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.

USEPA GHG Emission Reporting Deadline Extended

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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.

A Busy February at ECSI

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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.

Wind Turbine Production and ISO 14001/OHSAS 18001 Management Systems

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This turbine is at the top of a 300 foot tower. The garage door at the back is about 15 feet tall. There are electric motors in the hub that control the pitch of the propeller blades for optimal performance. Click to enlarge

About 60 percent of what we do at ECSI is internal and third party audits.  Every so often we do one that is very special.  Last year it was for the US Department of Energy at Argonne National Labs.     Recently, we performed a combined ISO 14001 and OHSAS 18001 Stage 1 and Stage 2 registration audit on behalf of one of our registrar clients for a fascinating company located in east central Iowa that assembles, tests and installs wind turbines.

Wind power is a growing business as you can see by driving around the countryside these days. When I first began planning for the audits I knew that the facility was only making the power generating part of the complete wind system.  So I was thinking … how complex can this be?  They probably purchase the generators and then bolt on a few pieces of hardware to attach it to the tower and blades.   Holy mackerel was I in for a shock. 

As I was walking through the facility on the way to the Stage 1 opening meeting,  I was stunned at how huge and complex these turbines are.  The turbines are assembled in three sections (gear box, hub, and base) that will be put together on top of the tower in the field.  The castings that make up the housings for the gear box, hub, and base, are gigantic, each weighing close to 30 tons.  Once assembled, the gear box alone weights almost 50 tons and they were moving these around with cranes and gantry cranes.  Obviously the operational controls for ensuring safe lifting were an important part of the OHSAS portion of the audit.

Turbine Parts - Click to enlarge

The gear box, base, and hub castings come from Germany and need to be cleaned and painted with the associated significant environmental aspects.  Large gears that transfer the wind energy from the blades to the generators need to be micro finished in an oversized vibratory deburring process.  This increases the life of the gears to around 20 years.  Replacing the gears if they fail is an expensive proposition because it needs to be done at the top of a 300 feet tower.

The assembled generators are also tested to confirm they are capable of generating the promised 2640 KW and 1320 VDC.  Generating that kind of energy in a testing environment requires special controls, training, and competence to be done safely.

The audit process was enhanced by management’s commitment to the system.  They recognized the value of the audit process in ensuring a return on their EHSMS investment.  Employees  also helped us collect the evidence we needed to support our recommendation for registration.  We are proud to have been a part of this developing technology and industry that is helping to reduce international environmental impacts of electrical energy generation.