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.

Cap and Trade – Another Perspective

A recent conference in Milwaukee held by the U.S. State Department received public comments on the U.S. position on global warming to be presented by the U.S  State Department at the United Nations Framework Convention on Climate Change in Copenhagen, Denmark this December (see http://unfccc.int/2860.php). This is an important convention where the U.S.  along with other nations may commit to reducing global GHG emissions. From the tone of the meeting it sounds like the State Department is more willing to cooperate with global GHG emission reduction initiatives than it was at previous meetings but very few details were provided on what the U.S. was willing to try to negotiate in Copenhagen.

The conference audience was a good mix between manufacturing, business and academic interests. The meeting began with the State Department representatives making a statement to the effect that there was “no longer any reason to doubt the scientific basis for global warming and the role GHG emissions play”. Many in the audience were  quick to challenge this statement insisting that the science was not at all-conclusive and expressing the opinion that there was little evidence that GHG emission cause global warming.  Most in the audience also expressed the concern that cap and trade regulation would seriously damage affected U.S. businesses’ competiveness with developing nations who would not likely adhere to GHG control requirements.

This is the same debate that has persisted for at least the last 30 years and is likely to continue for at least another 30. Personally,  I am not convinced that there is a concrete, demonstrable link between GHG emissions and global warming. I think it is plausible that such a link exists but have not yet seen compelling indisputable evidence of the connection. But I really don’t think that a concrete link is needed for us to want to control GHG emissions, especially those associated with energy use.

There are other strategic issues with potential global warming that I believe should be driving our efforts to reduce these emissions. I believe that the security of our nation, which relies heavily on non-renewable sources of energy to sustain its standard of living,  is not as strong as a nation that is less reliant on non-renewable energy. If the United States continues to delay development of technology to improve our use of renewable energy, and we continue to deplete limited supplies of non-renewable energy, there may come a time when we have reached the  tipping point. A point where we are unable to sustain our standard of living and no longer have the resources to invest in development of alternate renewable energy sources

If cap and trade is able to create additional incentive to limit the use of non-renewable energy in this country I believe that may be a good thing. If we can also hedge our bets about whether or not GHG emissions are causing global warming it seems like a no-lose strategy. It seems there is more to gain than to lose by controlling the use of non-renewable energy and if cap and trade will help us we should look past fears of change and move ahead on reducing GHG emissions here in the U.S. and around the world.

Posted in GHG

ECSI Now Offers GHG Voluntary Inventory Reporting Assistance.

Organizations wanting to be prepared for the USEPA mandatory GHG Emission Inventory requirements coming this  November now have a source of information and assistance to guide their efforts.  Our role  as ANSI GHG Verification and Validation program Lead Auditors has given us unique insight into how USEPA and others will be operating GHG inventory and Cap and Trade programs.  Equipped with our unique insight we are now offering assistance to organizations for submission to the following GHG Inventory and Offset Trading programs:

 Call us for more information at 920-648-4134 or email us at ghgprograms@envcompsys.com

Posted in GHG

ISO 14001 Registration – How it Works

The process of becoming registered to ISO 14001 can be confusing. Common questions we are asked include the following:

 – Who is qualified to issue ISO 14001 Registration Certificates?

 – Who is qualified to perform the registration audits?

 – How long is a certificate good and what is the registration process?

These are a few common questions asked by organizations considering implementing an EMS which will be explained here.

What Organizations are Qualified to Issue ISO 14001 Certifications?

Authority to issue internationally recognized ISO 14001 certificates are linked to the International Accreditation Forum. The International Accreditation Forum, Inc. (IAF) is the world association of Conformity Assessment Accreditation Bodies and other bodies interested in conformity assessment in the fields of management systems, products, services, personnel and other similar programs of conformity assessment. Its primary function is to develop a single worldwide program of conformity assessment which reduces risk for a business and its customers by assuring them that accredited certificates may be relied upon. IAF members accredit certification or registration bodies that issue certificates attesting that an organization’s management, products or personnel comply with a specified standard (called conformity assessment).

In the United States ANAB is the main accrediting body for the registrars who actually issue the ISO 14001 Certificates. ANAB is a member of the International Accreditation Forum and a signatory of the IAF multilateral cooperative arrangements (MLAs) for QMS and EMS. Through the IAF MLAs and the Multilateral Cooperative Accreditation Arrangement, ANAB cooperates with other accreditation bodies around the world to provide value to its accredited CBs and their clients, ensuring that accredited certificates are recognized nationally and internationally. The global conformity assessment system ensures confidence and reduces risk for customers engaging in trade worldwide.
At last count ANAB had accredited 45 organizations (28 located in the USA) to issue ISO 14001 registration Certificates.

Registrars have been accredited to issue ISO 14001 certificates by ANAB. ANAB evaluates each registrar against the requirements ISO/IEC 17021 Conformity Assessment – Requirements for Bodies Providing Audit and Certification of Management Systems when determining if the registar should be authorized to issue ISO 14001 Certificates. Accredited registrars hire competent auditors to perform the registration audits and provide a record of the evidence reviewed as part of the auditor’s recommendation for or against registration of the organizations being audited.

Which Individuals are Qualified to Perform ISO 14001 Registration Audits for Registrars?

One of the requirements of ISO 17021 which must be met by all registrars is that the auditors performing audits on behalf of the registrar are competent to do so.

7.2.5 The certification body shall have a process to achieve and demonstrate effective auditing skills, including the use of auditors and audit team leaders possessing generic auditing skills and knowledge, as well as skills and knowledge appropriate for auditing in specific technical areas. This process shall be defined in documented requirements drawn up in accordance with the relevant guidance provided in ISO 19011.

ISO 19011 is specific guidance for registrars on how to establish audit programs and determine auditor competence.

Auditors can demonstrate they have achieved a level competence through personal certification by RABQSA International which is itself accredited by JAZ-ANZ. However, this certification alone is not sufficient evidence to ANAB that auditors working for registrars are competent to perform audits. In addition the registrar must, at a minimum observe the auditor’s performance during an actual audit before they are deemed competent by the registrar.

Figure 1 shows the links between the various organizations making up the registration process.

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How is the ISO 14001 Registration Process Performed?

ISO 14001 Certificates are good for a period of three years assuming the organization successfully completes a series of surveillance audits during that three year period. The registration process begins with a documentation review performed by the auditor to determine if the organization has addressed all the elements of the ISO 14001 Standard. The outcome of the document review can be a recommendation by the auditor to proceed to the registration audit process or a recommendation to delay the registration process until the organization has addressed deficiencies identified by the auditor during the Document Review.

The registration audit begins with what is often referred to as a Stage 1 assessment. The lead auditor visits the site for a day or so to review the organization’s environmental aspects and verify conformance with some of the basic ISO 14001 requirements that could not be verified during the Document Review. The purpose of the Stage 1 audit is also to provide the auditor with additional information about the facility to enable them to prepare a plan for the Stage 2 assessment. The Stage 1 audit is also is a final check on the readiness of the organizations to undergo the Stage 2 Assessment.

The Stage 2 assessment is of longer duration (several auditors on site for several days) than the Stage 1 assessment this is a deeper drilling into the organization’s EMS that is performed in either the Document Review or the Stage 1 Assessment. The Stage 2  Assessment is where the audit team collects and records the evidence of the organization’s conformance to the requirements of ISO 14001 and the organization’s own EMS. This is the evidence that the audit team will submit to the registrar supporting their recommendation for registration.

Successful completion of the registration audit begins three year period that the ISO 14001 certificate is valid. During that three year period the registrar will perform periodic surveillance audits (at least once per year) to confirm that the EMS has sustained effectiveness in the ability of  the organization to continually improve its environmental performance. At the end of the three year period the re-registration assessment is performed which is of similar duration and scope to the original registration audit.