ISO 14001 Environmental Management System EMS

1
ISO 14001Environmental Management System
(EMS) Auditing Overview for the Department of
Interior
Linda Baetz, EMS-LA and Jim Wood, P.E.,
EMS-LA U.S. Army Center for Health Promotion and
Preventive Medicine
2
Discussion Topics

• EMS Requirement Background
• Preparing for External EMS Audits
• Joint Compliance/EMS Audits
• Evolution of Army EMS Auditing
• Army EMS Audits Lessons Learned
• Army EMS Auditor Training (External Internal
  Auditors)

3
EMS Requirement - Background

• EO 13148 Required Federal Agencies to implement
  EMS
• EO 13423 Reinforced EMS implementation at all
  appropriate levels and EMS use as primary
  management approach
• OFEE EO 13423 Instructions Requires external
  audits initial follow-up (3-yr cycle)

4
Preparing for External EMS Audits(Phase I -
Document Review Phase)

• Understand ISO 14001 Standard
• Review EMS Gap Analysis Results (and determine
  if gaps resolved)
• Understand your DOI-Agency specific EMS
  Manual/procedures
• Review of DOI-Agency specific EMS
  Manual/procedures (ISO 14001 conformance)

5
Preparing for External EMS Audits(Phase II
Internal Audit Phase)

• Conduct an internal EMS audit (using trained
  auditors)
• Implement corrective/preventive action(s) based
  on internal audit
• Understand the different types of nonconformance
  (i.e., major vs. minor) and the level of
  resources commitment for resolution

6
Preparing for External EMS Audits(Common
Nonconformance Issues)

• ISO 14001, 4.1 (General Requirements)
• Has the scope of the EMS been documented?

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Preparing for External EMS Audits(Common
Nonconformance Issues)

• ISO 14001, 4.2 (Environmental Policy)
• Does the policy address all of the mandatory
  commitments?
• Has the policy been communicated to all persons
  working on behalf of the organization (i.e.,
  contractors subcontractors)?

8
Preparing for External EMS Audits(Common
Nonconformance Issues)

• ISO 14001, 4.3.1 (Environmental Aspects)
• Are the aspects documented and kept up-to-date?
• Are the significant aspects taken into account
  in the EMS?

9
Preparing for External EMS Audits(Common
Nonconformance Issues)

• ISO 14001, 4.3.2 (Legal and Other Requirements)
• Do the legal and other requirements apply to
  the environmental aspects?

10
Preparing for External EMS Audits(Common
Nonconformance Issues)

• ISO 14001, 4.3.3 (Objectives, Targets, and
  Programs)
• Have significant environmental aspects been
  considered when establishing objectives/targets?
• Do the programs designate responsibilities,
  means, and time-frames to achieve objectives
  targets?

11
Preparing for External EMS Audits(Common
Nonconformance Issues)

• ISO 14001, 4.4.1 (Resources, Roles,
  Responsibility and Authority)
• Has EMS Management Rep. been appointed?
• Have roles, responsibilities, and authorities
  been documented and communicated?

12
Preparing for External EMS Audits(Common
Nonconformance Issues)

• ISO 14001, 4.4.2 (Competence, Training, and
  Awareness)
• Has competence been determined for persons with
  potential to cause significant environ. impacts?
• Are training needs identified?
• Has awareness been provided to persons working
  on behalf of the organization?

13
Preparing for External EMS Audits(Common
Nonconformance Issues)

• ISO 14001, 4.4.3 (Communication)
• Do external communication procedures match
  actual business practices?
• Has the record of decision (regarding external
  communication of significant environmental
  aspects) been documented?

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Preparing for External EMS Audits(Common
Nonconformance Issues)

• ISO 14001, 4.4.4 (Documentation)
• Does the EMS documentation include all of the
  mandatory requirements?

15
Preparing for External EMS Audits(Common
Nonconformance Issues)

• ISO 14001, 4.4.5 (Control of Documents)
• Do procedures (e.g., approval, review,
  update/re-approval, revision, removal of obsolete
  documents, etc.) match actual business
  practices?
• Are documents of external origin addressed?

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Preparing for External EMS Audits(Common
Nonconformance Issues)

• ISO 14001, 4.4.6 (Operational Control)
• Have operational controls been developed for
  those activities operations with significant
  environmental aspects?
• Are those operational controls being
  implemented at the user level?

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Preparing for External EMS Audits(Common
Nonconformance Issues)

• ISO 14001, 4.4.7 (Emergency Preparedness and
  Response)
• Are emergency preparedness response procedures
  periodically tested (where practicable)?

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Preparing for External EMS Audits(Common
Nonconformance Issues)

• ISO 14001, 4.5.1 (Monitoring and Measurement)
• Are key characteristics of operations (that can
  have significant environmental impact) being
  monitored and measured?
• Are there calibration records for any associated
  monitoring and measurement equipment?

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Preparing for External EMS Audits(Common
Nonconformance Issues)

• ISO 14001, 4.5.2 (Evaluation of Compliance)
• Is there a process for the periodic evaluation of
  compliance with legal and other requirements?
• Are records available of those periodic
  compliance evaluations?

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Preparing for External EMS Audits(Common
Nonconformance Issues)

• ISO 14001, 4.5.3 (Nonconformity, Corrective
  Action Preventive Action)
• Do procedures also address preventive actions?
• Do procedures address corrective prev. action
  effectiveness?
• Do the procedures match the actual business
  practices?

21
Preparing for External EMS Audits(Common
Nonconformance Issues)

• ISO 14001, 4.5.4 (Control of Records)
• Do procedures address the retention times
  disposal of records?
• Are records legible, identifiable, and
  retrievable?

22
Preparing for External EMS Audits(Common
Nonconformance Issues)

• ISO 14001, 4.5.5 (Internal Audit)
• Has an Internal Audit Program been implemented
  (e.g., schedule established auditors identified
  trained audits conducted)?
• Does the selection of auditors the conduct of
  the audits ensure objectivity impartiality of
  the audit process?

23
Preparing for External EMS Audits(Common
Nonconformance Issues)

• ISO 14001, 4.6 (Management Review)
• Has the management review process been
  implemented?
• Does the management review process incorporate
  all of the required inputs?

24
Joint Compliance/EMS Audits(Different Approaches)

• Army Environmental Performance Assessment System
  (EPAS) External Audits Active Component
  Installations
• Concurrent Compliance/EMS Audit
• Dedicated EMS Audit Team
• Separate Compliance EMS Audit Reports

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Joint Compliance/EMS AuditsDifferent Approaches
(Cont.)

• Army EPAS External Audits Reserve Component
  Installations
• Installation Compliance Audit is Conducted First
• Follow-up EMS Audit (conducted months after the
  compliance audit)
• Root Cause Analysis (from compliance audit) is
  used to Formulate EMS Audit Plan

26
Joint Compliance/EMS AuditsDifferent Approaches
(Cont.)

• Defense Logistics Agency (DLA) Compliance and EMS
  Audit Programs
• Separate Compliance EMS Audit Schedules (no
  integration between compliance EMS audits)
• DLA EMS Focus Multi-site Organizational EMS
  vs. Facility-specific EMS

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Joint Compliance/EMS Audits (Key Points)

• Compliance auditing and conformance auditing are
  VERY different skills sets
• If joint compliance/EMS audits are conducted, the
  audit team needs to include dedicated EMS
  auditor(s) (with no compliance audit
  responsibilities)

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Joint Compliance/EMS Audits Key Points (Cont.)

• EMS Lead Auditor needs to have full
  responsibility for conduct of the EMS portion of
  the audit (e.g., preparing EMS audit, briefing
  results, preparing report, etc.)
• Compliance auditors may provide site-specific
  feedback (e.g., training records, current
  plans/procedures, operational controls, etc.)

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Joint Compliance/EMS Audits Key Points (Cont.)

• If contractor EMS auditors are used, consider
  specifying that the auditors be RABQSA-certified
  (ensures level of competence)
• If contractor EMS auditors are used, consider
  Nondisclosure Agreements (prevents contractor
  from using DOI EMS practices in support of other
  clients)

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Joint Compliance/EMS Audits Key Points (Cont.)

• If EMS support contractors have assisted with the
  implementation of the EMS, do NOT use those
  same contractors to audit the EMS (avoids
  conflicts of interest)
• EMS support contractors can still be used to
  address audit findings (if needed), but they need
  to be independent of the audit

31
Evolution of Army EMS Auditing

• FY 85 91 Army Environmental Audit Program
  (multiple protocols, compliance medias only)
• FY 92 00 Army Environmental Compliance
  Assessment System (ECAS) Program standard
  protocol (TEAM Guide) Army Supplement to TEAM
  Guide (included Env. Program Mgt.)

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Evolution of Army EMS Auditing(Cont.)

• ECAS Env. Program Mgt. evaluations included
  several components of an EMS audit
• FY 01 Present Army EPAS Program Army
  Supplement to TEAM Guide revised to include EMS
  section (ISO 14001)
• Env. Program Mgt. assessors trained as EMS
  auditors

33
Army EMS Audits Lessons Learned

• Many contractor-prepared EMS manuals/procedures
  do not reflect installation business practices
• Some Army Commanders equate EMS nonconformance
  to regulatory noncompliance
• Some Army installations tend to regard EMS as a
  Program vs. a management system

34
Army EMS Audits Lessons Learned(Cont.)

• Command emphasis on EMS can vary with changes in
  installation leadership (integration of EMS with
  sustainability has worked well at some
  installations)
• Incorporation of tenants into host installation
  EMS can prove challenging.

35
Army EMS Auditor Training(Training External
Auditors)

• Army Environmental Command (AEC) hosts ISO 14001
  Lead Auditor Course (open to potential auditors
  funds attendance)
• EMS auditor trainees are assigned to participate
  in EMS audits (AEC funds travel) with experienced
  (e.g., USCCHPPM) EMS auditors until capable of
  serving as auditor

36
Army EMS Auditor Training(Training External
Auditors)

• Core Group of Experienced EMS Auditors Still
  Conduct the Majority of Army EMS Audits
• Expanding the Army Pool of Experienced Auditors
  is a Major Challenge (multi-year effort)
• EMS Auditor Pool MUST be Expanded (Core Group
  cannot support all Army EMS audits)

37
Army EMS Auditor Training(Training Internal
Auditors)

• General EMS internal auditor training (interview
  techniques, reviewing objective evidence,
  preparing findings, and practical exercise using
  generic manual)
• Installation-specific EMS internal auditor
  training (above basics of internal EMS audits
  practical exercise using installation manual)

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Questions

• Linda L. Baetz, EMS-LA
• [phone]
• linda.baetz_at_us.army.mil
• James D. Wood, P.E., EMS-LA
• [phone]
• jim.wood_at_us.army.mil