PRACTICAL IMPLEMENTATION OF AN ISO14001 EMS ROBERT HEPKER Director Environmental Health & Safety Sumco USA Phoenix, AZ 1.

The presentation was developed from the standpoint of a person who has implemented an EMS after learning a little about ISO14001 on the basis of various short courses, but virtually no practical application. 2. To the un-enlightened, ISO14001 might be perceived as being a program that requires excessive concessions in the name of protection of the environment. It is not about tree hugging, save the whales, or save the gray wolves. 3. What it is though, or at least it can be, if developed right, is a very practical business approach to environmental stewardship. ISO does not require that your business become a green company just for the sake of being green. It does expect that you look at the environmental impact of your operations and make business decisions with an awareness of their impact on the environment. 4. How did we put our Environmental Management System (EMS) together? We had some advantages that you should be aware of. First, senior management understood that they had a role to play that was greater than telling the EHS Director that they wanted an ISO certified EMS. Management has to be involved in the System or you do not really have a business approach. Management, not the Environmental staff sets expectations, priorities, and accountabilities. Your EMS cannot be an environmental department program. Let me say again - This cannot be an environmental department program. It has to be a management emphasis in which the environmental staff is the facilitator. If your management tells you to give them an EMS that will pass an ISO14001 audit, and they do not expect to be involved, you are in trouble. 5. The second significant advantage we had going into the development of our EMS was the fact that we were already ISO9000 certified. Therefore, our entire organization not only had an understanding of an ISO system, we also had some existing elements of the Quality System that could completely address the same elements of an EMS. Most notably, these were Document Control and Corrective and Preventive Actions. 6. Finally, we had excellent coaching from a specialized consultant. There are a couple of important points that need to be qualified. This was not a turn-key project that a consultant did for us. We knew that the EMS had to be our program because we would have to demonstrate to an auditor that it actually met the elements of the Standard. We developed the system with our best understanding of what the ISO14001 standard was telling us, and the consultant made sure that we addressed all of the Standard elements in such a manner that an EMS Lead Auditor could easily approve.

7. Now let us return to Business Approach to Environmental Stewardship. No matter what business is managing, it follows these steps. 1) it decides what it wants, 2) it plans on how it will do that, 3) it puts the plans in action, and 4) it checks on how the plan worked against the target. These four steps are really what ISO14001 expects from an EMS. 8. When put together from a business perspective, the EMS is a tremendous system for managing environmental concerns. Perhaps for the first time, management, not the environmental professional, is stating expectations. Again, this is a business approach to environmental stewardship. Lets be realistic. Management expectations have a tendency to be accomplished. The desires of the environmental professional will only get done when the professional takes the time to do them. 9. There is a negative to any ISO certification that is the first thing that anyone thinks about, especially if they have gone through ISO9000, and it is that the documentation will be burdensome. While that can be the case, the rest of the presentation will give tips on ways to minimize that burden and to use the documentation to make your EMS more effective and efficient. The Standard itself does not say that you have to have an EMS manual, but you do have to develop a system that is both documented and which offers objective evidence of accomplishment. Your EMS manual is the tool to do that. 10. Your auditor does not want to flunk your EMS. He only wants to find OBJECTIVE EVIDENCE that will show that you have met conditions in the Standard. That is his job. Here is the key. Make your system easy for him to make that link. 11. First, was our manual itself. We developed a chapter for every paragraph in the Standard. The chapter explained how we accomplished the ISO requirements, but since it was organized as a match to the paragraphs in the Standard, it was the first in a series of methods specifically designed to make it easy for the auditor to find objective evidence. 12. A very significant part of the audit will be a review of the Environmental Policy. 13. The content of the Policy must include commitments to Prevention of Pollution; Compliance; and Continual Improvement. This is not rocket science. Your policy has to have those words in it. 14. Next you have to consider Environmental Aspects and Significant Environmental Aspects, It is very important that you understand the difference between them. 15. Environmental Aspects have a unique meaning under ISO that is not evident by connotation. It is the interaction of the environment with the Activities, Products and Service from your operations. Significant about it is that there is no quantification or hazard assessment. Only that there is an interaction with the environment. Here is an everyday example. When you go on a picnic there are environmental aspects associated with that activity. You throw away your paper cups and plastic plates. You light a charcoal grill. But that does not mean you are being environmentally irresponsible. It only represents the interactions your activities

have with the environment. It is not an inherently bad thing to have Environmental Aspects. In fact, you have to have them because they are the initial step in building your Environmental Management System. You need to know what your potential environmental interactions are before you can pick out the significant ones. 16. That bring us to Significant Environmental Aspects. One could easily jump to the conclusion that a Significant Environmental Aspect is a significant source of pollution. That is not the meaning of Significant Environmental Aspect for ISO. Once you know all of the Environmental Aspects, you simply pick out the most important ones that you have an opportunity to control and call those Significant Environmental Aspects. Does anyone recognize that this is really a business approach? 17. How do you move from Environmental Aspects to Significant Environmental Aspects? You develop and apply a SYSTEM. 18. The auditor is not likely to argue with your system, as long as you have a rationale that is consistently applied. Here is an example of one. Recognize at this point that your Significant Environmental Aspects will be a very important part of your EMS because many of the ISO requirements zero in on them. As this example is further developed, you will also see it made it easier for the auditor to find objective evidence of ISO conformance. 19. Here is a fictitious manufacturing operation. There are seven steps to the operation, and for each step we will consider its environmental impact in six areas or Environmental Aspects. Those six are Air Emissions; Chemical Usage; energy Usage; Hazardous Waste: Solid Waste; and Water Usage. 20. For the sake of brevity, we will only show the application of this system for two of the steps. 21. Next we add columns for comments and outputs which are helpful in giving some additional information as we prepare for the next step which is developing a Significancy Rating score for each Aspect. 22. The example shows that each Aspect gets a quantitative score for its IMPACT ON THE ENVIRONMENT; IMPACT ON PUBLIC HEALTH; ISSUES OF LEGAL, REGULATORY & OTHER REQUIREMENTS; and VIEWS OF INTERESTED PARTIES. The cumulative score is then the SIGNIFICANCY RATING. 23. Since this information is on a spreadsheet, it can be sorted on the Significancy Rating column to have the highest to lowest scoring. The top X scores will be called Significant Environmental Aspects for the fictitious factory. Where the split is made may be somewhat arbitrary, but you need to defend it. In our example case, there is a big gap between the scores of 10 and 7, but we want more than two Significant Aspects, so we show that we will make the break at a score of 6. Our Executive Advisory Committee, and the minutes of that meeting, documented the Executive approval of the Significant Environmental Aspects.

24. So now we have identified our Significant Environmental Aspects and we are ready to continue developing our EMS. Operational Control, and Monitoring and Measuring are next. These requirements apply to our Significant Environmental Aspects, so we are not done with our spreadsheet 25. From an ease of auditing standpoint our spreadsheet is now starting to pay dividends. Every Significant Aspect must have Operational Controls Of course those are the SOPs that are in our Document Control system and the auditor can easily find them by referring to the documents shown in the column. Every Significant Aspect must have Monitoring and Measurement Those are the metrics shown in the Monitor & Measure column. Again the auditor will find it amazingly easy to find the evidence for this requirement because the matrix shows him what to ask to see. 26. If you look at the process that the spreadsheet documents, you can see that indeed it is a Business Approach to Environmental Stewardship. 27. The next major elements are Objectives and Targets, and Environmental Management Plans. Now forget about the spreadsheet, because you do not want to make the mistake that your Objectives and Targets must come from your Significant Environmental Aspects. Objectives and Targets can be anything that is an environmental improvement project. While it may be related to a Significant Aspect, it need not come only from that group. 28. Here is what ISO has to say about Objectives and Targets. When establishing and reviewing its objectives, an organization shall consider the LEGAL and other requirements, its SIGNIFICANT ENVIRONMENTAL ASPECTS, its TECHNOLOGICAL OPTIONS, and it FINANCIAL, OPERATIONAL and BUSINESS REQUIREMENTS and the VIEWS OF INTERESTED PARTIES. This is ISO verbatim. Look at what it says about business and business requirements. In essence it says that you should follow all the laws and be environmentally responsible, but you do not need to spend a million dollars to solve a three dollar problem. Your objectives and targets are the environmental improvement projects that you want to do. Your Environmental Management Plan is how you are going to do them, but you cant just pick something out without showing documentation that you CONSIDERED all of the things mentioned in the Standard. For that you need a system. 29. Here is an example of that documentation. Again, it makes it easy for the auditor to verify that we did the Consideration. Our Executive Advisory Committee approves all Objectives and Targets. In the course of that approval, a controlled Planning Form and the minutes of the meeting show that the Committee considered each of the ISO requirements. 30. Some of the remaining significant elements that your EMS will have to address are: Emergency Response; Document Control; and Corrective Actions. Every plant has some existing procedures for Emergency Response so it is just a matter of putting them in your

EMS. Document Control and Corrective Actions were elements that already existed in our ISO 9000 program. Our EMS just had to reference our ISO14001 Document Control and Corrective Actions to the ISO9000 system that exists. 31. Finally, there is the nagging question of how much does it cost to go through the process of preparing for ISO14001 certification. It is not uncommon to hear that it will cost $250,000. We did not find that to be anywhere close to the case. You can see that the total direct expense came to just under $53 thousand. There are two areas of expenses that need to be emphasized as critical. You can see that nearly half our total was on consulting assistance. With our starting point as being un-initiated in the ways of an ISO EMS Lead Auditor, that assistance was critical to keeping our work product on target. Also, dont pass up the opportunity to have a stage 1 audit. It is a practice audit probably by the same auditor who will do the real ISO stage 2 audit. But because it is practice he has the latitude of providing some coaching on where you need to change things.

Practical Implementation of an ISO14001 Environmental Management System

Presentation by Robert Hepker CIH, CSP, CHMM

ISO14001 - What it is not!

ISO14001 - What it is!

Business Approach to Environmental Stewardship

How Did We Put It Together?

ADVANTAGES 1. ISO9000 Document Control Corrective and Preventive Actions

How Did We Put It Together?

ADVANTAGES 1. ISO9000 Document Control Corrective and Preventive Actions EMS Lead Auditor

2. Excellent Consulting Assistance

Business Approach to Environmental Stewardship

3. DO 2. PLAN

1. THINK

4. CHECK

ISO14001 Positives & Negatives

Tremendous system for managing environmental concerns.

ISO14001 Positives & Negatives

Tremendous system for managing environmental concerns.

Documentation requirements can be burdensome

1. Say what you do! 2. Do what you say! 3. Prove it!

EMS Manual

ISO14001 Elements

EMS MANUAL

1. Introduction 2. Environmental Policy 3. Structure & Responsibility 4. Environmental Aspects 5. Env. Objectives & Targets 6. Env Management Programs 7. Training & Competence 8. Internal Communication 9. External Communication 10. EMS Documentation

11. 12. 13. 14. 15. 16. 17. 18. 19. 20.

EMS Document Control Operational Control Purchasing & Subcontractor Control Emergency Preparedness Monitoring & Measurements Measuring & Testing Corrective/Preventive Actions Environmental Records Internal EMS Audits Management Review

ISO14001 Elements

EMS MANUAL

POLICY

POLICY
From top management appropriate to nature, scale and environmental impacts commitment to prevention of pollution commitment to compliance commitment to continual improvement framework for setting and reviewing environmental objectives and targets communicated to all employees available to the public

ISO14001 Elements

EMS MANUAL

POLICY

ENVIRONMENTAL ASPECTS & SIGNIFICANT ENVIRONMENTAL ASPECTS

Environmental Aspect

Activities Products Services

that can interact with the environment

ISO unique term No quantification or hazard assessment

SIGNIFICANT ENVIRONMENTAL ASPECTS

The MOST important of all the Environmental Aspects

SIGNIFICANT ENVIRONMENTAL ASPECTS

Hey Bob, how do you move from Environmental Aspects to Significant Environmental Aspects??

Develop and apply a SYSTEM

Significancy Screening - Example

Start with environmental aspects

Use a system to pick out the most important ones

ISO14001 Elements

EMS MANUAL

POLICY

ENVIRONMENTAL ASPECTS & SIGNIFICANT ENVIRONMENTAL ASPECTS

OPERATIONAL CONTROL, MONITORING AND MEASURING

Business Approach to Environmental Stewardship

3. DO 2. PLAN

1. THINK

4. CHECK

ISO14001 Elements

EMS MANUAL

POLICY

ENVIRONMENTAL ASPECTS & SIGNIFICANT ENVIRONMENTAL ASPECTS OBJECTIVES TARGETS AND ENVIRONMENTAL MANAGEMENT PLANS

OPERATIONAL CONTROL, MONITORING AND MEASURING

ISO14001 4.3.3

Objectives and Targets

When establishing and reviewing its objectives, an organization shall consider the LEGAL and other requirements, its SIGNIFICANT ENVIRONMENTAL ASPECTS, its TECHNOLOGICAL OPTIONS , and its FINANCIAL, OPERATIONAL and BUSINESS REQUIREMENTS and the VIEWS OF INTERESTED PARTIES.

SYSTEM needed to accomplish these specific bullets. Say it, do it, prove it

ENVIRONMENTAL OBJECTIVE & TARGET PLANNING Air Emissions Control

CONSIDERATIONS COMMENTS

Legal and other requirements Significant Environmental Aspects Technological Options Financial Considerations Operational Controls Business Requirements Views of Interested Parties

No legal requirement to add air emission treatment. Air emissions from the painting operation is a significant environmental aspect. Carbon absorption Incineration To be determined from technological options Current SOPs do not control air emissions. SOPs will be needed for PM of treatment units. Paint operation will be down for two weeks for installation. Supply can cover demand. Community will appreciate removal of VOCs from air stream.

ISO14001 Elements

EMS MANUAL

POLICY

ENVIRONMENTAL ASPECTS & SIGNIFICANT ENVIRONMENTAL ASPECTS OBJECTIVES TARGETS AND ENVIRONMENTAL MANAGEMENT PLANS

OPERATIONAL CONTROL, MONITORING AND MEASURING EMERGENCY RESPONSE, DOCUMENT CONTROL, CORRECTIVE ACTIONS