copy to use as a reference. If you need a copy of the standard one can be purchased from ANSI. Here is also a web address:
You can post your answers anonymously to the blog where we can discuss various answers with others participating. I will post what I believe are the best answers to this questions in a week or two and notify those who have posted to the blog when I do so. Have fun with this. My students in the ISO 14001 EMS-LA course find this to be one of the most fun and valuable parts of the course.
Instructions:
1. Read the situation carefully
2. Decide which ISO 14001 clause or clauses may apply.
3. If you think more than one clause applies choose the one that you think fits best.
4. Identify what is wrong with the situation
5. Identify the requirements within the applicable clause of the standard.
Here is an example:
The documented emergency response procedure indicates that a test of the organizations ability to respond to emergencies will be tested at least annually. When interviewing the Environmental Management System Representative (EMR) you ask for evidence that the emergency response procedure had been tested for effectiveness. The EMR states that the last test was performed three years ago. The EMR also states that they had planned to do another test several months ago but have been unable to perform it due to layoffs at the plant and curtailed work schedules.
Which ISO 14001 clause best applies?
4.4.7 —Emergency Preparedness and Response
What is the Problem (evidence)?
The organization was not able to show if had performed a periodic test of the emergency response procedure as required by its own procedure.
What is the requirement?
The organization shall establish, implement and maintain a procedure(s) to identify potential emergency situations and potential accidents that can have an impact(s) on the environment and how it will respond to them.
The organization shall also periodically test such procedures where practicable.
You’re the Auditor — The Situation/Evidence
During an ISO 14001 at a plastic injection molding company you discover that the company has begun manufacturing their own injection molding tools (molds) to use in their injection molding machines. In the past, these were always being manufactured by an outside source. Review of the organizations list of environmental aspects reveals the new environmental aspects have been introduced by the new process. These are waste coolant and solvent cleaning waste. You find that these new aspects have not been added to the list of environmental aspect for the department. When you interview the tool room team leader they indicate that this oversight had been found in a previous internal audit performed six months ago and that they were in the process of correcting this nonconformance. You are not able to find any other evidence that this nonconformance from the previous audit had been addressed.
Which ISO 14001 clause best applies?
What is the Problem (evidence)?
What is the requirement?
Post your answer here or check back in a week or so to review what others came up with and to see the correct answer(s).
ISO 14001 Registration – How it Works
The process of becoming registered to ISO 14001 can be confusing. Common questions we are asked include the following:
- Who is qualified to issue ISO 14001 Registration Certificates?
- Who is qualified to perform the registration audits?
- How long is a certificate good and what is the registration process?
These are a few common questions asked by organizations considering implementing an EMS which will be explained here.
What Organizations are Qualified to Issue ISO 14001 Certifications?
Authority to issue internationally recognized ISO 14001 certificates are linked to the International Accreditation Forum. The International Accreditation Forum, Inc. (IAF) is the world association of Conformity Assessment Accreditation Bodies and other bodies interested in conformity assessment in the fields of management systems, products, services, personnel and other similar programs of conformity assessment. Its primary function is to develop a single worldwide program of conformity assessment which reduces risk for a business and its customers by assuring them that accredited certificates may be relied upon. IAF members accredit certification or registration bodies that issue certificates attesting that an organization’s management, products or personnel comply with a specified standard (called conformity assessment).
In the United States ANAB is the main accrediting body for the registrars who actually issue the ISO 14001 Certificates. ANAB is a member of the International Accreditation Forum and a signatory of the IAF multilateral cooperative arrangements (MLAs) for QMS and EMS. Through the IAF MLAs and the Multilateral Cooperative Accreditation Arrangement, ANAB cooperates with other accreditation bodies around the world to provide value to its accredited CBs and their clients, ensuring that accredited certificates are recognized nationally and internationally. The global conformity assessment system ensures confidence and reduces risk for customers engaging in trade worldwide.
At last count ANAB had accredited 45 organizations (28 located in the USA) to issue ISO 14001 registration Certificates.
Registrars have been accredited to issue ISO 14001 certificates by ANAB. ANAB evaluates each registrar against the requirements ISO/IEC 17021 Conformity Assessment – Requirements for Bodies Providing Audit and Certification of Management Systems when determining if the registar should be authorized to issue ISO 14001 Certificates. Accredited registrars hire competent auditors to perform the registration audits and provide a record of the evidence reviewed as part of the auditor’s recommendation for or against registration of the organizations being audited.
Which Individuals are Qualified to Perform ISO 14001 Registration Audits for Registrars?
One of the requirements of ISO 17021 which must be met by all registrars is that the auditors performing audits on behalf of the registrar are competent to do so.
7.2.5 The certification body shall have a process to achieve and demonstrate effective auditing skills, including the use of auditors and audit team leaders possessing generic auditing skills and knowledge, as well as skills and knowledge appropriate for auditing in specific technical areas. This process shall be defined in documented requirements drawn up in accordance with the relevant guidance provided in ISO 19011.
ISO 19011 is specific guidance for registrars on how to establish audit programs and determine auditor competence.
Auditors can demonstrate they have achieved a level competence through personal certification by RABQSA International which is itself accredited by JAZ-ANZ. However, this certification alone is not sufficient evidence to ANAB that auditors working for registrars are competent to perform audits. In addition the registrar must, at a minimum observe the auditor’s performance during an actual audit before they are deemed competent by the registrar.
Figure 1 shows the links between the various organizations making up the registration process.
How is the ISO 14001 Registration Process Performed?
ISO 14001 Certificates are good for a period of three years assuming the organization successfully completes a series of surveillance audits during that three year period. The registration process begins with a documentation review performed by the auditor to determine if the organization has addressed all the elements of the ISO 14001 Standard. The outcome of the document review can be a recommendation by the auditor to proceed to the registration audit process or a recommendation to delay the registration process until the organization has addressed deficiencies identified by the auditor during the Document Review.
The registration audit begins with what is often referred to as a Stage 1 assessment. The lead auditor visits the site for a day or so to review the organization’s environmental aspects and verify conformance with some of the basic ISO 14001 requirements that could not be verified during the Document Review. The purpose of the Stage 1 audit is also to provide the auditor with additional information about the facility to enable them to prepare a plan for the Stage 2 assessment. The Stage 1 audit is also is a final check on the readiness of the organizations to undergo the Stage 2 Assessment.
The Stage 2 assessment is of longer duration (several auditors on site for several days) than the Stage 1 assessment this is a deeper drilling into the organization’s EMS that is performed in either the Document Review or the Stage 1 Assessment. The Stage 2 Assessment is where the audit team collects and records the evidence of the organization’s conformance to the requirements of ISO 14001 and the organization’s own EMS. This is the evidence that the audit team will submit to the registrar supporting their recommendation for registration.
Successful completion of the registration audit begins three year period that the ISO 14001 certificate is valid. During that three year period the registrar will perform periodic surveillance audits (at least once per year) to confirm that the EMS has sustained effectiveness in the ability of the organization to continually improve its environmental performance. At the end of the three year period the re-registration assessment is performed which is of similar duration and scope to the original registration audit.