If you are living in the North Country as I am, the weather has been a perpetual topic of discussion. Just for fun, a couple of years ago, I decided to start to learn how to harvest ice from our local lake. Last week I got a call from some local divers needing a hole cut in the lake to do a certification ice dive.
Having cut some ice earlier this year to build Ice Henge, I had an idea that cutting a hole in the ice now was not going to be easy. It turned out that the ice on our local lake is almost 3 feet thick and it took over 3 hours to cut a 3′ x 6′ hole. At the time they started diving the outside air temperature was about 9 degrees F and dropping. The entire idea of ice diving offended every sensibility. Its just not right!
The US Technical Advisory Group (US TAG) for the new Occupational Health and Safety Management System Standard ISO 45001 met in Washington DC in late January which we attended as voting members. The objective of the meeting was to review the first working draft of the new standard and provide comments on the US position. The area of greatest interest was Clause 6 Planning where discussion centered on how best to address the concept of hazard identification, risk assessment and risk treatment (control). A key question discussed was how much discipline specific information should be inserted into the High Level Structure (HLS), the normative part of the standard, and how much should be presented in the Annex (the informative part of the standard).
My opinion is that the requirements part of the HLS should be left mostly as it is with only little additional discipline specific (OH&S) information being added. Additional discipline specific information should be placed in the Annex as informative interpretation and guidance on how to use the standard.
As the DC meeting concluded several members of the group offered to prepare the Annex portion of the standard to be presented in Morocco next month at the international meeting of the full ISO 45001 Project Committee.
ECSI prepared a proposed Annex A section for the standard which was based partially on other international and national standards like ISO 31000:2009 – Risk Management, ISO 31010:2009 Risk Assessment, OHSAS 18001:2007 and ANSI Z10:2012.
Here is one of the figures we introduces to explain the relationship between the various parts of ISO 45001 and the risk assessment process.
The Annex we prepared explained the different steps in the risk assessment process and also included a figure that could be used to explain the concept of Risk Analysis (Figure A6-2). The information we provided was combined with information offered by others on the US TAG. The proposed annex will be presented by the US TAG next month in Morocco. Now we just need to sit back and see what the rest of the international ISO 45001 Project Committee thinks about the US proposal for Annex A clause 6. .
Here is a senario and question that was posted to a Linkedin group that I thought was interesting. Below are my thoughts.
Senario – An auditor was performing a site visit to the management offices during an ISO50001 audit in a factory. The time was noon and the weather was hot outside. and he noticed that a large area of the offices from the east side was subject to a direct sunlight. The curtains are already there but they look in a bad status and when he asked staff there it seems never been used to cover windows. He checked then the EnMs records and found that the SEUs are only the cooling and the motors. He checked the operational procedure , nothing is mentioned about use of curtains. The list of ECMs does not mention anything about the use of curtains. Can he consider this as a non-conformity? and according to which clause of ISO50001?
My Reply –
There is no way in heck that a competent auditor should write a NC to ISO 50001 based on the facts provided here. Much more information is needed to make that call. I would want to know at least the following:
1. Has the organization established objectives and targets associated with the cooling SEU? If not this is a clear NC to 4.4.6. If they have established objective and targets for this SEU then I want to know…
2. Have they established action plans for achieving these objectives and targets? If not, it is also a clear NC to 4.4.6. If they have established action plans for achieving the objectives and targets then I want to know…..
3. Have the action plans been sufficiently developed that the curtains should have been considered as an effective operational control? If the conclusion to this question in “No” the action plans have not been sufficiently developed, I need to decide if I believe a creditable effort has been put forth by the organization given the timeframe the actions plans have been in place. If the action plans have been in place for a few years and little progress has been made to identify and implement controls than a NC to 4.4.6 is justifiable.
If on the other hand the organization has recently implemented the EnMS and the objectives and targets have only been in place for a few short months, I cannot expect them to have made great progress on identifying appropriate controls yet.
4. At some point on this audit trail I also want to ask myself the question…Is this a “material issue”. In other words “does it matter” in the grand scheme of the organizations EnMS if these curtains are in use or not. This is auditor judgment and why auditors should become certified or otherwise competent to do this important work. Depending on the circumstances this might be the first questions I would want to ask.
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.
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.
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 firstname.lastname@example.org.
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.