As a member of the US Technical Advisory Group to ISO 14001 I traveled to Washington DC recently to attend meetings of the US TAG (TC 207).  Although TAG members are sworn to secrecy to help protect the US negotiating position on key issues I can say that the next version of the standard is likely to be unrecognizable in its form.  This is due to a big change at ISO headquarters compelling all standards revisions to conform to a new format called the “High Level Structure” or HLS.  What this means is that the ISO 14001 standard will be dramatically rearranged to fit neatly into a format that ISO believes will facilitate better understanding of the intent of each standards requirements.

ISO believes that all standards should have a uniform format so the current work of TC 207 is to disassemble the existing ISO 14001:2004 standard and reassemble it within this new structure.  If you are interested you can see what the HLS looks like here.

The other changes to the standard are not expected to include new requirements.  There are however areas where the US TAG is working to clarify the intent of the standard.  These areas include revised language on how organizations decide what their EMS will manage (significant environmental aspects) and the need to continue to include preventive action as a separate activity in the EMS.

The international ISO 14001 group is meeting in Rochester NY later this month when the US TAG will present its ISO 14001 revision proposal.  It will be interesting to see what comes out of Rochester and what the rest of the international community is thinking about how to align the current version of ISO 14001 with the MLS.

Our approach to climate change is based on assessment of potential business risks to our clients from inaction.  We believe there are actions that our clients can take to improve their competitive position and reduce their carbon footprint.  These actions are good business practices and make sense regardless of which side of the climate change political debate you are on.

A significant portion of a business’s cost is associated with energy use.  Coincidentally, energy use (carbon emissions from combustion of fossil fuels) is one of the most often sited potential causes of climate change.  Our approach is to focus on the dynamic aspects of our clients’ energy use to help them improve performance.  Improving energy performance provides the following benefits:

• Long term return on investment 
• Strategic hedge against future energy cost increases 
• Credibility as a “Greener” Organization 
•  Strategic positioning for future potential regulatory changes

We see minimal downside risk to business endeavoring to proactively manage their energy use by:

• Establishing an effective energy management system (EnMS) 
• Performing energy reviews 
• Establishing energy baselines 
•  Identifying key energy performance indications 
• Developing energy management action plans

ISO 50001 is an International Standard describing the minimal requirements for a continual improvement based EnMS.  As a voting member on the ISO 50001 technical advisory group TC 242 we monitor developments and participate in international consensus building on these important issues and encourage you to learn more about how an EnMS can be good for your business.

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.

Hurray!! ECSI Assurance Trademark Approved! Here is link.  US tradmark_112211

 We also cleared the last pre-application hurdle and should begin the ANSI ASQ National Accreditation Board application review and approval process within the next few weeks.

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.

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.