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.

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.

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.

On March 1, 2011 the USEPA announced its intention to extend this year’s GHG Emission reporting deadline – originally March 31 – and plans to have the final uploading tool (e-GGRT) available this summer, with the data scheduled to be published later this year. This extension would allow EPA to further test the system that reporters will use to submit data, and give industry the opportunity to test the tool, provide feedback and have sufficient time to become familiar with it prior to reporting.

In its news release today the agency indicated it will provide more detail on the intended changes in the coming weeks and will ensure that this reporting extension is in effect before the original reporting deadline of March 31, 2011.

ANAB Registrar Application

Preparation of the ECSI Assurance ANAB application for ISO 14001 and OHSAS 18001 registrar accreditation consumed a great deal of our time and effort last month.   The process requires that we address all of the requirements of ISO 17021, ISO 19011 and the International Accreditation Forum (IAF) Guidelines.  ANAB and IAF put great emphasis on impartiality and processes that will ensure the minimization of potential conflict of interest in the certification services we will be providing.  The ANAB impartiality process requires that we perform an independent review of audit reports before we make a certification decision.  This step cannot be performed by the auditors who conducted the actual registration audit.  It is additional assurance that the audit was conducted competently and objectively.  We are looking for folks who are familiar with the requirements of ISO 14001 and OHSAS 18001 who are interested in performing reviews of reports on a contract basis for us when we begin actual registration audits.  Let us know if you are interested, and we can fill you in on the details of the work.

Another ANAB and IAF challenge is defining the process we will use to determine auditors’ competence to perform EHSMS audits for us.  The process must include an evaluation of our auditors’ skills, knowledge, and personal attributes, as well as observations of our auditors actually performing audits before we deem them qualified.

TaskTracker CPAR Database

We have also been working on a major upgrade to the web-based TaskTracker corrective and preventive action system that we offer to our audit clients to help them track CPARs and other EHS tasks from creation through closure.  Several clients who are already using TaskTracker had some great ideas for improvements, which we are now implementing.  We have not been charging folks to use TaskTracker and will likely continue that practice for the basic version.  Here are links to flow diagrams that give an idea of the TaskTracker process for CPAR Tasks and EHS Tasks. We will be providing more information about the TaskTracker upgrade later.  Let us know if you are interested in trying it out.  We are looking for volunteers.

EHSMS Internal Auditor Course

In February, we also invested significant effort in a revised edition of our EHSMS Internal Auditor Training Course.  This course has evolved over the last 10 years based on our experiences in teaching the course and on customer and student feedback.  In this revision, we have added a few new activities that will help students understand the relationship between audit criteria, audit evidence, and audit findings.  We believe that this will make them better auditors, and that it will improve the overall quality of the internal audits they perform.

The course includes a day and a half of actual auditing, so that we can check if the added materials are effective in preparing students to perform internal audits.  The next course is will be in the New Orleans area the last week of March 28, 2011.

It’s a Go!  Madison, WI ISO 14001 EMS Lead Auditor Course

Only a few seats are left in our ISO 14001 EMS Lead Auditor Course in Madison, Wisconsin, March 28 – April 1, 2011.

Register today to confirm your place in this widely acclaimed course for EH&S professionals.  Space is limited, and we only offer this course once a year.

This is an RABQSA-certified course and can be used to obtain Lead Auditor certification from RABQSA.  The course is also perfect for those who are responsible for implementing an ISO 14001 EMS and for those who are performing EMS internal audits.  Here is a link to our website for more information, or you can call

920-648-4134.