ECSI Blog

Recently we traveled to a client located a bit north of New Orleans to assist in the initial phase of a project to implement an integrated environmental health and safety management system (EHSMS).  The clients’ goal was to becoming registered to ISO 14001 and OHSAS 18001 Management System standards by the early next year.  The company manufactures large transformers for the electricity power and distribution industry and had been recently sold to another organization which was encouraging our client to implement these systems and become registered by a third party.

The first phase of the project was to travel to the facility for a 2 day on-site visit to perform a gap assessment and to assist in identification of environmental aspects. Wendy Ward who is one of our new associates was along on the trip to assist with the rigorous schedule needed to complete all of the tasks in that short period of time.  The visit started with a brief facility tour (about 1 hour) to get familiar with the processes being operated and the facility layout.  One of the fun parts of our work is learning about new manufacturing processes. On this  trip we got to see the manufacturing processes for the sub components of a large transformer and observed assembly and testing of these transforms.

The gap assessment began immediately after the tour and was straight forward as the organization was already registered to ISO 9001:2008.  They were familiar with the vocabulary of ISO type management systems and able to show us the elements of the system we were looking for.  Wendy’s experience as a TS 16949 auditor allowed her to cover some of the elements common to all systems such as document control, awareness and competence, internal audits, non-conformance corrective and preventive action and so on while I was able to focus on assessing other elements such as environmental aspect identification, hazard identification and risk assessment, legal and other requirements, objective and targets and management review.

We completed the gap assessment by mid-afternoon and then began the environmental aspect identification part of the project.  We had previously discussed options for identifying environmental aspects that have been popular in the past.  We discussed the advantages and disadvantages of various methods and the client selected the approach we recommended.  Over the years we have developed a process for performing this work that is much different than the traditional Failure Mode Effects Analysis (FMEA) type approach used by most other organizations.  Our process is simple to implement, engages the facility department personnel in the process so they get to decide what is significant and people actually think its fun to do. 

The traditional FMEA type process differs in that it requires numeric evaluations of several attributes of each aspect which is often tedious and in our opinion diminishes the value to the outcome of the process. The FMEA approach usually results in a confusing list of environmental aspects that uses an arbitrary numeric value for determining which aspects are significant (those that the organizations cares about and intends to do something about.).  There are ways to tinker with the FMEA approach to make it more useful but in the end we believe its draw backs out weigh any perceived benefits from generating what appears to be a prioritized list of aspects.

Although initially extremely popular the old FMEA approach to aspect investigation is an unfortunate artifact of early efforts by quality management system professional to get their arms around ISO 14001.  Unfortunately they selected a tool (FMEA) that, although helpful when assessing risk of failure in a manufacturing process, is ill suited for determining which environmental aspects of a manufacturing process are significant. 

There are strong opinions at ECSI about the negative effect the FMEA approach has had on  business perception of ISO 14001 and the effectiveness of many EMS’s.  Rather then go into my FEMA aspect rant here I will save it for a future newsletter when we talk about approaches to re-engineering ineffective EHSMS’s.

The approach we use to aspect identification creates a matrix that shows which aspects are present in which departments.  Anyone can easily see which environmental aspects are present, where they are and why the aspects are significant.  The matrix includes links to applicable legal requirements, operation controls and/or environmental management programs. Anyone including internal and third party auditors can easily understand how the organization is managing an aspect in a particular department.  This makes internal auditing much easier and facilitates the implementation process.  The aspect list can also be used as a training matrix because it shows which employees need to know what in each department.

Our role in the process is to help facilitate and guide the organization and act as an independent outside source of opinions and technical guidance.  The process is accomplished by assembling key staff from a department at the facility and the sketching a process map with help from the department representatives.  As the map is sketched we identify what materials are entering the process, how they are manipulated and what impacts result such as air emission, wastewater, solid waste.  As the process maps are being sketched one of the ECSI team, in this case Wendy, recorded the environmental aspects that we discovered during the process.  Some processes however don’t lend themselves well to a process mapping approach such as the Maintenance Department.  In these cases we simply brainstorm and record the aspects based on discussion of what tasks are being performed in the department

After we have completed the process map and identified the aspects in the department we go back to the top of the list and decide which of the aspect is significant and why.  We identify any existing or necessary future operational controls (standard operating procedures) for some of the significant aspects and we identify objectives and targets to improve environmental performance of others.  Some significant aspects will have both an operational control and an objective and targets.  Some will only have one or the other.

The last step in the aspect identification process is to link the significant aspect to the specific regulatory (or other) requirements that apply to the aspect.  It is important to have at least one competent experienced environmental professional in the room during this phase of the aspect identification process who knows the state and federal requirements and can assist in identifying these. 

We finished the aspect identification process in the late afternoon on the second day of the visit and then conducted the visit and gap assessment closing meeting.  The outcome of the project was achieved onetime and to the clients satisfaction.  The next phase of the project is to perform the Hazard Identification and Risk Assessment and fill the other gaps identified in the gap assessment. 

As always, I am interested in your opinions of this article so I encourage you to leave a comment or questions here on the ECSI blog.