Customers' and suppliers' increased
awareness of environmental issu
es is spurring process industries and other manufacturers
throughout the world to look for the best ways to integrate
environmental management systems into their day-to-day operations.
Bringing an EMS into the mainstream right alongside other
management systems helps businesses meet their customers'
needs, which, in turn, helps them achieve their own financial
goals. Integrating the EMS into daily operations also helps
to elevate the level of consciousness within a business's
workforce relative to environmental costs and impacts, often
overlooked because they're difficult to quantify.
Perhaps most important, as the EMS becomes an integral
part of an organization's daily operating environment, everyone
within the organization, including decision makers, manufacturing
associates, marketing representatives and finance personnel,
takes ownership in a process that guides the organization
toward achieving much greater productivity.
ISO
14001 Implementation Guideline
Following is an example of a practical implementation
guideline, from which each organization’s practical
checklist can be developed. The checklist helps focus
activities.
Have the implementation team review the current ISO
14001 standard to determine requirements.
Identify an ISO 14000 process owner at the site.
Identify all site processes and functions that carry
special requirements applicable to the EMS.
Define and document a matrix of existing policies
and procedures.
Develop additional procedures to meet requirements,
if needed.
Develop internal training material and methods for
instruction.
Train internal auditors and relevant personnel in
ISO 14000.
Develop communication methods, such as a newsletter,
to promote ISO 14000 to the facility.
Implement all new or changed procedures and collect
documented evidence of implementation during an internal
audit.
Rectify all nonconformities.
Plan the registration audit by writing a scope statement
and a strategy for registration.
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The ISO 14001 standard, often referred to as the "green"
standard, sets forth specific requirements for a comprehensive
EMS. Formally published by the International Organization
for Standardization on Sept. 1, 1996, the standard was developed
to allow organizations to formulate policies and objectives
within a structured management system framework. Simultaneously,
legislative requirements, relevant public issues and plant-specific
environmental concerns could all be considered.
As the introduction to ISO 14001 states, "International
standards concerning environmental management are intended
to provide organizations with the elements of an effective
environmental management system, which can be integrated
with other management requirements (or other management
systems) to assist organizations in achieving environmental
and economic goals."
ISO 14001 specifies the following components of an EMS:
Definition of an environmental policy
Environmental planning, encompassing identifying environmental
aspects and legal obligations, developing objectives and
targets, establishing an environmental management program,
and specifying the means of achieving objectives
Implementation of the EMS and operational control
Assessment of conformity with the standard's requirements
and/or company requirements, and corrective action in the
case of nonconformity
Management review of the EMS
Each of these components must be fulfilled to completely
integrate the EMS into a company's operating environment
and/or achieve ISO 14001 registration.
Those wondering about the need for an EMS should note
that, at this time, the United States is not the main driver
for ISO 14001. Nevertheless, one would be naive to think
the standard will go away.
Many see ISO 14001 certification as the ticket to trade
in Europe and Asia. Already, sufficient evidence exists
from a variety of international initiatives indicating that
ISO 14001 will be widely adopted. Certification is well
under way in the United Kingdom, Japan, East Asia, Brazil,
India, Korea, Argentina, Hong Kong and Taiwan.
The Japanese Ministry of International Trade and Industry
has advocated mandatory third-party registration to ISO
14001. The Japanese electronics industry has responded by
developing the necessary infrastructure, and U.S. companies
are reviewing their existing environmental programs in concert
with the ISO 14001 criteria in order to better develop implementation
strategies.
A company that seeks to integrate ISO 14001 with other
management systems in its business must be willing to begin
that effort with a strong commitment to environmental responsibility.
Perhaps Bin Prasad, manager of quality engineering at Rockwell
Automation, best expressed the current "trend philosophy"
being adopted by more and more companies when he said, "We
really believed at that point [i.e., beginning the ISO 14001
pursuit] that our employees and our customers would prefer
to do business with a company that espouses an environmental
awareness."
Once the commitment to that philosophy is made and communicated
to all employees, the next step is to put in place clearly
defined environmental policies, programs, objectives and
targets. Success at this phase allows an organization to
both mainstream and fully integrate the EMS into its business.
As companies entering the process begin to get their feet
wet, they should first turn to a variety of often-overlooked
aids that may already be available. On-hand information
might prove useful, and a business should consider viewing
the following items--available in almost all organizations'
existing databases--at the initial stage of development:
Documentation of the list of chemicals in the Occupational
Safety and Health Act
Reports prepared for hazard and operability studies
Chemicals listed in the Environmental Protection Act and
the Toxic Substances Control Act's chemical substances inventory
Process safety management rules often implemented in manufacturing
facilities
Form R's and Tier I and Tier II reports submitted under
the Emergency Planning and Community Right to Know Act
Contingency or vulnerability studies completed relative
to critical systems and equipment
Data from risk management studies
Data from corrective action reports, especially data from
preventive maintenance programs and inspections
Maintenance records
When assembled, the information from these resources establishes
the existing environmental baseline, which can be used to
help identify and evaluate environmental aspects and impacts.
Examining the local environment represents a prudent next
step, with the understanding that companies should start
with the major and obvious. Consider the following:
Air/climate factors, including local weather conditions,
air quality data, etc.
Historical and cultural resources
Topography and landscape (from U.S. Geological Survey maps)
Any recreational uses
Proximity to residential areas
Watersheds, wildlife sanctuaries, lakes and streams
Past practices
Be sure to consider existing data from current operating
permits, including:
Wastewater treatment parameters
Air quality emission data
Form R's
SARA Tier I and Tier II reports
Air emissions inventory
Waste characterization studies
Listed hazardous waste
After taking all these considerations into account, an
organization is ready for a review of all key areas. The
review should include a re-examination of all legislative
and regulatory requirements. Take a look at existing environmental
management procedures, feedback obtained from corrective
action response systems, results available from completed
internal audits and industry codes of practice. Use technical
models, when appropriate, to further review potential environmental
aspects and effects.
Once the baseline relative to the environment has been
established, it's time to begin formulating a plan to develop
and deploy the EMS. This could include preparing an ISO
14001 general requirements guideline and framework to identify
environmental aspects and effects. Program support needs
an up-to-date document reference list to help prepare a
step-by-step implementation guideline. Training and development
should be considered part of the general requirements.
Organizations will also find it helpful to refer to Annex
A of ISO 14001:1996 (E), and ISO 14004:1996 (E) Environmental
Management Systems, which contain general guidelines on
principles, systems and supporting techniques to build an
EMS that conforms to ISO 14001 requirements.
Objectives are the overall goals for environmental performance
based on an organization's environmental policy and evaluation
of environmental aspects. Goals should be set after taking
into account the identified environmental aspects as well
as the associated environmental effects. Obviously, special
consideration should be given to those identified as significant
to the organization and the environment. Targets should
be specific, have an established time frame and be measurable.
As companies set objectives and targets, it's acceptable
to consider technological options, financial options, operational
options, and both business and customer requirements. Remember
to include the views of interested parties, such as regulators,
the community, stockholders and nongovernment organizations.
A company should be wary of the temptation to set "appealing"
objectives and targets, which can adversely affect the process
if they're not linked directly to policy and environmental
aspects and effects. When placed correctly, targets should
be linked with environmental aspects, performance indicators,
relevant levels and functions of the organization, relevant
operational controls, and most important, measuring and
monitoring activities.
To maintain conformance with the ISO 14001 standard, an
organization, as it sets objectives and targets, should
discover that the process is continual. Each step must take
into account the previous steps when developing the EMS.
Most companies generate an objectives and targets matrix
or checklist to remain organized and stay on track. An organization
should strive for aggressive but attainable targets and
make available the necessary resources, expertise and time
to reach each of them. Because this involves practical and
effective training of the workforce, both time and cost
for training should be a factor when establishing the time
frame for reaching a target.
At this point, companies should be ready to begin implementing
and completing the integration of ISO 14001 into their existing
management systems. During implementation, companies should
remember to use procedures and programs from existing management
systems whenever possible, continuing to build on what they
have.
Using a guideline and developing a checklist tied to the
ISO 14001 standard is a wise approach and a key ingredient
when planning and integrating an EMS and pursuing ISO 14001
registration. The registrar will be using a checklist, and
a company should too. Objectives and targets of the EMS
don't need to be totally implemented at the time of a registration
audit, but a company must have assembled sufficient evidence
to show progress in the pursuit of its goals.
A company can gather this evidence through an internal
EMS audit that provides objective evidence of implementation,
signs that objectives and targets are being monitored and
measured, and confirmation that progress is being tracked
according to an established time frame.
In summary, as a company successfully integrates an EMS
into its business, its ability to meet its customers' needs
and expectations will improve.
Create and use a checklist linked to the ISO 14001 standard.
Remember that when seeking registration, a company must
be able to identify environmental aspects and effects in
a manner clear to the registrar.
Finally, be practical: Avoid issues over which the organization
has no real control, and refrain from writing elaborate
procedures.
Russell V. Thornton is a manager of environmental certification
for Det Norske Veritas, a leading supplier of accredited
management systems registration services worldwide. He is
a frequent author and lecturer regarding EMS development
and implementation. DNV (www.dnvcert.com)
is based in Houston. Letters to the editor regarding this
article can be e-mailed to letters@qualitydigest.com.
This article originally appeared in the July 1998 issue
of InTech magazine.
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