Gap Analysis Checklist

GAP ANALYSIS 1S0 14001 2011-2012

Prepared by Baiq Dian Zoelaeha

GAP ANALYSIS CHECKLIST

ISO 14001 SYSTEM REQUIREMENT CURRENT PRACTICE AND FINDING EMS

SATISFIED

(Yes/NO/Partl

y)

Recommendation

I.ENVIRONMENTAL MANAGEMENT SYSTEM (EMS)

General

4.1 1 Is there a documented EMS which conforms to the

requirements of the ISO 14001 Standard

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.

No The company should develop a

documented EMS in accordance with

ISO 14001 Standards requirements and

document existing environmental

practices

4.1 2 Is the EMS kept up to date Not applicable No The EMS should be kept up to date

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

4.1 3 Is the EMS sufficiently implemented Not Applicable

No The EMS should address all clauses and

sub clauses of ISO 14001 standard

4.1 4 Are other environmental commitments addressed within

EMS

Not Applicable No The EMS should address the company

environmental commitments

4.1 5 Does the scope of the EMS cover all the company

activities, products and services?

Not Applicable No The EMS should cover all activities,

product and services of the company

II. ENVIRONMENTAL POLICY

4.2 1 Has the company top management defined, endorsed

and signed the 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.

Yes Policy is needed to be socialized to all

employees, contractor and sub

contractor.

2 Is the companys policy consistent with the corporate

policy

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 The head company (Eramet) has

determined the environment principles

and the policy is in line with the Eramet

environmental principles.

GAP ANALYSIS 1S0 14001 2011-2012


4.2.a 3 Does the policy sufficiently describe the company

activities, product and service

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.

Yes Company commitment, activity

program, implementation plan,

monitoring plan and continuous

improvement process should be

imposed in the policy

4.2.a 4 Is the policy appropriate to the nature , scale and

environmental impact of its activities, products and /or

services

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

4.2.b 5 Does the policy include a commitment to continual

improvement of environmental performance

Yes

4.2.b 6 Does the policy include a commitment to pollution

prevention

Yes

4.2.d 7 Does the policy include a commitment to system

improvement

Yes

4.2.c 8 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 9 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.

GAP ANALYSIS 1S0 14001 2011-2012


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

No Internal audits should be incorporate in

the implementation of EMS, and if any

issues of improvement should

incorporate in the policy .

12 Has the policy been communicated to all (including

contractor and employees)

Not yet The

4.3 II. PLANNING ACTIVITIES

1.Environmental Aspects

4.3.1 1 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 2 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.

No

4.3.1 3 Is there a sound method to allocate significance 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 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.

4.3.1 4 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 The top management has to consider

significant environmental aspects in

setting objectives and targets. Each

objective and target should cross-

reference to relevant significant

GAP ANALYSIS 1S0 14001 2011-2012


4.3.1 5 If yes, is it implemented and updated? Not yet No

4.3.1.A 6 Has an Initial environmental Review been carried out The IER is in progress Partly, the IER

is being

conducted

The company should complete the IER

4.3.1.A 7 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.

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

No

4.3.1.A 8 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

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

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.

4.3.1.A 9 Consideration on situation such as:

abnormal

normal

accidents

emergency condition

Yes, in the environmental impact assessment methods.

There are several SOP created in managing the emergency

response to natural disaster and accident.

Not yet

existed fully

When making identification of aspect

and impact, it should look the

significance in the different situation.

1 II. PLANNING ACTIVITIES

2. Legal and other requirements

4.3.2 2 Is there a method to identify and have access to:

legal and regulatory requirement

(permits/consents)

other requirements

Yes, legal and regulation are listed according to the

intended compliance.

Yes, partly

GAP ANALYSIS 1S0 14001 2011-2012


4.3.2 3 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

4 How are these requirement kept up to date Not applicable No

5 Have they related the requirements to their activities,

products and services

Not applicable No

II.PLANNING ACTIVITIES

3. Objectives and targets, and programs

4.3.3 1 Is there a method to establish Objectives and targets Not yet No The company in general or the

environment project team need to

establish the objective and target of the

environmental management system

4.3.3 2 Are these objectives and targets set on a company wide

basis

Not applicable No 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 3 Are these objectives and targets set at each relevant

function and level within the company

Not applicable No

4.3.3 4 Do the objectives and targets consider:

Significant aspects

The legal requirements

Other EMS requirements

Views of interested parties

Financial, operational and business goals

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.

4.3.3 5 Are the objectives and targets consistent with the

environmental policy, including a commitment to

prevention of pollution

Not applicable Objectives and target should consistent

with the policy and reflect the spirit of

the environment policy.

4.3.3 A 6 Are objectives specific Not applicable

Objectives and targets should be

SMART, specific, measurable,

achievable, realistic, timely.

GAP ANALYSIS 1S0 14001 2011-2012


Are the targets measurable where practicable No

7 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 1 II. PLANNING ACTIVITIES

4. Environmental management programme

4.3.4.b 2 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.

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

4.3.4.A 3 Does the program define the means (detailed program

steps) and time frame by which objectives and targets

are to be achieved

Not clearly defined Partly Same as above

4.3.4.A 4 Has responsibility for achieving Objectives and Targets

been designated at each relevant function & level in the

company

Not clearly defined NO The environmental management

program should assign responsibilities

fro achieving the objectives and targets.

4.3.4.A 5 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?

Not clearly defined No 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

4.3.4.A 6 Does the programme for current and new activities,

products and services consider the following stages?

Planning

Design

Production

Marketing

disposal

The company should consider these

stage in establishing the environmental

management program

4.3.4.A 7 Does the programme for products consider the following

stages?

Design

Materials

No Not It is recommending to consider these

stage

GAP ANALYSIS 1S0 14001 2011-2012


Production

Processes

use and disposed

4.3.4.A 8 Does the programme for installation or significant

process modifications address the following stages?

Planning

Design

Construction

Commissioning

Operation

decommissioning

no no

III. IMPLEMENTATION AND

OPERATIONAL ISSUES

1. Structure and responsibilities

4.4.1 1 Have roles, responsibilities and authorities for

effective environmental management been:

Defined?

Documented?

Communicated?

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.

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

4.4.1 2 Has the management provided the following resources

for EMS implementation and control?

human resources

specialized skills

technology

financial resources

The team will assembled from existing human resources

available within the environmental department and

possible representative from each department. The team

member should have

Partly The company should establish a

procedure to ensure all these resources

are sufficient, and utilized and managed

in systematic and effective way.

4.4.1.a.b 3

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?

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.

4.4.1.A 5 Have environmental responsibilities been defined in

departments other than just the environmental

department?

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 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.

GAP ANALYSIS 1S0 14001 2011-2012


4.4.1.A 6 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

III. IMPLEMENTATION AND OPERATION

ISSUES

2. Training, Awareness and Competence

4.4.2 1 Has the company identified training needs 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

Yes/partly Methodology used is bottom up,

employee give detailed training they

need and HR process and funded.

4.4.2 2 Has the company appropriately trained those personnel

whose work may have a significant impact on the

environment?

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.

Yes/partly 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.

4.4.2 3 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?

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 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.

4.4.2 4 Are those who perform tasks that can cause significant

impacts competent to do so, based on appropriate

education, training and/or experience?

The information on other department condition is not

available right now since the IER is only focus to the

environment department

No

Information

The implementation of EMS should

cover process, product and services of

the company, and other department

also shall take part in this process.

4.4.2 5 Has the company determined whether contractors The company currently working with several contractors to Partly The company can start to be selective

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.


OPERATIONAL ISSUES

3. Communications

4.4.3.a 1 Does the company have a method for internal

communications about its significant aspects and EMS,

between the various levels and functions?

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/partly Communication method should be

documented as for internal

communications as well as record all

correspondences

4.4.3.a 2 Does the company have a method for receiving,

documenting and responding to relevant communication

from external interested parties about its significant

aspects and EMS

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

Yes/partly As part of document control, all

communication or document need to

be recorded.

4.4.3.a 3 Has the company decided whether to communicate its

significant aspects externally?

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

Yes/partly To communicate the significant

environmental aspect, the company

should establish a procedure to explain

the method.

4.4.3.a 4 Has there been any dialogue with external interested

parties, other than the regulators?

In regard of environmental performance, the environment

department maintain dialogue with other department,

while externally, environment department maintain

dialogue with government and stakeholders.

Yes/partly

4.4.3.a 5 Has there been any dialogue with public authorities

regarding emergency planning and other relevant issues?

The company keeps correspondences to public authorities

such as village head, bupati.

Yes/partly


OPERATIONAL ISSUES

4/5. EMS Documentation and Document Control

4.4.4.a 1 Is there information in paper or electronic form to

describe the core elements of the management system

and their interactions?

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

electronic form

No EMS shall be documented both in paper

and electronic.

GAP ANALYSIS 1S0 14001 2011-2012


4.4.4.a 2 Does this information provide direction to relevant

documentation?

Not applicable No EMS documentation system should

provide direction to relevant

documentation

4.4.5 3 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?

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 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 4 Is the documentation:

legible?

dated (with dates of revision)?

readily identifiable?

maintained in an orderly manner?

retained for a specific time?

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.

4.4.5 5 Is there a method detailing who is responsible for

creation and modification of the various types of

documentation?

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 The responsibility for document

creation and modification should be

defined.


OPERATIONAL ISSUES

6. Operational Control

4.4.6 1 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?

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

Partly EMS required documented, accessible

and implemented standard operation

procedures and control which based on

the identified environmental aspect and

impacts

2 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, 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 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. .

GAP ANALYSIS 1S0 14001 2011-2012


the identifiable significant environmental aspects of

goods and services used by the company and

communicating relevant procedures and

requirements to suppliers and contractors?


OPERATIONAL ISSUES

7. Emergency Preparedness and Response

4.4.7 1 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 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.

2 Has the company reviewed and revised, where

necessary, its emergency preparedness and response

procedures, in particular, after the occurrence of

accidents or emergency situations?

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.

Yes 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

3 Has the company periodically tested such procedures

where practicable?

The company test the emergencies system such as during

fire, riots and evacuation

Yes All these procedures should be

periodically tested where practicable

IV. CHECKING AND CORRECTIVE ACTION

1. Monitoring and Measurement

1 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

GAP ANALYSIS 1S0 14001 2011-2012


periodically evaluate compliance with

relevant environmental regulation and

legislations

2 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 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 Do they calibrate and maintain monitoring equipment? The calibration of equipment is done regularly, in particular

for baseline environmental management.

Yes

4 Do they retain records of this process according to their

procedures?

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

Yes

5 Has the company established and maintained a

documented procedure for periodically evaluating,

compliance with relevant environmental legislation and

regulations?

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.

Partly The company should establish and

maintain a documented procedure for

periodically evaluating compliance with

relevant environmental legislation and

regulations.


2. Non-conformance and Corrective and Preventive

Action

4.5.2 1 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.

2 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

GAP ANALYSIS 1S0 14001 2011-2012


3 Has the company implemented and recorded any

changes in the documented procedures resulting from

corrective and preventive action?

The department usually record the action in the

environmental inspection and corrective actions logbooks

Yes

4.5.2.A 4 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?

Yes, as shown in the environmental inspection and

monitoring report, identification of cause of non

conformance, actions required and review are undertaken.

Yes EMS required all these basic elements

to be consider while establishing and

maintaining procedures for

investigating and correcting non

conformance


3. Records

4.5.3 1 Has the company established and maintained methods

for the identification, maintenance and disposition of

environmental records?

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.

Yes EMS require establishment of

procedure for identification,

maintenance and disposition of

environmental records.

4.5.3 2 Do these records include

training records?

results of audits?

results of reviews?

Training records biweekly meeting and weekly meeting

reports are store in the share point and maintain the

updating regularly.

Yes EMS require the organization to identify

and keep all records that arise from the

implementation of the EMS

4.5.3 3 Are these environmental records:

Legible?

Identifiable?

traceable to the activity, product or service

Involved?

Yes, however the organization of the share point need to

be controlled by assigned employee

Yes Documents and procedures should

provide direction to relevant

environmental records which should be

dated., with title shown on the first

page.

4.5.3 4 Are the environmental records stored and maintained in

such a way that they are readily retrievable and

protected against damage, deterioration or loss?

Environmental record are stored in the softcopy and

hardcopy forms, each supervisor know the system

Yes The department should state the

responsibility of keeping environmental

records on EMS documents and

procedures.

4.5.3 5 Are retention times established and recorded? Every document is dated, however there is no information

on the retention time fro the document to be kept

NA The department should record the

retention times of environmental

records on EMS documents and

procedures

4.5.3 6 Are these records sufficiently maintained, as appropriate

to the system and to the company, to demonstrate

conformance to the requirements of ISO 14001

Standard?

Partly, systematic record on the implementation of EMS

procedures in order to conform to the requirements of ISO

14001 Standard are absen

No Record from implementation of EMS

should be identified and kept.

4.5.3 Do methods for identification, maintenance and

disposition of records focus on those records needed for

No formal method for identification, maintenance and

disposition of environmental records

No

GAP ANALYSIS 1S0 14001 2011-2012


the implementation and operation of the environmental

management system?

4.5.3.A 7 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

Partly The department should define the

responsibility in environmental

management program for recording the

progress towards achieving the

c=objectives and targets

8 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.

The department keeps records except:

Pertinent contractor and supplier information

Record on significant environmental aspects

Audit results

Management reviews

Partly


4. EMS Internal Audits

4.5.4 1 Has the company established and maintained (a)

programme(s) and methods for periodic Environmental

management system audits?

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

No The department should establish and

maintain a procedures for defining a

program for periodic EMS audits

4.5.4 2 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?

Not applicable No 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.

4.5.4 3 Have they provided information on the results of audits

to management?

Not Applicable EMS audits results are discussed in

management review meeting

4.5.4 4 Is the programme based on the :

environmental importance of the activity

Not applicable No The company should consider all these

in establishing EMS audit program

GAP ANALYSIS 1S0 14001 2011-2012


concerned?

results of previous audits?

4.5.4.A 5 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?

Not applicable NO Audit procedures should cover these

elements

6 Was the audit carried out

impartially?

objectively?

Not applicable No The company should arrange EMS

auditors properly to ensure audit are

performed impartially and objectively

V. MANAGEMENT REVIEW

4.6 1 Has the companys top management, at intervals it has

determined, reviewed the environmental

management system, to ensure its continuing :

suitability?

adequacy?

effectiveness?

The company top management have formal meeting for

review of general performance but not for EMS. Meeting

minute are kept

No 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

4.6 2 Does the management review process ensure that the

necessary information is collected to allow management

to carry out this evaluation?

Not applicable No EMS required a procedures to ensure

that necessary information is collected

to allow management to carry out the

review

4.6 &

A.4.6

3 Has the review (observations, conclusions and

recommendations) been recorded/documented for

necessary action?

Not applicable No EMS required procedures to ensure to

ensure that the results of management

review are documented

4 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?

Not applicable A procedure to ensure that all these

elements are considered in the

management review process

5 Was the review of the policy, objectives and procedures

carried out by the level of management that defined

Not applicable No The management review should be

attended by top management, in

GAP ANALYSIS 1S0 14001 2011-2012


them? particular the environmental general

manager and managers.

Gap Analysis Checklist

Documents

Transcript of Gap Analysis Checklist