I wish you all a happy New Year 2011. Let this new year bring you all the best in life - health, wealth and happiness.
On 3 and 4 January 2011 we discussed various elements of ISO 14001: Environmental Management System. We agreed that we will spend more time on one management system in the class; the rest are similar in approach and so can be understood by reading the respective document. Here is the summary of what we learnt:
ISO-14001 Standard: Environmetal Management Systems - Requirements with Guidance for use was first published in 1996 and was revised in 2004. About 130000 organizations all over the world have got themselves certified to ISO-14001 standard by 2008. Japan leads the number of ISO-14001 certifications, followed by China. Both depend on international trade for growing/maintaining their economies. ISO-14001 provides a shield against the use of environmental issues as non-tariff trade barriers by western and other developed countries.
We started with the structure of ISO-14001 (2004) Standard - PDCA - Plan -Do -Check-Act.
There are Four sections in ISO-14001 Standard; the operative part is Section 4.
Before establishing an environmental management system, an organization may carry out an initial review of its environmental issues, procedures, practices, legal requirements and past practices/accidents etc.
4.1 is about the commitment of the organization to establish an environmental management system
4.2 is about the Environmental Policy. The Environmental Policy has to be issued by the TOP MANAGEMENT. The following are the requirement of the environmental policy:
a. It should be appropriate to the nature, scale and environmental impacts of the organization
b. It should commit the organization to compliance with applicable legal and other requirements
c. It should commit the organization to continual improvement and prevention of pollution
d. It should be available to the public
We discussed the meaning of CONTINUAL improvement; i.e. improvement that takes place in one or more areas of the organization, resulting in the overall system improvement. Improvements need not take place in all the areas at the same time or all the time; but some of the areas need to show improvement. These are determined by the resources available to the organization.
We also discussed the meaning of PREVENTION of POLLUTION; according to this standard prevention of pollution need not be complete elimination of the pollutant; it can be a reduction of the pollution.
The meaning of "PUBLICLY AVAILABLE"is that the policy is not a confidential document and hence should be available to any stakeholder who has an interest in the policy.
I showed you a simple Environmental Policy and we checked if all the above elements were present in the displayed policy.
Planning is the First phase of the PDCA Cycle; we discussed the quotatiion: "IF YOU FAIL TO PLAN, YOU PLAN TO FAIL"
4.3 PLanning
4.3.1. Identifying and Assessment of Significant Aspects.
AN ASPECT is an element of the activity, product or service, that can have an impact on the environment. AN IMPACT is the change in the environmental condition, positive or negative.
We discussed the input-output model using the example of an activity like coffee making. The inputs are e.g. Milk, Coffee powder, Sugar, water, LPG Gas, cups, mugs etc. The desirable output is Coffee. There are quite a few un-desirable outputs, e.g. waste heat, waste water, packaging materials etc. These undesirable outputs can have an impact on the environment (hence can be classified as ASPECTS). These aspects for ALL the activities, products and services of the organization have to be identified and recorded. In one way of assessing these aspects, the following criteria are used to assess significance: a) the probability of occurrence, b) the frequency of occurrence, c) the probability of the impact on property, people, flora/fauna and the environment outside the organization and d) the long term effect of the impact. To this one can also add the relevance of the aspect to any legislative requirement. We discussed as to how the significance will vary based on the "size" of the activity, product or service (e.g. emission of alcohol in a bottle and that in a 15 tons tanker). We also discussed that we have to identify DIRECT & INDIRECT impacts (e.g. of indirect impact, electrical energy used in the activity is related to emission of carbon dioxide at the thermal power station, leading to global warming), POSITIVE and NEGATIVE impacts, impacts due to START-UP, SHUT DOWN, ACCIDENTS etc. We also discussed that we need to capture ALL these impacts in the PAST, PRESENT and FUTURE, before assessing the ASPECT. We discussed as to how to use the assessment score to prioritize the aspects as significant as well as to ensure continual improvement. One of the requirements, which is not explicit in the ISO-14001 standard, is to RECORD all the Aspects and Impacts identified, including the significant aspects.
The next step (which can be started concurrently with the initial review) is to identify applicable legal and other requirements.
4.3.2. Legal and other requirements. The organization should establish a procedure to identify and access legal and other requirements.
Legal requirements may be local (e.g. Air (Prevention and Control of Pollution) Act, Water (Prevention & Control of Pollution) Act, Consent for operations under the Air and Water Acts, Authorization under the Hazardous Waste (Management & Handling) Rules, etc.), Country / Region specific (especially if the organization exports to these countries, e.g. RoHS, WEEE, REACH etc.), or Global (where international protocols warrant action, e.g. Montreal Protocol, BASEL Convention etc.). Other requirements include company specific standards, guidelines, policies or industry specific requirements like "Responsible Care" of the Chemical Industry, "Electronics Industry Code of Conduct" of the electronics industry etc. It is a good practice to have a register of legal and other requirements and update it periodically.
The standard requires that the organization identifies as to how these legal and other requirements are related to the environmental aspects of the activities, products and services of the organization.
4.3.3. Objectives, Targets & Programmes
Once the organization identifies its significant environmental aspects and applicable legal and other requirements, it has to set its objecitves based on the overall intent provided by the Environmental Policy. Objetive is a goal to be achived by a particular time - say, for example, "to reduce energy consumption by 50 % by the year 2010". Target is specific measureable sub-goal, with well defined measurement index. Targets are normally SMART: S = Specific, M=Measureable, A=Achievable, R= Reasonable and T = Timebound. e.g. To reduce energy consumed per product (MJ/Piece) by 20 % by 2009. The Environmental Management Programme is an elaboration of how to achieve the target and goals, with specific responsibility, milestones for various activities, resources required, monitoring methods and review mechanism etc. Objectives on specific significant environmental aspects is one way of addressing significant environmental aspects, so that their impact is reduced once the programme is successfully completed.
The identified significant aspects have to be addressed by one or more of the following: (a) setting objectives, targets, and programmes, (b) training (e.g. training operators as to how to transfer liquid chemicals from one container to the other without spilling and with secondary containers, to avoid soil pollution and consequent water/air pollution. We discussed the Bhopal case, if only the operator had been trained to understand the effect of water on methyl isocyanate, he would have avoided the leakage of water into the MIC tank), (c) communication (e.g. by communicating to people inside and outside the company as to what to do in case of a leakage of a toxic gas, the extent and intensity of any gas leak accident can be reduced - we discussed the Bhopal case - if only people had been communicated that they should close their nose with a wet handkerchief, many lives could have been saved. If only the Plant Director was communicated the minor leak of MIC when it just happened he could have intervened to control the situation - in Bhopal case he was informed more than four hours after the accident, (d) Operational Control Procedures - procedures, with operational criteria, that address identified significant environmental aspects so that the activities related to these aspects are carried out under controlled conditions. (e.g. we discussed that if such a procedure were in place in Bhopal the accident could have been avoided; the operational criteria in the case could be limit for pressure or temperature) and (e) emergency and/or accident response procedure (e.g. We discussed (even though not an environmental emergency) about the procedure to be followed in case of fire at a lower storey in Indsearch. In Bhopal if the company had an emergency procedure, we could have avoided the large number of fatalities. We also discussed the Sandoz case - a typical example of the consequences of emergency response. In the case of the fire in the SANDOZ warehouse in Switzerland, the fire was brought under control by spraying large quantities of water; but the water mixed with burnt and unburnt toxic substances reached the RHINE river, making it unusable for a few years. We discussed that the emergency procedure, therefore, should consider the consequences of that procedure too. Another issue we discussed was that the emergency procedure has to be periodically checked through mock-drills to identify and fill gaps in the preparedness). We also discussed about how these five methods could be applied to vehicular emission in Pune if the PMC identified the vehicular pollution as a significant environmental aspect.
In the next part of the lecture, we discussed the sub-sections under 4.4 - Implementation (DO). This section has seven sub-sections, viz., 4.4.1 - Resources, Roles, Responsibilities and Authority, 4.4.2 - Competence, training and awareness, 4.4.3 - Communication, 4.4.4 - Documentation, 4.4.5 - Control of documents, 4.4.6 - Operational Control and 4.4.7 - Emergency Preparedness and Response.
4.4.1 - Resources are to be provided by the management for establishing, implementing and maintaining the Environmental Management System - these resources are human resources, financial resources, infrastructure and information. The top management has to appoint a Management Representative to establish, implement and maintain an Environmental Management System and to report to the management periodically about the effectiveness of the system. Role is the part played by employees apart from the functions for which they are responsible or results for which they are accountable to. An employee, for example an Accounts Officer, may take the role of an internal auditor or a trainer even though his main responsibility is in Accounting. ( We discussed the ROLE played by individual in real life - a man is a husband to his wife, is a brother to his sister or brother, is a son to his parents, is a friend to his friends etc. These are various roles he plays in his life). In order to ensure that the system is effective the management should document the responsibilities and authority (to take actions, decisions etc.) and make it known to all concerned employees.
4.4.2 - Competence of employees who are responsible for activities related to identified significant aspects need to be ensured; competence is related to qualification, training and experience. ALL employees have to be trained to understand the policy, procedures and other relevant elements of the EMS. ALL is the key word here. We discussed the case of a CEO who had not been trained in the emergency procedure and response; how would he come to know about the emergency and save his life in case of an actual emergency ?
4.4.3 - Communication is of two types, (a) internal communication with employees and contract workers working within the premises and (b) external communication with stakeholders outside the organization, like the Government Departments, Statutory bodies, NGOs, Banks, Neighbours etc. Procedure for both internal and external communication should be effective (e.g. the internal communication should ensure that the receipient of the communication has understood the content of the communication). The procedure for external communication should address the receipt and response to communication from external stakeholders. The organization should decide whether to communicate its significant environmental aspects to external stakeholders and record its decision. One method of external communication is the Global Reporting Initiative (GRI) guideline based Sustainability Reports.
4.4.4 - Documentation - Information with its supporting medium (paper, magnetic tape, CD, DVD etc.) is a document; Records are a sub-set of documents. Procedures, Policy, Objectives/targets/programmes etc., with the medium on which they are captured are documents. Information on the past activity, including measurements, reviews etc., are RECORDS. While documents, except RECORDS, could be changed, RECORDS cannot be changed/altered. Documents, including Records, are used as evidence of the working of the Environmental Management System. Environmental Management System Manual, capturing various elements of the EMS is one such document (ISO-14001 does not prescribe a written manual, but for better working of the system a written manual is recommended)
4.4.5 - Documents are controlled; that means that the documents are checked for their authenticity and are verified and approved by those authrorized to issue documents. This procedure is necessary to avoid obsolete documents being used in the organization. Current documents need to be available at the all places where related work is carried out. Control is also required for documents which have external origin (e.g. standards, legal documents etc). We discussed how a part of the organization was not meeting the requirement of law as they were using obsolete standards for emissions and how this could lead to risk to the organization.
4.4.6 - We already discussed issues related to operational control procedures that are established to address significant environmental aspects
4.4.7 - We already discussed issues related to emergency/accident procedures and the consequence of the procedure.
4.5. Once we plan and implement, the next step is to CHECK. There are Five sub-sections under Checking, viz., 4.5.1 - Monitoring and Measurement, 4.5.2 - Evaluating Compliance (4.5.2.1 - Evaluation of Legal Compliance and 4.5.2.2 - Evaluation of other compliance), 4.5.3 - Non-conformity, corrective action and preventive action, 4.5.4 - Control of Records and 4.5.5 - Internal Audits
4.5.1 All environmental management programmes have to be monitored; where required measurements have to be made on identified parameters. The equipments used for such measurements have to be calibrated and the calibration records have to be maintained
4.5.2 - Procedures have to be established and implemented to periodically evaluate compliance with legal requirements as well as with other requirements to which the organization subscribes. The results of these evaluation have to be documented. In case of non-conformance, corrective and preventive actions have to be in place.
4.5.3 - Once a non-conformance to any element of the system requirements is noticed, corrective and preventive actions have to be taken to eliminate or avoid the recurrence of the non-conformance. A corrective action is the removal of the cause of non-conformance identified so that the non-conformance does not recur. The preventive actions is the change effected to the system to avoid the potential non-conformance. Preventive action is, therefore, a proactive action.
4.5.4 - In order to provide evidence that the system is working the orgnization should maintain records like the training record, record of audits and minutes of the Management Review etc. The organization decides as to which of the records are required to demonstrate the working of the environmental management system.
4.5.5 - Internal audits are carried out to evaluate the working of the EMS. Internal audits may be carried out by competent persons from within the orgnization or by those working outside the organization. An EMS audit is a systematic process of objectively collecting audit evidence against audit criteria, evaluate the audit evidence, to conclude if there sufficient evidence to show if the EMS audit criteria are met and to report to the client the conclusion of the findings. EMS internal audits have to be carried out according to ISO-19011: Guidelines for Quality and/or Environmental Management System Auditing.
4.6 Once the elements of Checking have been established and implemented, the next step to go for the Management Review. The management review addresses issues like a) results of internal audits and evaluations of compliance with legal requirements and with other requirements to which the organization subscribes, b) communication(s) from external interested parties, including complaints, c) the environmental performance of the organization, d) the extent to which objectives and targets have been met, e) status of corrective and preventive actions, f) follow-up actions from previous management reviews, g) changing circumstances, including developments in legal and other requirements related to its environmental aspects, and
h) recommendations for improvement.
The output of the management review includes, decisions and actions related to the possible changes to environmental policy, objectives, targets and other elements of the environmental management system, consistent with the commitment to continual improvement. The discussions and decisions taken at the Management Review are minuted.
Thus the Management Review completes one PDCA cycle of the EMS and triggers off the next PDCA Cycle for improving the organization's environmental performance.
The other management systems like OHSAS 18001 and SA 8000 can be understood if you understand how ISO-14001 Environmental Management system works
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