Module 5

Methodology Operation, Check &

Correct and Management Review
Steps
ISO 14001 : Implementation &
Operation (4.4)
Resources, roles, responsibility and authority
(4.4.1);
Competence, training and awareness (4.4.2)
Communication (4.4.3)
Documentation (4.4.4)
Control of documents (4.4.5)
Operational control (4.4.6)
Emergency preparedness and response (4.4.7)
Implementation & Operation
4.4.1 - Structure & responsibilities:
Ensure everyone knows who does what
Define the organization and responsibility
Appointment of a Management Representative
(MR)
Resources, roles, responsibility and
authority (4.4.1)
Provide essential resources such as:
Human resources
Specialized skill
Technology
Financial resources
Define, document and communicate roles,
responsibilities and authority for effective
environmental management
Appoint Management Representative(s)
Competence, Training, Awareness
Employees who can cause significant
environmental impact(s) shall be competent
to implement;
Employees competence shall be enhanced
continuous through appropriate
Training
Education and/or
Experience
Competence, Training, Awareness
Based on identified need, training shall be
provided to employee;
All employee shall be aware of:
Importance of conformity with
environmental policy and procedures
Environmental benefits of improved
performance, their roles & responsibilities;
Potential consequences of departure from
specific operating procedure
Communication (4.4.3)
Document the methods for ensuring effective and
efficient communications on environmental issues to
both internal and external sources and recipients;
Organization shall establish & maintain procedures for:
Internal communication between different levels, departments
and functions;
Receiving, documenting and responding to communications from
interested parties;
Organization shall
Decide on external communication about its
significant environmental aspects, implement and
record;
Communications
Organization
Awareness
Performance
Internal
Complaints
Interested
parties
External
Documentation (4.4.4)
Establish documentation to ensure the core
element, policies/procedures/specific
instructions - are described and linked
Information on paper or in electronic form
shall
Describe core elements of EMS and their
interaction
Provide direction to related documentation
Documentation
EMS
Manual
EMS
Procedures
&
Instructions
EMS
Records
References
References
General Description
Policy
Aspects
Procedures
Responsibilities
Resources
Detailed description for
each core element
Contains information
about
Who should do
what, how and when
Records from procedures
& instructions
List of aspects, laws,
objectives & targets
Audit reports
Measuring results
Documentation of training
LCA - analyses
Control of Documents (4.4.5)
Establish a system to keep the documentation in
location, assigned to, date & revision
Procedures shall ensure all documents to be:
Reviewed, approved & updated;
Identified changes & revision status available to those
who need;
Legible, easily identifiable;
Identified & distributed for external documents;
Promptly removed when obsolete and marked, if used
Operational Control (4.4.6)
Organization shall:
Identify operations associated with significant
environmental aspects;
Prepare documented procedure to avoid
deviation from Policy/Objectives/Targets within
operational limits
Operational Control
Identify significant aspects of all activities
Controls should:
Eliminate Unnecessary Sources
Minimize Necessary Sources
Eliminate Unnecessary Migration Pathways
Minimize Necessary Migration Pathways
Include Contractors in Controls
Operational Control
- Operational control MUST be capable of dealing
with normal AND abnormal circumstances:
Accidents
Start-up and Shut-down
The types of operational control are NOT defined,
each
company defines their own system
Operation Control - Example
S. No. Significant
Monitoring
Env. Aspect
Wastewater
Discharge
Process
Effluent
Treatment
Plant
Procedure
pH control
COD, BOD
Oil & Grease
(O&G)
Operation
Criteria
5.5 - 9.0
COD < 250 mg/l
BOD < 30 mg/l
O&G < 10 mg/l
Criteria
Continuous
On-line
Once a day
Once a day
Once a day
1.
Operation Control
Organization shall identify significant
environmental aspects from suppliers &
contractors:
Are these aspects addressed by procedures?
Are these procedures communicated with the
suppliers?
Emergency Situation (4.4.7)
Organization shall:
Identify potential accidents and emergency
situations;
Prevent and mitigate environmental impacts that
may arise from them;
Review and revise emergency preparedness
particularly after occurrence of accidents or
emergency situations;
Conduct periodic mock drills to test such
procedures, where practicable
Emergency Situation
Emergency preparedness and response:
Ensure there are procedures and plans for
mitigating the environmental impact of
emergency situations.
Requires:
Identification of what an emergency can be
Plans for response if circumstances occur
Testing of plans for capability
Review of tests and changes to plans, if necessary
Identification of Potential
Emergency Situation
Emergency situation may arise:
From transportation, storage and use of raw
materials & chemicals;
Storage of solid, toxic & hazardous wastes;
Malfunctioning of effluent treatment plant;
Non-functioning of air pollution control systems;
Fire hazards, etc.
Mitigation of Environmental Risks
Preventive Actions
Checking (4.5)
Monitoring and Measurement (4.5.1)
Evaluation of Compliance (4.5.2)
Non-conformity, corrective action and
preventive action (CAPA) (4.5.3)
Records (4.5.4)
Internal Audit (4.5.5)
Checking and corrective action
Monitoring and Measuring
Develop monitoring & measurement plans/programs and
procedures to ensure requirements are met:
Monitoring - visual inspections
Measurements - sampling and analysis
As a minimum based on legal compliance and the
milestones in management programs
Monitoring and Measurement
Organization shall monitor:
Procedures for key characteristics that affect
significant environmental impacts;
Conformity against Objectives & Targets;
Calibration records of monitoring equipment
Compliance with relevant environmental
legislation
Non-conformance and Corrective &
Preventive Action
If things go wrong - develop a procedure for:
Identifying and investigation
Initiating (with appropriate speed) Corrective
(controlling) Action
Design and implement preventive action to
eliminate repetition
Ensure changes to related documentation
Non-conformity, Corrective Action &
Preventive Action (CAPA)
Procedures for
Identifying and correcting non-conformity(ies)
Carrying out root cause analysis and actions
Initiate preventive actions
Recording results of actions
Reviewing effectiveness
Actions to be appropriate to mitigate
problems and impacts encountered
Clarifications
Non-conformity (NC)
Deviations from required standards
Correcting Non-conformance
Remedial measure taken to mitigate environmental
impact of NC
Corrective action
Reactive action taken to eliminate or minimize
recurrence
Preventive action
Proactive action to minimize potential NCs
Control of Records
Legible, identifiable and traceable
Stored, retrievable, protected and retention periods
established;
Records required to be maintained
To demonstrate:
Conformity to requirements of its Environment Management System, and
Environmental Performance
Control of Records
Procedures on how to handle environmental records:
To be identifiable, legible, traceable;
To be stored & maintained so they are easily retrieved &
protected against spoilage;
Retention & disposal times to be defined & recorded
Internal Audit
Establish a planned and
systematic approach for
conducting EMS internal audits
with:
Frequency of audit based on
criticality of area/activity/EMS
procedure to overall environmental
management
The focus on Pollution not just
Paper
The system being responsive to
change
Internal Audit
Organization shall have procedures for
periodic audits for EMS to determine:
Conforms to plan and standards;
Has been implemented and maintained
Provide information on audit results to
management
Internal Audit
Program & schedule shall reflect:
Potential environmental impact of activity;
Results of previous audit.
Procedure shall cover:
Audit scope/frequency/methodology;
Responsibility/auditor requirements, and
How to report audit findings?
Need for Audit
To satisfy ISO 14001 requirements;
Ensure compliance with procedures;
Determine systems effectiveness;
Identify and rectify non-conformities;
Identify training needs;
Carry out SWOT analysis and highlight
weaknesses & strengths;
Identify areas for improvement;
Provide facts to management.
Management Review (4.6)
Top management shall review:
Adequacy, suitability and effectiveness of EMS;
Policy, objectives and procedures need changes
Management Review
Inputs of Management Review shall be:
Based on Feedback, at regular intervals, the results of performance
Indicators;
Results of Internal Audits;
Results of evaluation of compliance with legal and other
requirements;
Communication from external interested parties, if any;
Environmental Performance of organization;
Status of achievements of Objectives & Targets;
Status of corrective & preventive actions;
Follow up actions, if any;
Changing circumstances & scenario;
Recommendations for further improvement
Summary
ISO 14001 : Implementation and Operation
Emergency Situation
NC & CAPA
Internal Audit
Management Review