Category Archives: ISO 14001

ISO 14001 Topics

Revision to ISO 14001:2004 – Defining Significant Environmental Aspects/Impacts – Sense and Semantics

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Over the last two decades practicing as an ISO 14001 auditor, consultant, and teacher, I have found that many individuals and organizations misunderstand the intent and meaning of the terms “significant environmental aspect” and “significant environmental impact.”  With the revision to ISO 14001:2004 well under way, perhaps now is a good time to attempt introducing language or definitions into ISO 14001:201x that will help individuals and organizations better understand the term “significant”, and the distinction between the terms “aspect,” and “impact.”   Such clarity would enable individuals and organizations to better interpret  what exactly must be done according to the standard. This confusion in meaning is understandable because, at least in the English language, there are several definitions or “senses” or “subsenses (meanings in specific contexts) of the term “significant.”  The senses or subsenses that are applicable within the context of ISO 14001 can be found in the MerriamWebster Collegiate Dictionary (Tenth Addition) as follows:

2   a: having or likely to have influence or effect:  IMPORTANT  <a significant piece of legislation>;    also: of a noticeably or measurably large amount <a significant number of layoffs> <producing significant profits>

In order to fully comprehend this definition, you need to refer to the Explanatory Chart and Explanatory Notes at the beginning of the dictionary, which describe the meaning of the numbers (2), something called a “sense number”; the small letters (a), which are “sense letters”; the colon (:), which is used to separate two or more definitions of a single sense; and the italicized word “also,” which is called a “sense divider” and is used to introduce a meaning that is closely related to but may be considered less important than the preceding sense.  If a capitalized word is used to define a sense of the word, that capitalized word, in this case IMPORTANT, is defined as a synonym of the term being defined.

The sense number 2 definition of the term “significant” has several subsenses with different meanings.  One of these subsenses means “important.”  The other means “a noticeably or measurably large amount.”   What has happened over the years with the interpretation of ISO 14001 is that many individuals and organizations have applied only the second subsense of the term – “a noticeably or measurably large amount,” – when they are determining which environmental aspects they consider significant.  They ignore the other, and arguably more important, subsense of the term –  “IMPORTANT.”

The effect on an organization’s Environmental Management System of only considering the part of the definition of “significant” that means “a noticeably or measurably large amount“ has been that an organization typically excludes from its list of significant environmental aspects those that are “important” to them for  reasons other than their being “a noticeably or measurably large amount”. This typically includes environmental aspects for which the organization has established operational controls (work instructions) to ensure that the environmental impact of the significant environmental aspect is controlled to the level desired by the organization.  

An example might be waste light bulbs, batteries, and other electronic waste.  Although most organizations have procedures for ensuring that these wastes are properly recycled (work instructions or procedures), many do not identify these wastes as significant environmental aspects because they believe the presence of the operational control has reduced the potential impact from these wastes to a point where they do not constitute a  “noticeably large amount.”   They do not apply the other subsense of the word “significant” with the meaning “important.”  Proper management of waste light bulbs is obviously important to the organizations because they have established a procedure (operational control) for ensuring that they are managed in a certain way. 

The unfortunate consequence of not including waste light bulbs as a significant environmental aspect is that this important environmental aspect  then becomes transparent to the management system.  The organization’s performance toward ensuring that waste light bulbs are managed correctly is not routinely measured or audited during internal or other system audits. 

To correct this problem the US TAG should consider adding the following definitions to ISO 14001:201x:

3.xx significant environmental aspect The cause of a significant environmental impact

3.xx significant environmental impact The potential or actual environmental effect or risk caused by a significant environmental aspect that an organization intends to manage or is managing through operational controls and/or environmental objectives, targets, and programs

The definition of significant environmental impact above includes reference to “risk,” which is meant to address the risk to the organization, including potential regulatory noncompliance.  The result of including the word “risk” in the definition is that organizations controlling  an environmental aspect to manage a potential risk of noncompliance will need to identify that environmental aspect as “significant.” Close attention should also be paid to the way in which the terms “significant environmental aspect” and “significant environmental impact” are used in the standard to avoid confusion between these terms.  The use of the term significant environmental impact” should be limited compared to the use of the term significant environmental aspect.  The term significant environmental impact should be used only in the section of ISO 14001:201x addressing identification of environmental aspects.

Kevin A. Lehner, EMS-LA, CHMM – January 11, 2013

A True Story – Why ISO 14001 Works

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Background

It has been over seven years since we first began helping a medium sized automotive equipment manufacturer in the midwest implement a company wide ISO 14001 EMS. They were getting pressure from their customers to prove they were good environmental performers and an ISO 14001 certificate was the best solution. We helped them with environmental aspects, setting up the EMS and identifying regulatory compliance requirements. As we were completing the project we performed a round of internal audits to check that each facility was complying with the applicable  legal requirements.

The Audit Finding

One of the findings of our compliance audit was that at one location, the company was operating unpermitted production painting equipment. The audit team could find no records of correspondence with the State permitting authority about this new equipment. It had been commissioned sometime after an initial Title V permit application had been prepared for the facility. The paint operation was an important part of the manufacturing process and it was not possible to simply shut the process down. Doing so would have resulted in delayed shipment of product and dissatisfied customers.

The Response

Although the discovery of this potential noncompliance was uncomfortable news for the organization, at least they now had a better picture of the potential risks they were facing. They examined the process closely and decided that it was time to upgrade. They worked it out with the state permitting authority to replace the old system with a new more efficient paint system.

Fast Forward

Over the last several years we have continued to perform periodic EH&S compliance, ISO 14001, and OHSAS 18001 internal audits to support their continued certification to these standards.. During a recent compliance audit at one of the facilities we were delighted to see a new process being installed. It means the company continues to grow but, from an auditors perspective, the stack ducting through the roof becomes a great opportunity to check the EMS effectiveness to control noncompliance risk. As we walked by the new process I could see the auditee cracking a half smile as I asked a few questions about the new equipment and construction underway. He knew where this audit was going.

The audit was actually a combined one-day environmental and OSHA compliance audit so we had a lot of ground to cover in 8 hours. When the audit schedule called for review of compliance with state air emission permits, I asked what they knew about the potential emission from the new process. The audtee said “the process had the potential to emit a hazardous air pollutant at levels requiring permitting before installation of the equipment”.  The auditee then produced the construction permit they had been issued by the state?  The EMS had worked to help the organization identify the need to obtain a permit, well in advance of beginning construction on the new process.

Results Matter

Discovery of unpermitted emission sources during internal and compliance audits is not uncommon for us even today. Helping organizations identify and manage risks of noncompliance in the short term provides some satisfaction in our work. But having the opportunity to see the results of an effective EMS that we helped implement and, how that EMS has helped manage risks long term, is particularly gratifying.

Skepticism of the benefits of ISO 14001 will continue to linger especially with the uniformed. However, organizations interested in managing environmental risk and becoming more sustainable need to understand how the audit processes, embedded in ISO 14001, can be used to support an organizations sustainability efforts, promote successful outcomes and provide confidence by other stakeholder that environmentally, things are as they should be.

Revision to ISO 14001:201x Moving Forward

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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.

ISO 14001 and Shared Operational Permits.

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Sometimes organizations share environmental permits with other organizations.  

This is a common situation with many large industrial operations where several plants are contiguous, use a common wastewater treatment facility or obtain energy from other parts of the organization where it is generated. The key is to carefully define the Scope of the EMS to only include those activities that are under the direct control of the organization implementing the EMS.

One of our clients in the paper industry has a similar situation. They are leasing a portion of a large paper making complex to make something called paperboard. Portions of the leased property are covered under the landlords Tier 1 NPDES Storm Water Discharge Permit and addressed in the SWPPP. The landlord has stipulated in the lease agreement that our client needs to comply with the terms of the SWPPP and we incorporated the conditions of the SWPPP that apply into the EMS as an “other requirement”.

The organizations is certified by an ANAB accredited Certification Body which has accepted our interpretation of the SWPPP as an “other legal requirement”. Again the real key here is to carefully define the Scope of the EMS (4.1) to limit it to the physical areas and process that the organization can control.

Also see – 4.3.1 a) to identify the environmental aspects of its activities, products and services within the defined scope of the environmental management system that it can control and those that it can influence …..

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

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.

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.

ISO 14001 Registration – How it Works

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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.

figure_11

 

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.