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.

The Future of ISO as a Measure of EH&S and Sustainability Performance

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Over the past few years I have been watching the development of various corporate sustainability reporting initiatives such as GRI (Global Reporting Initiative) and financial industry indexes such as Dow Jones Sustainability Indexes. Recently the Prince of Wales has weighed in on the issue with the development of an initiative to promote something call Integrated Reporting.

I have been trying to assess whether the criteria used in these newer measures of performance are on a path to eclipse the ISO standards or if the ISO standards will become an important part of these reporting and indexing products especially the assurance parts. I sometimes wonder if a parallel assessment process with its own set of performance criteria is coming that will make the ISO standards obsolete and with it the certification body accreditation process IAF and ISO certification business.

What are your thoughts? Is ISO gaining credibility as a measure of an organizations performance or are the common myths we hear about ISO so deeply entrenched and stakeholder confidence eroded to the point that the world is likely to seek other methods to assess organizations performance rather than ISO and IAF.

Tips For Environmental Aspect Identifcation

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Most organizations embarking on the EMS implementation process greatly underestimate the level of competence needed to do a good job in identifying environmental aspects, impacts and deciding which are significant. It’s sort of like landing an airplane. If you have never done it before the outcome can be a disaster.

The result of inept aspect identification will inevitably be an ineffective EMS. Do yourself and your organizations a favor and get professional help from someone who has done it many times. There are a zillion mediocre EMS consultants that will charge much and deliver little. Do your home work and check their references before you invest in their assistance.

Also, there are serious drawbacks to using a risk based approach to determining which environmental aspects are significant. A better outcome and more effective EMS will be achieved by establishing significance criteria (filters) for aspects such as:

1. Is the aspect regulated?

2. Is there potential for a significant impact from an unplanned release?

3. Are their other interested parties that care about the aspect like neighbors?

4. Is it costing lots of money to manage the aspect?

5. Is the scale or duration of the impact such that we should manage the aspect?

If an aspect is found to meet one of the criteria (gets caught on one of the filters) it should be considered significant or important to the organization and managed by the EMS (controlled, improved or both). If it passes all of the filters it should be considered insignificant or irrelevant to the organizations and ignored by the EMS.

Wisconsin Green Tier – Benefits and Risks to Wisconsin Business

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The following is a brief discussion of the Wisconsin Department of Natural Resources (WDNR) Green Tier program and some of the benefits it can have for business in Wisconsin and those doing business with WDNR Green Tier companies. The article also discusses some of the potential risks to these same business and WDNR that may result from stakeholders loosing confidence it what the Green Tier logo is supposed to mean.

Benefits to Business

A few months age I met with Pat Stevens who had just begun his new position as the Administrator of the Wisconsin Department of Natural Resources Division of Air and Waste. I was particularly interested in the potential changes to the Green Tier Program with a new administration and WDNR Secretary. During our discussions, Pat said he believed the new secretary and the new administration would continue to support and try to expand the Green Tier Program. One of the areas we explored was how Wisconsin businesses, in general, perceive the program and how the WDNR can gain broader acceptance with businesses by making some improvements.

I told Pat my experience had been that many potential Green Tier participants believe the benefits of the program do not justify the investment of effort needed to apply to the WDNR and become accepted into the program. I told him that we have also heard from some businesses that they perceive Green Tier participation as potentially increasing the risk of regulatory agency oversight and fines rather than reducing burdensome regulatory oversight.

Pat and I discussed a few ideas about how the WDNR can generate interest in the program through incentives, such as streamlined air emission construction permits for new or modified major sources and reduced reporting burdens. Within the last several weeks I have been pleased to see that a Tier 2 contract with Serigraph and correspondence with 3M in Prairie Du Chien ,WI included provisions for streamlined air permitting as Pat and I had discussed. I believe this is a move in the right direction and should help improve businesses perception of the potential benefits of Green Tier program.

Risks to Business and WDNR (Green Wash)

Pat and I also discuss what I perceive as significant potential risk to business participating in the Green Tier program and WDNR itself. The risk is that the process used by WDNR to confirm the existence of an ISO 14001 EMS may not be sufficiently robust to prevent some organizations acceptance into the program that are not really committed to the effective operations of the EMS. These participants want to be able to fly the Green Tier flag as evidence they are superior environmental performers but they are not actually committed to continual environmental performance improvement through an EMS.

This issue is particularly important for Tier 2 participants who may be receiving significant benefits under the green tier contracts. An example of this potential risk can be seen in WDNR acceptance of Serigraphs claim to be ISO 14001 “certified” as the basis for acceptance in to the Green Tier Program.

Although Serigraph has claimed to be certified to ISO14001 a examination of credentials of the Certification Body (Verysis, LLC) that issued the ISO 14001:2004 Certificate to Serigraph indicates that this organizations is not accredited by ANAB (the internationally recognized accreditation body in the USA) or any other International Accreditation Forum member. The accreditation of Verysis issued by an organization with a similar name “International Accreditation Board”  but does not reference any internationally recognized critera used to evaluate Verisys Registrars.

Here in the USA ANAB accredited ISO 14001 registrars undergo and extensive evaluation of their certification and audit process to ensure that they conform to the requirements of ISO/IEC 17021 Conformity assessment — Requirements for bodies providing audit and certification of management systems. There is no evidence that Verysis has undergone such an assessment.

The Wisconsin Statute for the Green Tier program describes what WDNR needs to consider when determining the acceptability of Green Tier audit in § 299.83 (7a) as follows:

7m)?Environmental auditors. The department may not approve an outside environmental auditor for the purposes of sub. (3) (d) 4. or (5) (c) 2. unless the outside environmental auditor is accredited by an accreditation body that complies with standards of the International Organization for Standardization for accreditation bodies or meets criteria concerning education, training, experience, and performance that the department determines are equivalent to the criteria in the standards and guidance of the International Organization for Standardization for entities providing audit and certification of environmental management systems.

The basic problem is that unless WDNR does at good job of reviewing the qualifications and objectivity of the auditors performing Green Tier audits there is a significant risk that at some point unqualified auditors will be performing Green Tier audits and issuing certificates of conformance to organizations that do not deserve them. If these Green Tier participants are later found to not be the superior performers that WDNR claimed them to be there is significant potential for stakeholders to loose confidence in the meaning of the Green Tier logo. This would result in embarrassing times for both the WDNR and all the other Green Tier participants.

I am interested in your feedback on this issue. Do you think additonal incentives are need to increase Green Tier participation and is WDNR doing a good job of screening who should be admited to the Green Tier program. Please post a comment if you are so inclined.

Kevin Lehner, EMS-LA

President ECSI

Integrated EHSMS

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Integration of Environmental Management Systems, (EMS) and Occupational Health and Safety Management Systems (OHSMS) into an EHSMS (Environmental Health and Safety Management System) is the way to go. ISO 14001:2004, OHSAS 2007 are your best choices for models of continual improvement management systems that are easily integrated. Both of these standards share many common elements and integration avoided the confusion of having separate process that address these in the EMS and OHSMS.

Separating the results of environmental aspect identification required by ISO 14001 and the hazard identification and risk assessment required by OHSAS 18001 alos helps avoid confusion. Get some help from an experienced, competent professional when you are deciding how to identify aspects and evaluate hazards and risks. If this part of the EHSMS implementation process is not done with skill, the effectiveness of the EHSMS will be greatly compromised.

Here is a link to a brief discussion about approaches to OHSMS hazard identification and risk assessment.

EHSMS Management Review – Making it Real

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Introduction

Skillful performance of concise management review meetings can dramatically improve management’s perception of the value of the EHSMS. The key to successful management review is distilling important information about the performance of the EHSMS to a point where it is actionable by management and presenting this information in a timely manner. Here are a few Does and Don’ts for successful management reviews:

Does

• Use regular periodic general business review meetings to present selected EHSMS inputs.

• Make sure the inputs are concise, well thought out and include recommendations for action.

• Include financial information such as Return on Investment calculations with recommendations.

• Keep a log of the dates each of the required inputs was discussed and records of the details of the presentation and any outputs from management.

Don’ts

• Conduct management review infrequently (only annually).

• Forget to record the results (outputs) of management review

• Ask management what they think should be done. It is the management review presenters’ responsibility to make EHSMS recommendations for improvement upon which management can act.

• Try to cover everything at once.

Discussion

The following is a brief discussion the Management Review Does:

Use regular periodic general business review meetings to present selected EHSMS Management Review inputs.

Good managers and leaders recognize that organizational change happens in increments. That’s why most organizations conduct regular periodic meetings of the management staff to review important attributes of business performance such as production issues, staffing, financial performance, new predict development and sales. These meetings are used by management to keep in touch with many of the key performance indicators management uses as a basis for deciding what incremental interventions are needed to keep the business healthy and prosperous.

These meetings are a great opportunity for the EHSMS manager to briefly get top managements attention about specific important EHSMS issues and propose potential incremental changes to improve performance. The notion that EHSMS Management Review is only needed infrequently (for some organizations only annually) can result in significant delay in management’s recognition of potential improvement opportunities and delay in realizing the benefits of the improvement. More frequent reviews also keep management informed on the progress of execution of recommended changes (outputs of management review).  Figure 1 is a example of how you might create a schedule for performing portions of management review during regulator business review meetings.

Figure 1

Figure 1

If management review is only conducted infrequently top management at the organizations will not know if the interventions they have approved are effective. It may be another year before they get any feedback on whether the recommended improvement was implemented and if it had an effect on performance.

Make sure the inputs are concise, well thought out and include recommendations for action.

Doing more with less is the reality of businesses today. Human resources including management resources are scarce and top managements time is a precious commodity. Therefore it is important to be able to quickly cover the important points about an EHSMS issue  in a way that will result in an action (a decision by top management). Make sure that at recommendation for action is included at the end of a brief presentation of the facts of a particular issue. If you simply present the facts of an issue without a specific recommendation management may not act. Proposing a specific recommendation as a potential solution to an issues encourages management to make a decision.

Include financial information such as Return on Investment calculations with recommendations.

Improvements in the EHSMS are good but, if they require an investment of financial or human resources management will likely care a lot about what they will get out of that investment. Putting a monetary value on the benefits in terms of return on investment helps management justify it. Proposed investments in the EHSMS should cash flow within the time period that management would consider for other investments.

The ROI for recommendations for improvements in environmental performance are easier to calculate than health and safety improvements because they are more measureable. Re-lighting a warehouse with energy efficient bulbs is an good example because it is fairly easy to calculate how long it will take to recover the investment.

Calculating ROI for Health and safety improvements is a bit more difficult because it involves estimating the relative risk of something bad happening and the consequences of that event. When presenting health and safety recommendation you should include a recommendation for what risk level should be acceptable and what it will cost to achieve that reduced risk level. Management then needs to decide if the recommend risk reduction is acceptable and worth the investment of financial or human resources.

Keep a log of the dates each of the required inputs was discussed and records of the details of the presentation and any outputs from management.

Records of the results of management review are valuable to show evidence of management commitment to the EHSMS. They can be used to show external auditors the organization is conforming to the requirements of ISO 14001 and OHSA 18001 clause 4.6. They may also be valuable should an incident occur that is investigated by a regulatory agency (USEPA or OSHA) or if there is a civil action involving an injury case.

A matrix or table like  Figure 1, showing what parts of the EHSMS were reviewed when (during regular business review meetings) can help you retrieve the records of what was discussed and what decisions were made. Keeping a brief accurate record of the issues discussed and the outputs from management and then linking these records to the dates on the matrix will help in locating specific management review meeting minutes when they need to be retrieved.

Conclusion and Recommendation

The management review part of an EHSMS is a powerful tool which enables incremental improvements in EHSMS performance. Done with skill, management review can improve the perception by management of the value of the EHSMS. Integrating the management review function with normal business review meetings helps management address import EHSMS issues in a timely incremental fashion.

Take a look at your management review process and decide if it is helping sustain the continual improvement process and the effectiveness of the EHSMS. If not, maybe it is time to think about re-engineering the management review process to make it more relevant to the organizations performance improvement efforts.

Internal Audit Teams

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Many organizations greatly underestimate the investment of resources needed to perform effective EHSMS internal audits.  The result is almost always a confused audit team which conveys a confused implementation effort to the rest of the organization.  The organization, including top management then looses respect for the EMS which can take years to overcome.  Don’t make this common mistake. 

 

If you are a team leader invest in your own competence by taking a certified EMS-LA course which includes an evaluation of your competence to lead audit teams.  Then invest in training a team of internal auditors in the requirements of ISO 14001 and ensure they understand the relationship between audit criteria, audit evidence and audit findings,  Lastly, make sure all the auditors poses the important personal attributes like being able to discuss without arguing, being able to listen effectively, good note taking and being perceptive.  Once you have covered those bases you are ready to lead a good internal audit that can provide important information upon which top management can act.

ISO 14031 – Environmental Performance

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I have not found ISO 14031 very useful in providing guidance on measuring environmental performance and the fact that it has not been revised or updated in over 12 years suggest that others do not find great value in it either. Measurement of environmental performance is quite subjective and complicated. For example, which organization is the better environmental performer? The one that emits 100 tons per year (TPY) of CO2 of the one that emits 100000 TPY. What if these organizations are in different industries different sizes and different climates?

To begin to be meaningful the emissions need to be normalized. A simple normalized metric might be tons of CO2 per unit of production. This performance metric could also consider atmospheric influences like very cold or hot temperatures that require more energy use or base load emissions when production is either abnormally high or low. The normalizing performance calculation can become quit complex as it matures.

Once normalized a comparison of similar industries can provide valuable information about performance. Unfortunately it is difficult to get normalized performance information of similar industries because the metrics used by different companies are rarely the same.

That’s why certification/registration to ISO 14001 can be a better indicator of an organizations overall environmental performance. If the certifying auditors are doing their job they will insist on the organizations demonstrating commitment to systematically improving environmental performance. They will also expect to see evidence of actual (measurable) environmental performance improvement.

Certification to ISO 14001 is still the best way to ensure that an organization with which you desire some kind of relationship (you want to buy their stock or their product) is committed to improving environmental performance and is actively working to achieve better performance.

OH&S Hazard Identification and Risk Assessment – OHSAS 18001

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OHSAS 18001 continues to gain popularity with organizations as an easy plug-in to their existing business management system.

ISO 14001 is to environmental management what OHSAS 18001 is to workplace employee health and Safety. OHSAS 18001 is a model that organizations can use to establish or enhance a continual improvement-based employee health and safety program or management system. An OHSAS 18001 Management System (OHSMS) can be readily integrated with other management systems, including ISO 9001 and ISO 14001.

The identification of workplace hazards and associated risks is a key element of OHSAS 18001 (Clause 4.3.1). Hazard identification is the process of identifying what could go wrong and possibly harm someone. Risk assessment is a multi-dimensional semi-quantitative evaluation of the potential likelihood of a hazard actually occurring and the potential consequences if a hazard should occur. Once the level of risk for a particular hazard has been quantified through the risk assessment process, that level of risk can be evaluated by the organization for “acceptability.” Acceptability is a subjective measure of how safe is safe enough and should be determined with the input and approval of the organization’s top management.

An example of a risk assessment might be making a comparison between the hazard of using a hand saw to cut a piece of wood and the hazard of using an unguarded table saw. Let’s assume that the hazard in question is the potential to seriously cut oneself while cutting a piece of wood. We know through experience that using a hand saw is not likely to cause a serious injury requiring substantial medical attention. The risk of serious injury is relatively low, and most would deem that risk tolerable or acceptable as is. Using an unguarded table saw, on the other hand, could result in a serious cut or even an amputation, which in some cases may be life threatening. The risk of using an unguarded table saw is therefore unacceptably high. In order to control the risk of amputation to a “tolerable” or “acceptable” level, the saw would have to be properly guarded, and all operators would need to be trained in the safe use of a table saw. The guarding and the training are referred to as operational controls. Although the hazard of a serious cut still remains, the operational controls contain the risk (the likelihood and consequences) to a tolerable level.

The task of performing an OHSAS 18001 hazard identification and risk assessment would be easy if there were only a few hazards present in the workplace. Unfortunately, most workplaces have hundreds of hazards that require evaluation. Consequently, organizations seeking to improve their OH&S performance need to find a way to prioritize these hazards so that they can address the highest risks first.

Such a numeric evaluation is similar to a Failure Mode Effects Analysis (FMEA), which is used by quality managers to prioritize potential risk to product quality. The OHSAS risk assessment process can be used to prioritize potential health and safety risks and help organizations decide what needs to be done first to get the most risk reduction as quickly as possible. These risk assessments can be tailored to each organization’s situation and risk tolerance threshold.

There is no one right way to perform hazard identification and risk assessment. However, if not performed with skill and competence, the results of the OHSAS risk assessment will dramatically affect the performance of the employee health and safety program or management system. In other words, the program or management system is only as good as the hazard identification and risk assessment process.

Following are some key points to remember:

  • Develop a documented procedure for hazard identification and risk assessment.
  • Don’t be afraid to tweak the procedure if it is not producing reasonable results.
  • Involve in the assessments those who are exposed to possible hazards.
  • Engage management to determine the risk tolerance threshold the organization wants to achieve.

What are your experiences with hazard identification and risk assessment? Let us know by placing a comment here.

Air Pollution Control Equipment – What ISO 14001 Requires

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Operation and maintenance of air pollution control equipment is often a source of the nonconformities we discover while performing both ISO 14001 EMS audits and Environmental Regulatory Compliance audits.

Clause 4.5.1 Monitoring and Measurement of ISO 14001 requires that organizations monitor and measure key characteristics of their environmental performance. An organization’s ability to control air pollution is one of these key performance characteristics, and the effectiveness of the organization’s air pollution control equipment is closely linked to this characteristic. Many of the legal requirements for air pollution control, including National Emission Standards for Hazardous Air Pollutants (NESHAP), also compel the proper operation and maintenance of pollution control devices.

Our audit experience shows that 50 percent or more of the organizations we audit are not as familiar with their air pollution control equipment as they could be, and as a result, are unable to show evidence during an audit that the equipment is, indeed, being operated and maintained according to the manufacturer’s specifications.

A simple example would be a paint booth that uses filters to control the particulate emissions from the painting operations. Booth manufacturers often specify a control efficiency of the booth, which is defined as the percentage of the particulate matter removed by the filters in the boot when the booth is being operated properly. Paint booth manufacturers also specify the types of filters to be used and the range of pressure drop across the filters, to ensure that the required control efficiency (98% as an example) is being achieved. During audits of paint booths, we often find that either the filters are not rated appropriately or the pressure drop across the filters is not being measured or recorded correctly.

A related issue is the ISO requirement (also Clause 4.5.1) that the instruments used to measure performance must be periodically calibrated. We find that pressure drop manometers or Magnehelic gauges are often not on a preventive maintenance schedule for calibration and/or replacement. Including the inspection of the pollution control equipment on a preventive maintenance schedule will help to ensure proper operation and maintenance of the equipment. As a risk management strategy, the ISO 14001 internal audit program should include a review of evidence that the scheduled maintenance has been performed and that the equipment is operating correctly.

If we can assist you in preparing for your ISO 14001 EMS audits and/or your Environmental Regulatory Compliance audits, or if you have any comments, questions, or concerns regarding your air pollution control equipment, please feel free to call us, at 920-648-4134, or e-mail us, at kalehner@envcompsys.com.

ECSI To Meet With New WDNR Senior Management

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The newly appointed Secretary of the WDNR Cathy Stepp has made a few changes at the top of the organization.  On March 3, 2011, I will be meeting with Pat Stevens the new Administrator of the Division of Air and Waste (WDNR Org Chart) to explore what these changes might mean to businesses in Wisconsin.  I have known Pat for many years and am particularly interested in the Bureau of Cooperative Environmental Assistance, which is the home of the Green Tier Program.  I am also interested in exploring any new approaches the WDNR is considering to help industry obtain approval on air permit applications or revisions to applications in a timely fashion.   Leave a post here or e-mail me to let me know if you have any issues that you would like me to bring up during this meeting.  Here is some more information about Pat and a link to the WDNR news release. 

Pat Stevens, Division of Air and Waste.  Stevens, 49, is new to the WDNR. He will oversee Air Management, Waste and Materials Management, Remediation and Redevelopment, and Cooperative Environmental Management (including Green Tier) programs.  Pat brings 17 years of experience with WDNR programs as general counsel for the Wisconsin Builders Association, counsel for the Wisconsin Transportation Builders Association, and environmental policy director for Wisconsin Manufacturers and Commerce.  In these roles, he collaborated with the WDNR and others on the development of a number of WDNR rules. Stevens also served as Assistant Attorney General in North Dakota from 1988-92, working with the Natural Resources and Indian Affairs Division and the Tax Commissioner’s Office.  He holds a B.A. in business management from Arizona State University and a law degree from the University of North Dakota School of Law.