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.

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.

Audits and the Good news – Bad News – No News Comparison – My opinion based on 30 years of EHS audit experience.

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Good news from audits is really no news for management. Good news from audits means that things are going as planned and there is no need for management intervention. System effectiveness has been confirmed through the audit process.

Bad news from audits is actually good news for management! The audit findings give management the opportunity to act (create incentive for change). Hopefully that change will correct the bad news situation discovered during the audit.

No News is Bad News. Organizations not performing audits have no means to assess the effectiveness of the management system. They are not getting information feedback about the organizations EH&S performance.

I encourage organizations to continue to audit even if they struggle to correct all the problems discovered. At some point the light bulb will turn on and the organization will recognize they have a problem with the corrective action process and hopefully figure out a fix.

ISO 14001 and Shared Operational Permits.

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Sometimes organizations share environmental permits with other organizations.  

This is a common situation with many large industrial operations where several plants are contiguous, use a common wastewater treatment facility or obtain energy from other parts of the organization where it is generated. The key is to carefully define the Scope of the EMS to only include those activities that are under the direct control of the organization implementing the EMS.

One of our clients in the paper industry has a similar situation. They are leasing a portion of a large paper making complex to make something called paperboard. Portions of the leased property are covered under the landlords Tier 1 NPDES Storm Water Discharge Permit and addressed in the SWPPP. The landlord has stipulated in the lease agreement that our client needs to comply with the terms of the SWPPP and we incorporated the conditions of the SWPPP that apply into the EMS as an “other requirement”.

The organizations is certified by an ANAB accredited Certification Body which has accepted our interpretation of the SWPPP as an “other legal requirement”. Again the real key here is to carefully define the Scope of the EMS (4.1) to limit it to the physical areas and process that the organization can control.

Also see – 4.3.1 a) to identify the environmental aspects of its activities, products and services within the defined scope of the environmental management system that it can control and those that it can influence …..

NASA Kennedy Space Center – ISO 14001 Internal Auditor Training

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OV-104 in Flight (NASA Photo)

Recently we delivered an internal auditor training course at the Kennedy Space Center (KSC) near Orlando, Florida. The two day ISO 14001 Internal Auditor course was delivered to a group of 17 NASA employees and KSC contractors. The classroom was within walking distance of the enormous Vehicle Assembly Building, the tallest one story building in the world.

We had a few hours before and after the course and the NASA folks gave us a wonderful behind the screens tour of the Orbiter Service Building where we were able to walk around directly beneath the Orbiter Atlantis (OV-104) as it was being serviced after its recent mission (STS-135). We also visited the Vehicle Assembly Building where the Orbiter Endeavor (OV-105) was being prepared for transport to the California Science Center. Apparently Atlantis is to remain at the KSC in “partial readiness” to fly again, which was the buzz around KSC during our visit. We also got a tour of the recently constructed LEED Platinum Certified NASA Propellants North building which has received several awards for its design.

Endeavour at VSB 10/24/2011

The training course we developed and delivered was specially designed to incorporate the elements of EO13423 and the KSC EMS documentation. The two day training helped refresh NASA internal auditor understanding of effective methods for performing value added process audits. The wide variety of processes and potential environmental impacts at KSC make internal auditing of the NASA operations and contractors especially challenging.

We are planning another trip to KSC to perform Phase II of the training. This phase will involve students participating in an actual internal audit at KSC. This 2 day process based EMS audit will demonstrate process audit techniques and coach NASA internal auditors in planning, implementing and reporting phases of effective internal audits

Here is a link to more information on our Internal Auditor Training courses.