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.

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.