Author Archives: Kevin Lehner

About Kevin Lehner

Kevin has been president of ECSI for over 25 years. His practice focuses on environmental and health and safety management systems training, consulting and auditing. He is an active member of the US Technical Advisory Committees to ISO 14001 and ISO 45001. He represents that USA at international meetings of these committees. He is also the lead developer of the CorrectTrack corrective action tracking app.

Revision to ISO 14001:201x Moving Forward

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As a member of the US Technical Advisory Group to ISO 14001 I traveled to Washington DC recently to attend meetings of the US TAG (TC 207).  Although TAG members are sworn to secrecy to help protect the US negotiating position on key issues I can say that the next version of the standard is likely to be unrecognizable in its form.  This is due to a big change at ISO headquarters compelling all standards revisions to conform to a new format called the “High Level Structure” or HLS.  What this means is that the ISO 14001 standard will be dramatically rearranged to fit neatly into a format that ISO believes will facilitate better understanding of the intent of each standards requirements.

ISO believes that all standards should have a uniform format so the current work of TC 207 is to disassemble the existing ISO 14001:2004 standard and reassemble it within this new structure.  If you are interested you can see what the HLS looks like here.

The other changes to the standard are not expected to include new requirements.  There are however areas where the US TAG is working to clarify the intent of the standard.  These areas include revised language on how organizations decide what their EMS will manage (significant environmental aspects) and the need to continue to include preventive action as a separate activity in the EMS.

The international ISO 14001 group is meeting in Rochester NY later this month when the US TAG will present its ISO 14001 revision proposal.  It will be interesting to see what comes out of Rochester and what the rest of the international community is thinking about how to align the current version of ISO 14001 with the MLS.

What to Do About Climate Change – Our Ideas at ECSI

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Our approach to climate change is based on assessment of potential business risks to our clients from inaction.  We believe there are actions that our clients can take to improve their competitive position and reduce their carbon footprint.  These actions are good business practices and make sense regardless of which side of the climate change political debate you are on.

A significant portion of a business’s cost is associated with energy use.  Coincidentally, energy use (carbon emissions from combustion of fossil fuels) is one of the most often sited potential causes of climate change.  Our approach is to focus on the dynamic aspects of our clients’ energy use to help them improve performance.  Improving energy performance provides the following benefits:

  • Long term return on investment 
  • Strategic hedge against future energy cost increases 
  • Credibility as a “Greener” Organization 
  •  Strategic positioning for future potential regulatory changes

We see minimal downside risk to business endeavoring to proactively manage their energy use by:

  • Establishing an effective energy management system (EnMS) 
  • Performing energy reviews 
  • Establishing energy baselines 
  •  Identifying key energy performance indications 
  • Developing energy management action plans

ISO 50001 is an International Standard describing the minimal requirements for a continual improvement based EnMS.  As a voting member on the ISO 50001 technical advisory group TC 242 we monitor developments and participate in international consensus building on these important issues and encourage you to learn more about how an EnMS can be good for your business.

Disappointing News from ANAB

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In late spring we meet with ANAB at their headquarters in Milwaukee to kick off the process of becoming an ANAB accredited registrar. Our hope was to issue ISO 14001, OHSAS 18001 and ISO 50001 accredited certificates to business in the upper Midwest.  To our surprise during that meeting ANAB made it clear that consultancies are prohibited from accreditation as certification bodies.  In ANABs eyes consultancies and anyone involved in governance of a consultancy is incapable of impartiality when performing ISO certification assessments.

We continue to believe that consultants make good auditors and vice versa.  The financial audit sector (accounts) has operated successfully for many decades using the model to ensure competency of both auditors and consultants.  We believe that ANAB, IAF and ISO’s conclusion that the threats to impartiality by consultancies are irreconcilable is not based in fact.  We also believe that the threats of financial self-interest by ANAB accredited certification bodies are at least as potent as any threat to impartiality from a consultancy performing certification activities.  This is because accredited CBs can (or should) only be allowed to generate revenue from one source, their certification activities.

We remain committed to trying to work with ANAB to find a way to offer ISO certification services in the upper Midwest but for the time being have placed this lower on our priority list of objectives.

Global Warming – Federal Appeals Court Ruling

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The following is an excerpt from Heck Associates July 1, 2012 Newsletter.  Werner Heck Associates is long time GHG consultant and auditor we have worked with on GHG V&V Body Accreditation audits.

 A federal appeals court on June 26 upheld a finding by the Environmental Protection Agency that heat-trapping gases from industry and vehicles endanger public health, dealing a decisive blow to companies and states that had sued to block agency rules. A three-judge panel of the United States Court of Appeals for the District of Columbia declared that the agency was “unambiguously correct” that the Clean Air Act requires the federal government to impose limits once it has determined that emissions are causing harm. The judges unanimously dismissed arguments from industry that the science of global warming was not well supported and that the agency had based its judgment on unreliable studies. “This is how science works,” they wrote. “The E.P.A. is not required to reprove the existence of the atom every time it approaches a scientific question.” In addition to upholding the E.P.A.’s so-called endangerment finding, the court let stand related rules setting limits on greenhouse gas emissions from cars and limiting emissions from stationary sources. Opponents had also challenged the agency’s timetable for enforcement and its rules singling out big polluters, but the court said the plaintiffs lacked the standing to do so.

During the week of June 25, record temperatures and wildfires have scorched the western United States. The National Climate Data Center reports that 41 heat records have been broken or tied since June 24, mostly in Colorado, Kansas and Nebraska, which is quite unusual for this time of year. Since June 23, a wildfire near Colorado Springs has burned over 18,000 acres, and 34 other large fires are still burning in the country. Scientists taking part in a conference call on June 21 arranged by the nonprofit science outreach group Climate Communication said that while they could not apportion blame to a specific factor, there was agreement that this week’s events fit into a pattern of extreme weather events and catastrophic fires that climate scientists predict will only worsen in decades to come. “What we’re seeing is a window into what global warming really looks like,” said Michael Oppenheimer, a geoscientist at Princeton University. “It looks like heat. It looks like fires. It looks like this type of environmental disaster.”

Posted in GHG

Rethinking Job Hazard Analysis

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Understanding potential occupational health and safety risks and how to control them is essential to any Occupational Health and Safety Management System (OHSMS). If done with skill, it can have immediate positive results. If not, the opposite effect of increasing potential risk and legal liability may result.

Limits of JHA/JSA

Job Safety Analysis (JSA) and Job Hazard Analysis (JHA) have been the mainstay in workplace hazard assessment for at least the last decade. These tools have helped organizations improve their incident rates but are now at the limits of what they can do to advance an organizations health and safety performance.

The JSA/JHA process provides a very detailed analysis of all potential hazards from each task of a particular job but the JHA/JSA process can be time consuming. Often the JHA/JSA process is limited to identifying job hazards and a listing of the operational controls used to reduce risk. Rarely do the JHA/JSA’s assess the remaining risk from the hazards after the control is in place. This leads to uncertainty if the hazard and associated risk have been controlled to an acceptable level or not. The question, “is the control in place adequate” and “is the job safe enough” remain mostly unanswered using the JHA/JSA process.

A Better Approach

New approaches introduced with the publication of OHSAS 18001 have been taking hold and producing excellent results in obtaining additional OH&S performance improvement. The new approach is called the “Hazard Identification and Risk Assessment Process” (HIERAP). This new approach helps quickly identify important job hazards and assess the level of risk associated with the job hazard. The output of this new approach is a prioritized list of hazards and risk which can be used as an ingredient in an overall OHSMS. With the prioritized list, an organization can focus its attention on what is most important (material) to ensure safety in the workplace.

A Few Important Considerations

  • Engage employees – They often understand the risks of their jobs better than anyone else
  • Develop a procedure – Think through details of the procedure and how you will us it and document the results. Include a risk matrix with clear definitions.
  • Work with Top Management – They have ultimate responsibility for determining how safe is safe enough.
  • Work Quickly – Establish a schedule to interview employees and capture their ideas about job hazards and risks. Stick to the schedule and avoid “paralysis by analysis”.
  • Have a Plan to Act – The results of the Hazard Identification and Risk Assessment process will be enlightening or even surprising. Make sure you have a plan to follow-up on the results of the HIRAP in a timely fashion

Finally, sometimes organizational dynamics can influence how the results of hazard identification and risk assessment are perceived at different levels of the organization.  Establishing the process/procedure and introducing it to top management before it is implemented can help avoid pushback from supervisory personal and managers.

ISO 50001 – What is it?

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ISO 50001:2011, Energy management Systems – Requirements with guidance for use, is a voluntary International Standard developed by ISO (International Organization for Standardization).

ISO 50001 gives organizations the requirements for energy management systems (EnMS).

ISO 50001 provides benefits for organizations large and small, in both public and private sectors, in manufacturing and services, in all regions of the world.

ISO 50001 will establish a framework for industrial plants; commercial, institutional, and governmental facilities; and entire organizations to manage energy. Targeting broad applicability across national economic sectors, it is estimated that the standard could influence up to 60 % of the world’s energy use.*

Here is a link for additional information on ISO 50001 http://www.iso.org/iso/iso_50001_energy.pdf.

Call us at 920-648-4134 to discuss how ISO 50001 can help your organization improve sustainability performance.

ECSI Appointed to US TAG 242 ISO 50001:2011

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We were recently honored with appointed to the United States Technical Advisory Group on to ISO 50001 – Energy Management Systems Standard. We are helping develop and represent the US position on important guidance that is currently under development and will be discussed by TC 242 in Dublin, Ireland April 30- May 4th.

Here Come the Bean Counters!

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Having lead hundreds of sustainability performance assurance engagements over the last several decades I admit bias but have seen first hand evidence that organizations exaggerate and in some cases misrepresent their sustainability performance. This is especially true when the marketing departments are tasked with the job of turning an organization green.

As non-financial sustainability performance information is relied upon to make important decisions about investment and other business relationships, assurance of organizations sustainability performance assertions will become more common. An important question is who will do this assurance work? Recognizing opportunity the financial accounting profession is hard at work tooling up to fill this emerging niche http://www.ifac.org/publications-resources/ifac-sustainability-framework-20

The confidences stakeholders can place in the results of an assurance engagement are directly proportional to the competence of those performing the audits. It will be interesting to see how the bean counters do at assessing environmental, health, safety and social performance as they endeavor to to learn the practice in this market.

Gap Assessment and Internal Audits

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If you are doing a Gap Assessment I would start at the top of the standard and march right through it clause by clause. Use the EMS manual as a reference and make sure all elements of the standard have been addressed.

If you are planning an internal audit I would consider using a process approach where you audit many of the clauses almost simultaneously in each department or functional area of the organization. The following is an example of a line of questioning you might consider when you are interviewing employees in a Maintenance Department (MD).

Auditor: What are some important environmental aspects of the maintenance department?
MD: We clean and paint equipment used in the mine so we generate solvent waste and we have air emissions from the spray paint operations.

Comment: If the aspects match those on the record required by 4.3.1 you have some evidence of conformance to 4.3.1 and 4.4.2. If you see parts cleaning operations and painting operations being performed but these have not been identified as environmental aspects you may have nonconformity to 4.3.1. If these aspects have been identified but the MD representative you interview has no idea about what an aspect is or any of the impacts from parts cleaning or painting you may have nonconformity to 4.4.2.

Auditor: How do you make sure that waste solvents are handled properly?
MD: There are some important laws we must comply with for these waste solvents and we follow our Waste Solvent work instruction.

Comment: You now have some evidence that they have identified the legal requirements 4.3.2 and have established operational controls of significant aspects 4.4.6.

Auditor: This section of the Waste Solvent work instruction says the waste solvent storage area will be inspected weekly and the results recorded on the inspection sheet. Can you show me a record of the inspection that was performed 2 weeks ago?
MD: Sure here it is.

Comment: With this question you are looking for evidence of Operational Control 4.4.6, Monitoring and Measurement 4.5.1, Internal Audit 4.5.5 and Record 4.5.4. You could even get Corrective Action 4.5.3 if problems are found during the inspections which were corrected.

Auditor: Can you tell me about what you do if you see a fire somewhere in the facility
MD: We have been trained in proper use of fire extinguishes so if I think I can put the fire out I will try. No matter what, I will call the designated emergency coordinator who will follow-up and I will evacuate to my designated assembly area in the parking lot across the street.

Comment: Here is evidence of 4.4.7 and 4.4.2 and maybe 4.4.3.

The potential audit trails you can follow in a department are almost endless and each trail should be able to give you evidence for one or more clauses of the standard.