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Initial Environmental Review
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What exactly is an Initial Environmental
Review?
It provides a snapshot of a companys
performance at a particular point in time.
It highlights a companys environmental impacts
allowing action to be taken where it is mostrequired.
The purpose is to find and evaluate as many
areas as possible in which the company canimprove its environmental performance.
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Approach and methods:
Process maps outlines the process
requirements (i.e. resources) and the outputs
including wastes, emissions and by-products
that serve as a baseline for identifyingenvironmental aspects.
Inputs: rawmaterials;energy,
resources
PROCESS
Outputs:emissions;
by-products;wastes
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Process Map:
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Process Map:
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Assessment of SignificantAspects
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6 Criteria for Assessment of Significance
Legislative / regulatory obligation
Risk to the Environment
Occurrence of incidents
Actual and potential nuisance/harm
International and/or resource usage /
resource management issues Lack of information or data to make
satisfactory appraisal
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Examples of aspects and impacts
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Steps in evaluating environmental aspects
EVALUATE THE SIGNIFICANCE OF THE IMPACTS
IDENTIFY THE ENVIRONMENTAL IMPACTS
IDENTIFY THE ENVIRONMENTAL ASPECT
SELECT AN ACTIVITY, PRODUCT OR SERVICE
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Criteria for significance evaluation
3 Evaluation criteria
Criteria allocated points
Severity (S) 10
Occurrence (O) 10
Detection (D) 10
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Criteria for significance evaluation
Significance evaluation rating system:
ERPN = S x O x D
Total maximum score = 1000
ERPN Environmental Risk Priority Number
used to rank order environmental aspects
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Definition
Severity
Is an assessment of the seriousness of the effect (environmental
impact) to the cause (environmental aspect) to the environment.
Occurrence
How frequently the specific environmental aspect is projected to
occur (the occurrence number has a meaning rather than a value)
DetectionIs an assessment of the probability that the existing operational
control(s) or monitoring and measurement(s) will detect
environmental aspect performance weakness, deterioration or
degradation.
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Severity (S) criteria
S = S1 + S2 + + S6
S1:RESOURCE USAGE (2.0 PTS)
0.2 VERY MINIMAL USAGE, NEGLIGIBLE IN IMPACT
0.4 WITH RESOURCE USAGE, 50 % OR MORE IS RECYCLED OR RE-
USED WITH REDUCTION PROGRAMS
0.8 WITH RESOURCE USAGE REDUCTION PROGRAMS IMPLEMENTED
1.2 RESOURCE USAGE WITH SOME CONTROLS BUT IS NOT DIRECTED
TOWARDS CONSERVATION
1.6 RESOURCE USAGE WITH NO CONSERVATION
2.0 EXTRAVAGANT USAGE OF RESOURCES, NO CONSERVATION OR
CARE
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Severity (S) criteria
S = S1 + S2 + + S6
S2 HEALTH AND SAFETY ( 2.0 PTS)
0.0 NO CONCERN
0.5 RESULT TO IRRITATION / MINOR INJURY
1.0 RESULTS TO INJURY OR ILLNESS
1.5 SHORT TERM ACCUTE HAZARDS SUCH AS ACCUTE TOXICITY BY INGESTION,INHALATION OR SKIN ABSORPTION, CORROSIVITY OR OTHER SKIN OR EYE CONTACT
HAZARDS OR RISK OF FIRE EXPOSURE OR EXPLOSION. USUALLY CONFINED IN THE
HOSPITAL
2.0 LONG TERM HAZARDS, INCLUDING CHRONIC TOXICITY UPON REPEATED EXPOSURE.
CARCINOGENIC IN SOME CASES RESULTING FROM ACCUTE EXPOSURE. FATAL
S3 AIR POLLUTION (1.5 PTS)0 NO EMISSION
0.5 CONTROLLABLE EMISSIONS WITH KNOWN NON-POLLUTING SUBSTANCES
1.0 UNCONTROLLED EMISSIONS WITH KNOWN POTENTIAL POLLUTING SUBSTANCES LIKE
OZONE DEPLETING SUBSTANCES (ODS), CO2, NOX, SOX, LEAD, ACID FUMES. ETC,.
1.5 EMISSIONS AFFECTING STAKEHOLDERS OR OTHER INTERESTED PARTIES.
MAINFESTED BY INTERNAL OR EXTERNAL COMPLAINTS
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Severity (S) criteria
S = S1 + S2 + + S6
S4:WATER POLLUTION (1.5 PTS.)
0 NO CONCERN
0.5 CONTROLLED DISCHARGE WITH KNOWN NON-POLLUTIVESUBSTANCE
1.0 UNCONTROLLED DISCHARGES WITH KNOWN POLLUTIVE SUBSTANCES1.5 DISCHARGES CAUSING COMPLAINTS FROM INTERESTED PARTIES LIKE
NEIGHBORHOOD, REGULATORY AGENCIES, ETC.,
S5:GROUND, SOIL/LAND CONTAMINATION (1.5 PTS.)
0 NO DISCHARGES, EFFLUENT OR EMISSION
0.5 WITH DISCHARGES OR EFFUENT WITH KNOWN NON-POLLUTIVE SUBSTANCES
1.0 WITH DISCHARGES OR EFFLUENT WITH KNOWN POLLUTIVE SUBSTANCE BUT
CONTROL IS IN PLACE.
1.5 NO MONITORING OF SOIL CONTAMINATION, WITH COMPLAINTS OR EVIDENCE OF
DETERIORATION AS SEEN VISUALLY. NO CONTROLS IN PLACE.
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Severity (S) criteria
S = S1 + S2 + + S6
S6:NUISSANCE, DISTURBANCE OR AESTHETIC EFFECT (1.5 PTS)
0 NO CONCERN
0.5 TOLERABLE LEVEL, NO INTERFERENCE, NORMAL WORK FLOW1.0 RESULTING TO WORK INTERFERENCE OR OCCASIONAL WORK STOPPAGE
WHICH MAY AFFECT THE OVERALL EFFICIENCY
1.5 CAUSING WORK STOPPAGES DUE TO NOISE, DISTURBANCE OR
UNTOLERABLE AESTHETIC EFFECT
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Occurrence (O) Criteria
RANKING PROBABILITY OF THE ASPECT TO OCCUR POINTS
VERY HIGH INCIDENT OR ACTIVITY HAPPENS DAILY AS PART OF THE PROCESS 10
OR COMPANY ACTIVITIES
INCIDENT OR ACTIVITY HAPPENS AT LEAST 3 TIME A WEEK, AS PART 9
OF AN ACTIVITY THAT IS NOT REGULR IN NATURE BUT OCCURS
DURING THE WEEK.
INCIDENT OR ACTIVITY HAPPENS AT LEAST 1X PER WEEK, AS THE 8
INSPECTION IS REGULARLY DONE ON A WEEKLY BASIS.
INCIDENT OR ACTIVITY HAPPENS AT MOST 2 X A MONTH DUE TO AN 7
ACTIVITY THAT IS PLANNED OR SCHEDULED
MODERATE INCIDENT OR ACTIVITY RE-OCCUR MONTHLY DUE TO ABNORMAL 6
CONDITIONS OR AS A RESULT OF REGULAR CHECKS
INCIDENT OR ACTIVITY RE-OCCUR QUARTERLY 5
INCIDENT OR ACTIVITY RE-OCCUR SEMI-ANNUALLY 4
INCIDENT OR ACTIVITY RE-OCCUR ANNUALLY 3
REMOTE OCCURS WHEN NATURAL DISASTER STRIKES OR ACCIDENT 2
OR USE IS DETERMINED PER FREQUENCY OF DISASTER OR
ACCIDENT OF ANY KIND.
OCCURS ON SOME BUT NOT ALL DISASTERS OR ACCIDENT OF 1
ANY KIND.
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Detection (D) criteria
RANKING PROBABILITY OF THE ASPECT TO OCCUR POINTS
ALMOST NO KNOWN CONTROLS TO DETECT THE INCIDENT OR THE ABNORMAL 9 - 10
IMPOSSIBLE USE DUE TO THE UNCONTROLLED OCCURRENCE OF THE ASPECT
REMOTE SOME CONTROLS IMPLEMENTED. CONTROLS NOT DEFINED IN 7 - 8
PROCEDURES BUT IS MONITIRED OR CHECKED IRREGULARLYLOW MONITIRED REGULARLY BUT FREQUENCY MAY NOT BE ADEQUATE
5 6
TO DETECT THE INCIDENT OR ACCORRENCE DEFINED IN
PROCEDURES.
HIGH REGULAR MONITORS DONE. CONTROLS ARE DEFINED IN PROCEDURES 3 4
IMPLEMENTED AND MAINTAINED
ALMOST CURRENT CONTROLS ALMOST CERTAIN TO DETECT THE INCIDENT 1 - 2
CERTAIN OR OCCURRENCE OF AN ASPECT. AUTOMATIC CONTROLS OR A
DESIGNATED PERSONNEL TO MONITOR OR INSPECT THE CONTROLS
IS DESIGNATED
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4.3.2 Legal and other requirements
Establish, implement and maintain a
procedure to:
a. identify and have access to the applicable legal
requirements and other requirements to whichthe organization subscribes
b. determine how these requirements apply to itsenvironmental aspects
C t i f i t l l l
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Categories of environmental legal
requirements
Air Quality Management
Control of Toxic Substances and Hazardous Wastes
Environmental Impact Assessment
General Environment Solid Waste Management
Water Quality Management
Other requirements may include
Customer requirements (e.g. RoHS)
Requirements of trade associations
Commitment to parent organizations
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4.3.3 Objectives, targets and programme(s)
Definitions
Environmental objectives
Overall environmental goal, consistent with the environmental
policy that an organization sets itself to achieve.
Environmental target
Detailed performance requirement, applicable to the organization
or parts thereof, that arises from the environmental objectives andthat needs to be set and met in order to achieve those objectives.
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4.3.3 Objectives, targets and programme(s)
Establish, implement and maintain documented environmentalobjectives and targets at relevant function and level within the
organization.
In setting objectives, consider:
Legal and other requirements Significant environmental aspects
Technological options
Financial, operational and business requirements
Views of interested parties
Consistent with the policy including commitment to the preventionof pollution.
Commitments to continual improvement
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4.3.3 Objectives, targets and programme(s)
Establish, implement and maintain a programme(s) for
achieving its objectives and targets.
Programme(s) should include
a. Designation of responsibility for achieving and targets
at relevant functions and levels of the organization
b. Means and time-frame by which they are to be
achieved.
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ENVIRONMENTAL
POLICY
COMMITMENTS
OBJECTIVE 1 OBJECTIVE 2 OBJECTIVE 3
TARGET 1 TARGET 2 TARGET 3
ENVIRONMENTAL ASPECTS AND IMPACTS
LEGAL AND OTHER REQUIREMENTS
INTERESTED PARTIES
Policy commitmentReduce waste from operations
OBJECTIVE 1
Reduce the waste generated
By the organization in 3 years
Target 1
Reduce the total waste
Generated by 50% in 3 years
Target 2
Reduce the packaging waste
By 40 % in 2 years
Target 3
Reduce liquid waste by 30%
In 2 years
Objectives/targets-
Quantified what and when
Programmes
Who, what, when, how,
Resources, knowledge
proogrammes
4.3.3 Objectives, targets and programme(s)
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4.4 Implementation and operation
4.4.1 Resources, roles, responsibility and authority
Define, document and communicate roles, responsibilities and
authorities in order for facilitate effective environmental
management. Provide resources essential to the implementation and control of
EMS.
Appoint (a) specific management representative (s) with defined
role, responsibility and authority for:a. Ensuring that the EMS is established, implemented and maintained.
b. Reporting on performance of EMS to top management for review
and as basis for improvement.
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4.4 Implementation and operation
4.4.2 Competence, training, awareness
Personnel performing tasks which cause significant
impacts shall be competent
Identify training needs
All personnel whose work significant impact receive
appropriate training or take other action
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4.4 Implementation and operation
4.4.2 Competence, training, awareness
Establish, implement and maintain procedure to make persons
aware of
a. Importance of conformity with the EMS
b. Significant environmental aspects and related actual or potential impacts
associated w/ their work
c. Environmental benefits of improved personal performance
d. Roles and responsibilities in achieving conformity
e. Potential consequences of departure from specified procedure
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4.4 Implementation and operation
4.4.3 Communication
Establish, implement and maintain a procedure(s) for
a. internal communication among the various levels and
functions of the organization,b. receiving, documenting and responding to relevant
communication from external interested parties.
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4.4 Implementation and operation
4.4.4 Documentation
a. Environmental policy, objectives and targets
b. Scope of the EMS
c. Description of the main elements of the EMS and theirinteraction and reference to related documents
d. Docs, including records, required by this standard
e. Docs, including records, determined by the organization to be
necessary to ensure the effective planning, operation andcontrol of processes related to significant environmental
impacts.
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4.4 Implementation and operation
4.4.5 Document Control
a. Approve documents for adequacy prior to issue
b. Review and update as necessary and re-approve documents
c. Ensure that changes and the current revision status ofdocuments are identified
d. Ensure that relevant versions of applicable documents are
available at point of use
e. Ensure that documents remain legible and readily identifiablef. External documents are identified and their distribution
controlled (e.g. MSDS)
g. Prevent unintended use of obsolete documents and apply
identification if retained
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4.4 Implementation and operation
4.4.6 Operational Control
a. Establish, implement and maintain documented
procedure(s) to control situations
b. Stipulating the operating criteria in the procedure
c. Establish, implement and maintain procedures related
to significant environmental aspects and communicate
requirements to suppliers
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4.4 Implementation and operation
4.4.7 Emergency Preparedness and Response
a. establish, implement and maintain procedures to identify
potential emergency situations and potential accidents
b. respond to these situations and prevent or mitigateassociated adverse environmental impacts
c. shall periodically review, where necessary, revise procedure
after the occurrence of accidents or emergency situations
d. Shall periodically test such procedures where practicable
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4.5 Checking
4.5.1 Monitoring and Measurement
monitor and measure the key characteristics of its operations
that can have significant environmental impact
include the documenting of information to monitorperformance, applicable controls and conformity with the
organizations objectives and targets
ensure calibrated or verified monitoring and measurement
equipment is used and maintained
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4.5 Checking
4.5.2 Evaluation of Compliance
Establish, implement, and maintain a procedure for
periodically evaluating compliance with applicable
legal requirements.
Shall evaluate compliance with other requirements to
which it subscribes
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4.5 Checking
4.5.3 Nonconformity, corrective action and preventive action
Establish, implement, and maintain a procedure for dealing with
actual and potential nonconformity and for taking corrective and
preventive action.Procedural requirements:
a. Identifying and correcting nonconformities and taking actions to mitigate
their environmental impacts.
b. Cause analysis and taking action in order to avoid their recurrence
c. Evaluating the need for action to prevent nonconformities and implementingappropriate action to avoid their occurrence
d. Recording results of CAPA
e. Reviewing effectiveness of actions taken.
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4.5 Checking
4.5.4 Control of Records
Establish, implement and maintain a procedure for
a. Identification
b. Storage
c. Protection
d. Retrieval
e. Retention
f. Disposal of records
Records shall remain legible, identifiable and traceable.
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4.5 Checking
4.5.5 Internal Audit
Establish programme(s) for periodic EMS audits to be carried out to:
a. Determine if the EMS conforms to planned arrangement and has
been properly implemented and maintained.b. Provide information on the results of audits to management.
Frequency based on importance of activity concerned and results of
previous audits
Procedures covers scope, frequency, methodology , as well as
responsibilities and requirements for conducting and reporting results. Audit system shall ensure objectivity and the impartiality of the audit
process
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4.5 Checking
4.5.6 Management Review Review the EMS to ensure continued suitability, adequacy and
effectiveness.
Assessing opportunities for improvement
Inputs to management review:
a. Internal audit results
b. Evaluation of compliance to legal and other requirements
c. Communication from external interested parties, including complaints
d. Environmental performance
e. Extent to which objectives and targets have been met
f. Status of CAPA
g. Follow-up action from previous management review
h. Changing circumstances
i. Recommendations for improvement
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4.5 Checking
4.5.6 Management Review
Outputs to management review:
Decisions and actions related to possible changes to:
Policy
Objectives
Targets
Other elements of the EMS (continual improvement)
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