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GAP ANALYSIS 1S0 14001 2011-2012

GAP ANALYSIS CHECKLIST

ISO 14001

SYSTEM REQUIREMENT

CURRENT PRACTICE AND FINDING

EMS SATISFIED (Yes/NO/Partl y)

Recommendation

4.1

I.ENVIRONMENTAL MANAGEMENT SYSTEM (EMS) General Is there a documented EMS which conforms to the requirements of the ISO 14001 Standard

4.1

Is the EMS kept up to date

There is no formal documented environmental management system exist within the company. Most of formal EMS component are absent. Sound environmentally practices mostly are coordinated by Environment Department on the site; however, these practices are not yet covered by well established system. Not applicable

No

The company should develop a documented EMS in accordance with ISO 14001 Standards requirements and document existing environmental practices The EMS should be kept up to date

No

4.1

2.1

Are all clauses of the standards addressed?

Not applicable

No

The EMS should address all clauses and sub clauses of ISO 14001 Standard The EMS should address all clauses and sub clauses of ISO 14001 standard The EMS should address the company environmental commitments The EMS should cover all activities, product and services of the company

4.1

Is the EMS sufficiently implemented

Not Applicable

No

4.1

Are other environmental commitments addressed within EMS Does the scope of the EMS cover all the company activities, products and services? II. ENVIRONMENTAL POLICY Has the company top management defined, endorsed and signed the policy

Not Applicable

No

4.1

Not Applicable

No

4.2

Is the companys policy consistent with the corporate policy

Top management of PT WBN has establish and signed the environmental policy which become driven force of all activities in all phase, pre construction, construction and operation. However, the policy has not yet reflected into objectives, targets and program in term of systematic environmentally program activities. The policy was designed to follow the ERAMET environmental charter and satisfy the current condition of the areas where PT WBN exists. Moreover, the environmental policy is consistent to the corporate policy to establish best practices in term of environmental management system.

Yes

Policy is needed to be socialized to all employees, contractor and sub contractor.

Yes

The head company (Eramet) has determined the environment principles and the policy is in line with the Eramet environmental principles.

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GAP ANALYSIS 1S0 14001 2011-2012

4.2.a

Does the policy sufficiently describe the company activities, product and service

4.2.a

Is the policy appropriate to the nature , scale and environmental impact of its activities, products and /or services Does the policy include a commitment to continual improvement of environmental performance

The policy covers commitment of the company to comply all relevant regulations, to identify, assess, manage and monitor all environmental risks, assess the potential impacts of future activities, to monitor and control the environmental impact, to conduct targeted and ongoing research and monitoring of new technologies, to continually improve environmental performance. The policy was designed to be driven force for all activities related to project. The project is to build the nickel and cobalt processing Yes

Yes

Company commitment, activity program, implementation plan, monitoring plan and continuous improvement process should be imposed in the policy

Yes

4.2.b

4.2.b

Does the policy include a commitment to pollution prevention

Yes

4.2.d

Does the policy include a commitment to system improvement

Yes

4.2.c

Does the policy provide a framework for setting and reviewing environmental objectives and targets

Not yet

4.2.c

Does the policy include a commitment to comply with legal and regulatory requirement

Yes

4.2.f

Does the policy include a commitment to comply with other requirement

Yes

4.2.f

10

Is the policy available to the public

Not yet

No

The policy has not yet been published to pubic through the website or to employee.

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GAP ANALYSIS 1S0 14001 2011-2012

11

Has the policy been updated as a result of audits/review

12

Has the policy been communicated to all (including contractor and employees)

Not Yet, so far there is no internal or external environmental audit yet, therefore the policy is not from the audits, however the environmental policy is updating version which go along the ERAMET environmental policy. Not yet

No

Internal audits should be incorporate in the implementation of EMS, and if any issues of improvement should incorporate in the policy .

The

4.3 4.3.1 1

II. PLANNING ACTIVITIES 1.Environmental Aspects Is there a method to identify and evaluate significant environmental aspect that they can directly control?

So far, there is no specific methods to identify environmental aspect impact, however, in the environmental impact assessment report (AMDAL) and ESHIA document, the general environmental aspect impact have been identified.

Partly/No

The company should establish a procedure for identifying environmental aspects and impact relevant to all activities and operations (including environmental aspect impact from activities and operations of the suppliers and contractors) under the normal, abnormal and accidental and emergency condition and establish a system to evaluate the significance of each environmental aspect. The company should also establish a register of the environmental aspect impact and keep the register up to date.

4.3.1

Is there a method to identify and evaluate significant environmental aspects that they can influence

General assessment in the AMDAL report and ESHIA report, however the assessment was part of AMDAL requirement. There is no specific method to allocate significance, however in the ESHIA report, it describe the likelihood and the magnitude of the impact, in way the combination of highly likelihood and magnitude result in high significance.

No

4.3.1

Is there a sound method to allocate significance

No

4.3.1

Is there a method to link objectives to these significant aspects

Not applicable, since there are no specific of objectives and target within environmental management system

No

There should be a method to allocate significance of environmental aspect. Environmental aspect evaluated as significant have to be either controlled by appropriate operational controls or improved by objectives and target setting. The top management has to consider significant environmental aspects in setting objectives and targets. Each objective and target should crossreference to relevant significant

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GAP ANALYSIS 1S0 14001 2011-2012

4.3.1

If yes, is it implemented and updated?

Not yet

No

4.3.1.A

Has an Initial environmental Review been carried out

The IER is in progress

Partly, the IER is being conducted No

The company should complete the IER

4.3.1.A

4.3.1.A

4.3.1.A

1 4.3.2 2

Did the review cover the four key areas legislation and regulatory requirements an identification of significant environmental aspects an examination of all existing environmental management practices and procedures. An evaluation of feedback from the investigation of previous incidents. Has the method for identifying of environmental aspects considered the following where relevant: emission to air releases to water waste management contamination of land impact on communities use of raw material and natural resources use of chemical and storage use of fuels impact on biodiversity impact on marine environment impact on fresh water system local environmental issues Consideration on situation such as: abnormal normal accidents emergency condition II. PLANNING ACTIVITIES 2. Legal and other requirements Is there a method to identify and have access to: legal and regulatory requirement (permits/consents) other requirements

The IER was only conducted within environmental department. The Review covers: 1. List of legislation and regulatory requirement 2. Document system and SOPs 3. Identification of activities and aspect

Identification of environmental impact is mainly described and listed in the AMDAL documents. emission to air releases to water waste management contamination of land impact on communities use of raw material and natural resources use of chemical and storage use of fuels impact on biodiversity impact on marine environment impact on fresh water system local environmental issues Yes, in the environmental impact assessment methods. There are several SOP created in managing the emergency response to natural disaster and accident.

Partly and has not yet follow the ISO standard in term of registered, analysis likelihood and risk rating.

Workshop for identification aspect and impact. Prior to that, it is recommended to have basic ISO 14001 training so that the project team will understand and aware of the ISO 14001 requirement.

Not yet existed fully

When making identification of aspect and impact, it should look the significance in the different situation.

Yes, legal and regulation are listed according to the intended compliance.

Yes, partly

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GAP ANALYSIS 1S0 14001 2011-2012

4.3.2

Is the method also used for products and services

Not applicable

No

The project has not yet had product (ferronickel), but the ore mining started in January for Karkar, and Nurspera

How are these requirement kept up to date

Not applicable

No

Have they related the requirements to their activities, products and services II.PLANNING ACTIVITIES 3. Objectives and targets, and programs

Not applicable

No

4.3.3

Is there a method to establish Objectives and targets

Not yet

No

4.3.3

Are these objectives and targets set on a company wide basis

Not applicable

No

The company in general or the environment project team need to establish the objective and target of the environmental management system Objectives are overall environmental goals, arising from the environmental policy, that an organization sets itself to achieve, and which is quantified where practicable, while targets should detail performance requirement, quantified where practicable, applicable to an organization or parts, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives

4.3.3

Are these objectives and targets set at each relevant function and level within the company Do the objectives and targets consider: Significant aspects The legal requirements Other EMS requirements Views of interested parties Financial, operational and business goals Are the objectives and targets consistent with the environmental policy, including a commitment to prevention of pollution Are objectives specific

Not applicable

No

4.3.3

Not applicable

No

When setting up the objectives and targets, they should consider the significant aspect, legal requirement, EMS requirements, view of interested parties, and financial operation business goals. Objectives and target should consistent with the policy and reflect the spirit of the environment policy. Objectives and targets should be SMART, specific, measurable, achievable, realistic, timely.

4.3.3

Not applicable

4.3.3 A

Not applicable

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GAP ANALYSIS 1S0 14001 2011-2012

Are the targets measurable where practicable

No

Do objectives and targets take preventive measures into account where appropriate

There is no a systematic system in establishing objectives and targets and a monitoring system to check progress towards achieving these objectives and target

NO

Objectives and targets should take preventive measures into account where appropriate

4.3.4 4.3.4.b

1 2

II. PLANNING ACTIVITIES 4. Environmental management programme Is there program to achieve objectives and targets There are no specific programs to achieve objectives and targets, in particular for waste, energy and water conservation. However, the practices in the site reflect some program intended to recycling waste and to conserve water. Not clearly defined Partly There should be a formal and detailed environmental management program or action plan with the time frame to achieve each objective and target. This program should be regularly reviewed and revised where necessary Same as above

4.3.4.A

Does the program define the means (detailed program steps) and time frame by which objectives and targets are to be achieved Has responsibility for achieving Objectives and Targets been designated at each relevant function & level in the company Has Environmental Management been applied to programme(s) relating to projects covering: a) new developments? b) new or modified activities? c) new or modified products? d) new or modified services? Does the programme for current and new activities, products and services consider the following stages? Planning Design Production Marketing disposal Does the programme for products consider the following stages? Design Materials

Partly

4.3.4.A

Not clearly defined

NO

The environmental management program should assign responsibilities fro achieving the objectives and targets. Environmental management should be applied to program relating to projects covering: New development New or modified activities New or modified product New of modified services The company should consider these stage in establishing the environmental management program

4.3.4.A

Not clearly defined

No

4.3.4.A

4.3.4.A

No

Not

It is recommending to consider these stage

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GAP ANALYSIS 1S0 14001 2011-2012

4.3.4.A

4.4.1

Production Processes use and disposed Does the programme for installation or significant process modifications address the following stages? Planning Design Construction Commissioning Operation decommissioning III. IMPLEMENTATION AND OPERATIONAL ISSUES 1. Structure and responsibilities Have roles, responsibilities and authorities for effective environmental management been: Defined? Documented? Communicated? Has the management provided the following resources for EMS implementation and control? human resources specialized skills technology financial resources Has the company appointed specific management representative(s) to: ensure EMS is established, implemented and maintained? report performance of EMS to top management for review and EMS improvement? Have environmental responsibilities been defined in departments other than just the environmental department?

no

no

4.4.1

The new organization structure show the line of roles, responsibilities, and authorities for environmental management. In each sub department and division, document control and communication system has been defined at all level. Communication system uses the intranet, share point and weekly meeting. The team will assembled from existing human resources available within the environmental department and possible representative from each department. The team member should have

Yes

To implement environmental management system, it is necessary to have specific project team to design the EMS, to plan and monitor the implementation of EMS The company should establish a procedure to ensure all these resources are sufficient, and utilized and managed in systematic and effective way.

Partly

4.4.1.a.b

Management representative will be appointed once the EMS project is agreed and the initial environmental review and gap analysis is done

Not yet

Management representative is of responsible a clearly strategy of change, coordinate schedule meeting and the implementation of the project team and bridge between project team and steering committee. Increasing the awareness of environmental management to all employees should be apriority of the EMS project. This can be done through campaign, communication and training.

4.4.1.A

The environmental responsibilities mainly still lies within environmental department. The environmental department conducts environmental inspection and monitoring across departments. However, other departments are urged to adopt environmentally sound practices within their activities.

Partly

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GAP ANALYSIS 1S0 14001 2011-2012

4.4.1.A

Does top management ensure that appropriate resources are provided to ensure the EMS is implemented and maintained?

Not applicable, because the company has not had EMS yet

NO

The EMS should be documented, periodically reviewed and revised where necessary, and authorized by the General Manager to ensure that appropriate resources are provided for implementing and maintaining the EMS

4.4.2

III. IMPLEMENTATION AND OPERATION ISSUES 2. Training, Awareness and Competence Has the company identified training needs

4.4.2

Has the company appropriately trained those personnel whose work may have a significant impact on the environment?

Training need information usually come from the sub department manager and proposed to HR department. If appropriate and match with the development process f the employee, employee can take the training The staff in the environmental department, in particular those at supervisor level has gained several training including first level mining supervision training, waste management training, and other, however the training documentation is not really defined. Standard operation procedures have become the guideline when conducting activities. Currently, within environmental department, there are more than 30 SOP which divided into three categories, baseline monitoring, rehabilitation and biodiversity and environmental monitoring and inspection. SOPs was design and prepared by environmental department based on template and reference agreed by the manager

Yes/partly

Methodology used is bottom up, employee give detailed training they need and HR process and funded. As part of EMS implementation, training on awareness, documentation and monitoring aspect of EMS is crucial. The trainings are intended to employees whose role and responsible related to EMS requirements. SOPs should be prepared base on the activities concerned in the ISO 14001. At least there are 14 must have SOPs in the ISO 14001 and from the initial review, the company can get the comparison.

Yes/partly

4.4.2

4.4.2

Are there procedures to ensure employees at each level & function are aware of: importance of conformance with the environmental policy and procedure? importance of conformance with the requirements of the EMS? the significant environmental impacts, actual or potential, of their work? the environmental benefits of improved personal performance? their roles and responsibilities in achieving conformance with the environmental policy and procedures? their roles and responsibilities in achieving conformance with the requirements of the EMS including emergency preparedness and response requirements? the potential consequences of departure from specified operating procedures? Are those who perform tasks that can cause significant impacts competent to do so, based on appropriate education, training and/or experience? Has the company determined whether contractors

Yes/partly

The information on other department condition is not available right now since the IER is only focus to the environment department The company currently working with several contractors to

No Information

4.4.2

Partly

The implementation of EMS should cover process, product and services of the company, and other department also shall take part in this process. The company can start to be selective

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GAP ANALYSIS 1S0 14001 2011-2012

working on their behalf can show that their employees have the requisite training?

do activities in different department, for example mining, drilling, sample analysis, construction. Most of the contractor is local and national contractor; however, so far there is no information whether they are ISO 14001 or ISO 9001 certified contractor.

to contractor that ISO certified contractor and be used as one of the requirement.

4.4.3.a

III. IMPLEMENTATION AND OPERATIONAL ISSUES 3. Communications Does the company have a method for internal communications about its significant aspects and EMS, between the various levels and functions?

4.4.3.a

Does the company have a method for receiving, documenting and responding to relevant communication from external interested parties about its significant aspects and EMS Has the company decided whether to communicate its significant aspects externally?

Within environmental department, there is internet share point where the main management level can share information, weekly meeting for core team in Jakarta and site, bi-weekly reporting. While for external, the GM environment department has regular meeting with other top management. For all part of company, communication department can be asked to published information on the weekly newsletter and also magazine. Yes, all document or communication from external usually received by intended recipient then if necessary the document or information will be uploaded by document controller Release of information should go through standard operation procedure of communication to external parties. GM responsible for disseminate information if necessary to team, and all information release from communication department In regard of environmental performance, the environment department maintain dialogue with other department, while externally, environment department maintain dialogue with government and stakeholders. The company keeps correspondences to public authorities such as village head, bupati.

Yes/partly

Communication method should be documented as for internal communications as well as record all correspondences

Yes/partly

As part of document control, all communication or document need to be recorded.

4.4.3.a

Yes/partly

To communicate the significant environmental aspect, the company should establish a procedure to explain the method.

4.4.3.a

Has there been any dialogue with external interested parties, other than the regulators?

Yes/partly

4.4.3.a

Has there been any dialogue with public authorities regarding emergency planning and other relevant issues? III. IMPLEMENTATION AND OPERATIONAL ISSUES 4/5. EMS Documentation and Document Control Is there information in paper or electronic form to describe the core elements of the management system and their interactions?

Yes/partly

4.4.4.a

So far EMS is not documented yet, either in paper or electronic form

No

EMS shall be documented both in paper and electronic.

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GAP ANALYSIS 1S0 14001 2011-2012

4.4.4.a

Does this information provide direction to relevant documentation? Is there a method to control all documents such that : they can be located? they are periodically reviewed, revised as necessary and approved for adequacy by authorized personnel? current versions of all relevant documents are available at appropriate operational locations? obsolete documents are removed promptly and their disposal ensured? obsolete documents retained for reference are suitably identified? Is the documentation: legible? dated (with dates of revision)? readily identifiable? maintained in an orderly manner? retained for a specific time? Is there a method detailing who is responsible for creation and modification of the various types of documentation? III. IMPLEMENTATION AND OPERATIONAL ISSUES 6. Operational Control Has the company identified those operations and activities that are associated with the identified significant environmental aspects in line with its policy objectives and targets?

Not applicable

No

EMS documentation system should provide direction to relevant documentation In the future, as part of EMS, it is important to define a document control system to control, EMS documentation to ensure compliance with ISO 14001 standard requirements.

4.4.5

So far all documents within environmental department is stored in the share point at site and share point in Jakarta. Document control is part of each supervisor responsibilities. Any changes of document, the supervisor will give notice. Moreover, the tool box meeting every morning ensures that all employees get informed regarding the SOPs or any related issues.

Partly

4.4.5

The documentation in the share point is only available to those who have access to share point, however, if there is document need to be informed to all employees, supervisor printed and put the document shelf.

Partly

EMS procedure is to ensure that the EMS documentation is legible, dated, readily identifiable, maintained in orderly manner, retained for specific time. The responsibility for document creation and modification should be defined.

4.4.5

So far, there is no specific procedure to determine whose roles and responsibilities for creation and modification of various types, however supervisor responsible to establish and ask for supervision and approval from the upper level.

Partly

4.4.6

Has the company planned these activities, including maintenance, in order to ensure that they are carried out under specified conditions by: establishing and maintaining documented procedures to cover situations where their absence could lead to deviations from the environmental policy and the objectives and targets? stipulating operation criteria in the procedures? establishing and maintaining procedures related to

Yes partly, the company, in particular the environmental department has identified environmental aspect impacts based on activities, for example n, and environmental inspection. However, it needs to see in other department, whether other department also have standard operation procedures based on the identified aspect and impacts Yes, the environmental department has some formal SOP and work instruction sheet (maintenance schedule, sampling schedule, and notice board) for internal use. Detailed operation criteria and responsibilities are moderately defined.

Partly

EMS required documented, accessible and implemented standard operation procedures and control which based on the identified environmental aspect and impacts EMS required well documented operation control procedures to control activities and operations related to significant environmental aspects and consider communicating these procedures and requirements to supplier and contractors. .

Partly

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GAP ANALYSIS 1S0 14001 2011-2012

4.4.7

the identifiable significant environmental aspects of goods and services used by the company and communicating relevant procedures and requirements to suppliers and contractors? III. IMPLEMENTATION AND OPERATIONAL ISSUES 7. Emergency Preparedness and Response Has the company established and maintained a method to: identify potential for accidents and emergencies? respond to accidents and emergency situations? prevent and mitigate the environmental impacts that may be associated with them?

Yes. The environmental department has established procedure operation when the environmental incident or accidental take place, for example, oil spill, soil erosion , or riots

Yes

Has the company reviewed and revised, where necessary, its emergency preparedness and response procedures, in particular, after the occurrence of accidents or emergency situations?

Has the company periodically tested such procedures where practicable? IV. CHECKING AND CORRECTIVE ACTION 1. Monitoring and Measurement

In regards of emergency preparedness and response, the OHS department also has significant roles and responsibility. The fire system, lighting and power system also has been monitored regularly. The maintenance and preventive activities are done by the EMC department, while emergencies related safety are organized by OHS department. For example, during the pre construction process, the frequency of traffic incident increase, therefore the OHS department reviews the speed limit regulation on the road. The company test the emergencies system such as during fire, riots and evacuation

Yes

As part of the operation control, EMS requires established and maintained procedures in identifying potential for accident, and respond to emergency situation and mitigate the environmental impact that may be associated with them. Moreover, these programmes should be tested and revised periodically where necessary, and communicate about it to all employees. The company should establish, maintain, and test (where practicable) procedures to identify potential for and to respond to accidents and emergencies situations and for preventing and mitigating the environmental impacts that may be associated with them

Yes

All these procedures should be periodically tested where practicable

Has the company established and maintained documented procedures to monitor and measure on a regular basis the key characteristics of its operations and activities that can have a significant impact on the environment?

Review of records and document system in the environmental department shows that the department has conducted regular monitoring and measurement on resources usage, waste management record, baseline environmental monitoring. Formal documented monitoring and measurement procedures are absents.

Partly

The company should establish and maintain procedures to monitor and measure, on regular basis, the key characteristic of its operation and activities that can have a significant impact on the environment. Monitoring equipement is calibrated according to schedule and records are maintained. Implementing a procedure to

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GAP ANALYSIS 1S0 14001 2011-2012

Does this include the recording of information to track performance, relevant operational controls and conformance with the companys objectives and targets?

Some records are kept in hardcopy and softcopy, however, as stated before the relation between the operational control and conformance with the objectives and are absent.

No

periodically evaluate compliance with relevant environmental regulation and legislations The company should establish and maintain documented procedures to record information to tract performance, relevant operational control and conformance with the objectives and targets

3 4

Do they calibrate and maintain monitoring equipment? Do they retain records of this process according to their procedures? Has the company established and maintained a documented procedure for periodically evaluating, compliance with relevant environmental legislation and regulations?

The calibration of equipment is done regularly, in particular for baseline environmental management. Records are kept in the hard copy or soft copy file, however, it is to be reorganize and coordinated so it is accessible to others One of the environmental impact assessment report requirements is to provide quarterly environmental monitoring and management plan to the Government, and part of legislation and regulation comply, the company welcome any site inspection by government authorities. However, so far there is no formal documented procedure to evaluate legal compliance periodically.

Yes Yes

Partly

The company should establish and maintain a documented procedure for periodically evaluating compliance with relevant environmental legislation and regulations.

4.5.2

IV. CHECKING AND CORRECTIVE ACTION 2. Non-conformance and Corrective and Preventive Action Has the company established and maintained methods for defining responsibility and authority: for handling and investigating nonconformance? for taking action to mitigate any impacts caused? for initiating and completing

Yes, when nonconformances occur, the site environmental department manager normally reviews the issues and assigned the superintendent and supervisor to inspect the incident. Mitigation effort and corrective action then is undertaken.

Yes

The company should establish a documented procedures for stating the method and defining the responsibility and authority: for handling and investigation non conformance for taking action to mitigate any impact caused for initiating and completing corrective and preventive action.

Has the corrective or preventive action taken to eliminate the causes of actual and potential nonconformance been appropriate to the magnitude of problems and commensurate with the environmental impact encountered?

Yes. In the environment inspection record shows the corrective actions to response any environmental incident. The inspection is carried out regularly and when the incident occurs, the superintendent is informed to check it. The superintended will base on their experience and consult external parties where necessary to implement appropriate actions to mitigate any abnormal performance.

Yes

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GAP ANALYSIS 1S0 14001 2011-2012

4.5.2.A

Has the company implemented and recorded any changes in the documented procedures resulting from corrective and preventive action? In establishing and maintaining procedures for investigating and correcting non-conformance, has the company included these basic elements : identified the cause of the non-conformance? identified and implement the necessary actions? implemented or modified controls necessary to avoid repetition of the non conformance? recorded any changes in written procedures resulting from the corrective action? IV. CHECKING AND CORRECTIVE ACTION 3. Records Has the company established and maintained methods for the identification, maintenance and disposition of environmental records? Do these records include training records? results of audits? results of reviews? Are these environmental records: Legible? Identifiable? traceable to the activity, product or service Involved? Are the environmental records stored and maintained in such a way that they are readily retrievable and protected against damage, deterioration or loss? Are retention times established and recorded?

The department usually record the action in the environmental inspection and corrective actions logbooks Yes, as shown in the environmental inspection and monitoring report, identification of cause of non conformance, actions required and review are undertaken.

Yes

Yes

EMS required all these basic elements to be consider while establishing and maintaining procedures for investigating and correcting non conformance

4.5.3

4.5.3

Review on records and document, both hard copy and soft copy shows that the department keeps records relevant to resources usage and reuse, equipment. However, it still need improvement in term of regularity and maintenance. Training records biweekly meeting and weekly meeting reports are store in the share point and maintain the updating regularly. Yes, however the organization of the share point need to be controlled by assigned employee

Yes

Yes

EMS require establishment of procedure for identification, maintenance and disposition of environmental records. EMS require the organization to identify and keep all records that arise from the implementation of the EMS Documents and procedures should provide direction to relevant environmental records which should be dated., with title shown on the first page. The department should state the responsibility of keeping environmental records on EMS documents and procedures. The department should record the retention times of environmental records on EMS documents and procedures Record from implementation of EMS should be identified and kept.

4.5.3

Yes

4.5.3

Environmental record are stored in the softcopy and hardcopy forms, each supervisor know the system

Yes

4.5.3

Every document is dated, however there is no information on the retention time fro the document to be kept

NA

4.5.3

Are these records sufficiently maintained, as appropriate to the system and to the company, to demonstrate conformance to the requirements of ISO 14001 Standard? Do methods for identification, maintenance and disposition of records focus on those records needed for

Partly, systematic record on the implementation of EMS procedures in order to conform to the requirements of ISO 14001 Standard are absen

No

4.5.3

No formal method for identification, maintenance and disposition of environmental records

No

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GAP ANALYSIS 1S0 14001 2011-2012

4.5.3.A

the implementation and operation of the environmental management system? Do they record the extent to which planned objectives and targets have been met?

Analyses on existing records and compare the result with the previous analysis. The results, which indicate environmental performance, will be discussed in the department meeting The department keeps records except: Pertinent contractor and supplier information Record on significant environmental aspects Audit results Management reviews

Partly

The department should define the responsibility in environmental management program for recording the progress towards achieving the c=objectives and targets

Do they keep the following environmental records? a) information on applicable environmental laws or other requirements; b) complaint records; c) training records; d) product process information; e) product information; f) inspection, maintenance and calibration records; g) pertinent contractor and supplier information; h) incident reports; i) information on emergency preparedness and response; j) records of significant environmental aspects; k) audits results; l) management reviews. IV. CHECKING AND CORRECTIVE ACTION 4. EMS Internal Audits Has the company established and maintained (a) programme(s) and methods for periodic Environmental management system audits? Have they determined whether the environmental management system: conforms to planned arrangements for environmental management including the requirements of ISO 14001 Standard? has been properly implemented and maintained?

Partly

4.5.4

4.5.4

Not entirely. An environmental audit was conducted by the representative of ERAMET, however this was carried out in general with special attention to OHS department. Audit was conducted in 2009 Not applicable

No

The department should establish and maintain a procedures for defining a program for periodic EMS audits The department should establish an audit program and carry out regular audits to ensure that the EMS: conforms to planned arrangement for environmental management including the requirements for the ISO 14001 has been properly implemented and maintained. EMS audits results are discussed in management review meeting The company should consider all these in establishing EMS audit program

No

4.5.4 4.5.4

3 4

Have they provided information on the results of audits to management? Is the programme based on the : environmental importance of the activity

Not Applicable Not applicable No

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GAP ANALYSIS 1S0 14001 2011-2012

4.5.4.A

4.6

concerned? results of previous audits? Does the audit procedure cover: the audit scope, i.e. the activities and areas to be considered? frequency? methodology, i.e. how the audit will be conducted? responsibilities associated with managing and conducting audits? requirements for conducting audits, i.e. auditor competence? requirements for reporting and communicating the audit findings? Was the audit carried out impartially? objectively? V. MANAGEMENT REVIEW Has the companys top management, at intervals it has determined, reviewed the environmental management system, to ensure its continuing : suitability? adequacy? effectiveness?

Not applicable

NO

Audit procedures should cover these elements

Not applicable

No

The company should arrange EMS auditors properly to ensure audit are performed impartially and objectively The company should establish a procedure to review EMS regularly, based on EMS audits result, comment from interested parties. The management review provides a good chance to see whether the environmental policy is relevant to the company activities and operation EMS required a procedures to ensure that necessary information is collected to allow management to carry out the review EMS required procedures to ensure to ensure that the results of management review are documented A procedure to ensure that all these elements are considered in the management review process

The company top management have formal meeting for review of general performance but not for EMS. Meeting minute are kept

No

4.6

Does the management review process ensure that the necessary information is collected to allow management to carry out this evaluation? Has the review (observations, conclusions and recommendations) been recorded/documented for necessary action? Did the management review address the possible need for changes to policy, objectives and other elements of the EMS, in the light of environmental management system audit results? the extent to which objectives and targets have been met? changing circumstances? concerns amongst interested parties? the commitment to continual improvement? Was the review of the policy, objectives and procedures carried out by the level of management that defined

Not applicable

No

4.6 & A.4.6

Not applicable

No

Not applicable

Not applicable

No

The management review should be attended by top management, in

Prepared by Baiq Dian Zoelaeha

GAP ANALYSIS 1S0 14001 2011-2012

them?

particular the environmental general manager and managers.

Prepared by Baiq Dian Zoelaeha