Interpretive Guidelines to ISO 14001:2004. DNV Business Assurance

Transcription

1 Interpretive Guidelines to ISO 14001:2004 DNV Business Assurance

2 Copyright 2013 by Det Norske Veritas Certification, Inc. All rights reserved. Printed in United States of America Published by Det Norske Veritas Certification, Inc Ravello Drive Katy, TX DNV is an independent foundation established in 1864 whose objective is safeguarding life, property and the environment. DNV is a world-class provider of loss control management services including safety, health, quality and environmental protection for business, government and industry. Worldwide publishing and distribution rights held by Det Norske Veritas Certification, Inc., 1400 Ravello Drive, Katy, Texas, No part of this document may be reproduced by any means, nor transmitted, nor translated into a machine language without prior written permission of the publisher. The information contained in this reference material is distributed as a guide only; it has been compiled from sources believed to be reliable and to represent the best current opinion on the subject. No warranty, guarantee or representation is made by Det Norske Veritas Certification, Inc. as to the absolute correctness or sufficiency of any representation contained in this reference material, and Det Norske Veritas Certification, Inc. assumes no responsibility in connection therewith; nor can it be assumed that all acceptable safety measures are included herein, or that other measures may not be required in particular or exceptional conditions or circumstances. While Det Norske Veritas Certification, Inc. does not undertake to provide a revision service or guarantee accuracy, we shall be pleased to respond to your individual requests for information at any time.

3 Table of Contents Introduction to ISO ISO Series of Standards... 2 Frequently Asked Questions... 3 Understanding the Standard General Requirements Environmental Policy Planning Environmental Aspects Legal and Other Requirements Objectives, Targets and Programs Implementation and Operation Resources, Roles, Responsibility and Authority Competence, Training and Awareness Communication Documentation Control of Documents Operational Control Emergency Preparedness and Response Checking Monitoring and Measurement Evaluation of Legal Compliance Non-Conformity and Preventive and Corrective Action Control of Records Internal Audit Management Review Important Questions to Ask Your Registrar Glossary of Terms What We Have Learned List of ISO Articles... 37

4 INTRODUCTION Companies seeking ISO compliance and certification need to begin with a strong commitment to environmental responsibility and an effective management system. The process of implementing ISO in successful companies leads to tangible management improvements, waste reductions, and overall improvements in regulatory compliance. In order to expand an organization s knowledge regarding Environmental Management Systems (EMS) and the ISO standard, the most current information is included in this compendium. The Guidelines can be used by organizations that are already certified, those seeking certification, and by those that are considering entering the process. The most current information available is included to provide guidance for those clients and potential clients seeking to expand their knowledge. It is the hope of all those involved in its preparation that it provides proven, honest and timely insights for those who need a guideline to more fully understand ISO From rather modest beginnings, the International Organization for Standardization (ISO) has grown steadily to its present level of 124 member countries. Support is provided by nearly 3,000 technical bodies and more than 30,000 volunteer experts. Approximately 50,000 companies in the United States and 700,000 companies worldwide have been registered to one or more of the ISO management system standards. The new edition of ISO 14001, referred to as ISO 14001:2004, was published in November This international standard specifies requirements for an environmental management system to enable an organization to develop and implement a policy and objectives which take into account legal requirements and information about significant environmental aspects. It is intended to apply to all types and sizes of organizations and to accommodate diverse geographical, cultural and social conditions. The success of the system depends on commitment from all levels and functions of the organization, especially from top management. A system of this kind enables an organization to develop an environmental policy, establish objectives and processes to achieve the policy commitments, take action as needed to improve its performance and demonstrate the conformity of the system to the requirements of this international standard. The overall aim of this international standard is to support environmental protection and prevention of pollution in balance with socioeconomic needs. It should be noted that many of the requirements can be addressed concurrently or revisited at any time. The second edition of this international standard is focused on clarification of the first edition, and has taken due consideration of the provisions of ISO 9001:2000 to enhance the compatibility of the two standards for the benefit of the user community. ISSUE 2 REV 1 All rights reserved PAGE 1 OF 38

5 ISO SERIES ISO is a series of international environmental standards. They can be divided into process related standards and product oriented standards. Currently, ISO is the only environmental standard to which a company can be certified. At least one company has been registered in 103 countries. Certificates in North America number more than 6,000. ORGANIZATION OR PROCESS STANDARDS Environmental management systems Specification with guidance for use Environmental management systems General guidelines on principles, systems and supporting techniques Guidelines for environmental auditing General principles of environmental auditing Guidelines for environmental auditing Audit procedures Guidelines for environmental auditing Qualification criteria for environmental auditors Environmental site assessments Evaluation of the environmental performance of the management system and its relationship to the environment. PRODUCT ORIENTED STANDARDS Goals and principles of all environmental labeling Environmental labeling self-declaration environmental claims. Terms and definitions Environmental labeling symbols Environmental labeling testing and verification methodologies Environmental labeling practitioner programs. Guiding principles, practices and certification procedures for multiple-criteria programs Environmental management life cycle assessment. General principles and guidelines Environmental management life cycle assessment. General principles and guidelines Environmental management life cycle assessment Environmental management life cycle assessment. Interpretation Terms and definitions Guide for the inclusion of environmental aspects in product standards. ISSUE 2 REV 1 All rights reserved PAGE 2 OF 38

6 FREQUENTLY ASKED QUESTIONS Q. Why the interest in ISO 14001? A. ISO 14000, including the U.S. ISO nd edition published in November 2004, represents a harmonized international Environmental Management System (EMS) standard. It was created by ISO Technical Committee 207, which includes representatives from around the world. Effective environmental management can reduce an organization s impact on the receiving environment, improve operational efficiency, identify opportuni ties for cost savings and may reduce environmental liability, and improve regulatory compliance. ISO may also be a requirement for conducting everyday business. As examples, OEMs and/or Tier 1 suppliers to such companies as Ford Motor Company, Toyota, Honda and Daimler-Chrysler must eventually be certified to ISO BP and other energy companies are also heavily promoting EMS for contractors involved in the exploration, drilling, production and distribution of oil and gas. Q. How did the effort to develop the ISO series come into being and who is responsible for the development of the ISO series? A. As a result of the June 1992 U.N. Conference on Environmental Development held in Brazil, the International Organization for Standardization (ISO) made a commitment to support environmental development efforts. Discussions were initiated by ISO with its members playing appropriate roles directed toward those efforts. Aware of the strong international desire for better environmental care, ISO also saw the real potential of trade barriers in existing national environmental management standards. As the global market continues to expand and increase in importance, diverse national and regional environmental standards could result in unintended technical barriers to international trade and commerce. Therefore, a critical need was recognized for basic, uniform voluntary standards that will serve to manage environmental impacts and promote trade and commerce. Toward this end, ISO agreed to form ISO Technical Committee 207 in 1993 to develop international consensus standards, the ISO series, in the field of environmental management tools and systems. Q. What is ISO? A. ISO is an international non-governmental organization that promotes the development and implementation of voluntary international standards. ISO consists of more than 120 member countries, with the United States being represented by the American National Standards Institute (ANSI). Standards are developed within ISO technical committees. Draft versions of the standards are sent out for formal review and comments from ISO member countries. Feedback is incorporated to eventually publish an agreed-upon international standard. ISSUE 2 REV 1 All rights reserved PAGE 3 OF 38

7 FREQUENTLY ASKED QUESTIONS Q. What is an Environmental Management System (EMS)? A. An EMS is the management system that addresses the environmental impact of a company s processes, products and services on the environment. The EMS provides a formalized structure for ensuring that environmental concerns are addressed and met, and works to both control a company s significant environmental effects and achieve regulatory compliance. Q. What are some of the possible ways that the ISO series of standards will affect or be used by companies? A. To objectively demonstrate commitments to environmental responsibility Result in more effective management of environmental affairs and regulatory compliance May be a mandatory requirement for some suppliers in the automotive industry, for electronics and computer manufacturers, and oil and gas exploration and production contractors Help to eliminate or reduce waste by identifying impacts, risks, areas for improvement, and process adjustments or modifications To drive goals related to sustainable development, recycling, and reuse, e.g. design for the environment May be used by regulators in sentencing guidelines, consent orders, or other alternative enforcement mechanisms Q. How does ISO relate to the European Union s Eco-Management and Audit Scheme (EMAS)? A. EMAS is the European Union s Eco-Management and Audit Scheme. EMAS, a regulation relevant only in the European Community, is applicable only to industrial sites. EMAS requires the implementation of an Environmental Management System and validation of a company s environmental statement of performance. While it covers essentially the same substantive elements as the EMAS and the former BS7750, ISO is more flexible than either of these standards and therefore more suitable for international application. The major requirement of EMAS that is not covered in ISO is the publication of a verified environmental statement that discloses to the public the organization s objectives and achievements toward environmental protection. ISSUE 2 REV 1 All rights reserved PAGE 4 OF 38

8 FREQUENTLY ASKED QUESTIONS Q. How does the U.S. EPA view ISO 14001? A. The EPA officially supports EMS s, but does not specifically endorse ISO It believes that EMS s and ISO have the potential to enhance and improve environmental protection and compliance. The EPA has developed an official policy statement that addresses ISO and the use of EMS s. This can be found in Federal Register: March 12, 1998 (Volume 63, Number 48), pages The EPA has also partially funded state and municipal EMS pilots through the Multi-State Working Group, and is financially supporting EMS standard development for biosolids management through the National Biosolids Partnership. Q. When will final ISO series standards become available for use and implementation? A. Sixteen documents in the ISO series in the areas of environmental management systems, environmental auditing, life cycle assessment and environmental aspects in product standards have been completed and are published. Other ISO series documents in the areas of life cycle assessment, greenhouse gas emission and environmental determined communications are in the development stages. Final document dates for these are still to be determined. Q. Does a company or organization have to implement all standards in the ISO series? A. ISO is a series of voluntary standards. Companies and organizations are not required to comply with or implement any of these standards. However, the standards become necessary to conduct business if they become the basis for regulations in countries or regions, or if they become de facto requirements in customer-supplier relationships. ISO is considered to be the foundation document of the entire series, and most other documents in the series are proposed as guidelines that will support a company or organization s environmental management system. With the exception of one of the eco-labeling documents under development, ISO is currently expected to be the only document developed by ISO Technical Committee 207 to which companies or organizations may become registered or certified. ISSUE 2 REV 1 All rights reserved PAGE 5 OF 38

9 FREQUENTLY ASKED QUESTIONS Q. Are there U.S. national standards at this time in the subject areas covered by ISO 14000? A. At this time, there are six American National Standards in the subject areas related to ISO The organizations ASTM, ASQ and NSF International have jointly sponsored the U.S. national adoption of the ISO and ISO EMS standards and the ISO 19010, ISO and ISO environmental auditing standards as American National Standards. In addition, ISO 14040, in the field of life cycle assessment, has recently been adopted as an American National Standard. The United States has not yet taken any decisions on the national adoption of other documents under development in the ISO series. It should also be noted that ASTM has additional standardization efforts related to environmental auditing, environmental site assessments and life cycle assessment. Q. What is the difference between conformity assessment, accreditation, certification and registration in relation to ISO 14000? A. Official definitions according to ISO/IEC Guide 66 and the IAF Guidance on the Implementation of Guide 66 are as follows: Conformity assessment: The determination of whether a product, process or service conforms to particular standards or specifications. Activities associated with conformity assessment may include testing, certification, accreditation, quality assurance system registration and environmental management system registration. Accreditation: A procedure by which an authoritative body (e.g. ANAB, formally RAB) gives formal recognition that a body or person is competent to carry out specific tasks. Accreditation means that a body has been evaluated in accordance with internationally recognized standards (ISO/IEC Guide 62 and ISO/IEC Guide 66) and has been found competent and therefore is authorized to register companies which have successfully demonstrated compliance to ISO Certification: A procedure by which a third party gives written assurance that a product, process or service conforms to specified requirements (e.g. ISO 14001). Registration: A procedure by which a company accepts and implements relevant requirements of a product, process or service and then includes or registers the product, process or service in a publicly available list. Registration is generally used in the United States for the procedure defined as certification above, while certification is the preferred term in Europe and other parts of the world. ISSUE 2 REV 1 All rights reserved PAGE 6 OF 38

10 FREQUENTLY ASKED QUESTIONS Q. What does ISO related registration/certification require? A. Registration requires evidence of implementation of ISO 14001, which also includes: procedures to maintain compliance to applicable laws, commitment to continual improvement (in a broad sense) and commitment to prevention of pollution (e.g. recycling, process changes, energy efficiency, materials substitution). Whether a company decides to seek third-party registration or certification to ISO will be dependent on the objectives the company has in conforming to ISO 14001, as well as the market and public context in which the company operates. For some companies, third-party certification may be the most reasonable option. For example, companies selling products to markets in Europe might face considerable pressure to obtain third-party certification. However, even in Europe, companies should not presume certification will be necessary. It is very important to understand that either third-party certification or self-declaration are available options. Q. How does my company/organization become involved in the development of the ISO series documents? A. Each country is allowed only one member and one vote in the standards development process and decisions of ISO. ANSI is the USA member of ISO. It is the responsibility of ANSI to ensure that U.S. positions on the development of ISO standards represent a single unified U.S. consensus view. This consensus building is accomplished through the establishment of U.S. Technical Advisory Groups or US/TAGs for ISO activities. US/ TAGs are committees made up of U.S. industry, government, professional/trade associations, public interest groups and other affected interests, accredited by ANSI to operate under consensus procedures to develop the U.S. positions on the ISO documents. The US/TAGs and sub-us/tags for the ISO series are administered by the organizations ASTM, the American Society for Quality (ASQ) and NSF International, on behalf of ANSI. Q. How do I purchase, order or find the price of published standards, draft international standards or committee drafts in the ISO series? A. ANSI and ASTM make available to the general public copies of the final published ISO standards. ANSI, ASQ, ASTM and NSF International will all make available to the general public final published versions of the national adoptions of the ISO standards, as well as draft versions of the ISO documents at either the committee draft stage or draft international stage. ISSUE 2 REV 1 All rights reserved PAGE 7 OF 38

11 FREQUENTLY ASKED QUESTIONS Q. How many significant aspects is a company required to identify? A. There is no set number of significant aspects that should be identified. It depends on the site s complexity, type of industry, and processes, products and services. All aspects must be identified considering normal, abnormal, and accidental situations. Q. How many objectives and targets is a company required to identify? A. There is no set number of objectives and targets required. However, the significant aspects must be considered in setting objectives and targets. Some of the objectives and targets must be related to the organization s significant environmental aspects. Q. Do targets have to be quantified? A. Targets should be quantified where feasible. If one or more cannot be quantified, the targets must at a minimum be results oriented, i.e. would result in improvement to the EMS and/ or environmental impact. Q. What employees need to be trained? A. All employees must receive general awareness training. This training may consist of subject matter on the environmental policy and the significant aspects and impacts of the organization s activities, products, and services. Employees whose work could significantly impact the environment and/or whose activities could affect the objectives and targets or environmental policy should have more detailed training. This may consist of detailed training on relevant operating procedures, the EMS, objectives and targets, etc. Q. Are there regulatory compliance incentives for ISO 14001? A. All companies must still adhere to all state and federal environmental statutes. However, some states are providing incentives to encourage companies to implement an EMS or to become certified to ISO Examples: Texas and Wisconsin are lining up bipartisan support for green programs designed in such a way for a company to voluntarily exceed regulatory compliance through ISO or an equivalent program. The Texas legislation provides for regulatory incentives among them are reduced inspections, on-site technical assistance, and in certain situations even modification of state or federal regulatory requirements. ISSUE 2 REV 1 All rights reserved PAGE 8 OF 38

12 FREQUENTLY ASKED QUESTIONS Q. What measuring and monitoring needs to be documented with records? A. Any calibration of measuring and monitoring equipment, if technically feasible, related to significant environmental aspects, must be recorded. Other than this specific requirement in the international standard under 4.5.1, there are no other requirements for measuring and monitoring records. However, the key characteristics of the organization, measuring and monitoring related to operational controls, objectives and targets should be adequately documented and recorded in order to assure that processes are within the parameters set by the organization and suitably tracked. Q. Does an organization have to be in 100% compliance? A. No. An organization does not have to be in 100% compliance. However, it must recognize that it is in non-compliance, and take appropriate corrective and preventive action(s) to become compliant. Q. Can ISO 9001:2000 and ISO management systems be integrated and audited together? A. Under the ANAB National Accreditation Program (NAP), ISO and ISO 9001 follow similar accreditation requirements. The standards can be integrated and audited in a combined approach as long as each standard s requirements are met. Combining audits can also result in cost savings and less disruption. Due to the relatively young nature of ISO and the maturity of ISO 9001, most companies still keep the two standard s systems partially or completely separated. But a growing number of companies have integrated or partially combined their quality and environmental management systems. Some are also integrating their safety requirements and systems with their environmental or quality systems. Q. Can an organization have one safety and environmental system, and still have the environmental management system certified to ISO 14001? A. It is common to see companies with one management team, functional area or person managing both safety and environmental affairs. Often the safety and environmental policies (EHS policies) are combined and compliance requirements implemented through one set of procedures. DNV can audit the environmental areas of the management system alone and issue an ISO certificate or it can also assess the safety aspects of the system and simultaneously issue a non-accredited safety certificate or letter of conformance. DNV can also audit or assess the safety system against Responsible Care (RC and RCMS ), VPP, to the new international safety standard referred to as OHSAS 18001, or to the DNV proprietary International Safety Rating System (ISRS). ISSUE 2 REV 1 All rights reserved PAGE 9 OF 38

13 FREQUENTLY ASKED QUESTIONS Q. What is OHSAS 18001? A. This refers to the Occupational Health and Safety Assessment Series. This is a Safety standard developed by DNV, other registrars and international accreditation bodies, and consultants. It is a consensus international safety standard which is specifically designed to be compatible with ISO It sets out the general requirements for an effective safety management system. Currently, OHSAS is not an ISO standard, but it could be the precursor of an ISO safety standard. Note: The preceding questions and answers have been partly provided by the International Organization for Standardization in Geneva, Switzerland, through Klaus-G. Lingner, Deputy Director, Planning and Technical Coordination, and by Russell V. Thornton, Director, Environmental, Health and Safety Certification for DNV Certification. ISSUE 2 REV 1 All rights reserved PAGE 10 OF 38

14 UNDERSTANDING THE STANDARD OVERVIEW The following is a guideline for meeting the requirements of ISO 14001:2004, the international standard for environmental management systems (EMS). Each element contains interpretations by DNV Certification, to be used in concert with the text of the ISO 14001:2004 standard and information and material from ANAB. The purpose of this guidance is to supplement portions of the standard that may not be easily interpreted through the ISO 14001:2004 standard alone. Each section of this guideline has two parts, the guidance and the required documentation. This document is designed to provide clear descriptions of the standard s requirements. It is designed to be an aid to organizations that want to participate in this voluntary program of conformance to ISO 14001:2004. When beginning the certification process, the EMS should be operational for at least three months prior to the certification audit conducted by the registrar. There must be objective evidence provided by the organization that this has been accomplished. That is, the EMS must be proven to be effective and that it will provide for regulatory compliance and continual improvement through documentation, demonstration of duties, interviews with employees and other objective evidence. Procedures shall be fully implemented with no significant gaps in terms of conformance to the standard and/or internal requirements, including implementing objectives and targets, awareness and training, internal EMS audit and management review. One complete cycle of internal EMS audit(s), meaning covering all elements of the standards, and a management review, must be completed by the organization prior to the certification audit. Ideally, the internal EMS audit(s) and management review should be completed 8 13 weeks prior to the certification audit to give the organization enough time to address non-conformances, and implement corrective and preventive actions. 4 GENERAL REQUIREMENTS OF ISO 14001: General requirements The process used by the organization to develop their environmental management system is required to be documented to ensure demonstration of conformance to ISO 14001:2004. One point that is contained in each element within the ISO 14001:2004 standard, which is not in the ISO 14001:1996 standard, is the stress on implementation, and not just establishment and maintenance. Continual improvement of the environmental ISSUE 2 REV 1 All rights reserved PAGE 11 OF 38

15 UNDERSTANDING THE STANDARD The organization is responsible for specifically defining and documenting the scope of the system and ensuring that the organization s processes, products and services are integrated into that scope. The process of how the organization will fulfill these requirements will need to be addressed and managed by the site. Recordkeeping and documentation issues General documentation of the system will need to be retained to demonstrate a functioning environmental management system. Also, the scope of the organization s system will need to be documented and maintained in the site s environmental records. 4.2 Environmental policy The purpose of the environmental policy is to establish the principal areas of environmental actions and activities within the defined scope of the EMS. The policy shall be authorized and approved (executed) by the organization s top management. Top management is considered to be the highest level with executive responsibility in the organization being certified. A plant manager at a particular site would be considered an example of top management. This policy will need to be appropriate to the nature of the organization s business and processes. Having one simple defined statement aids in ensuring the entire organization is moving in a consistent direction in relation to its environmental performance. This performance is measured by the site s conformance to legal and other requirements and their commitments to continual improvement and pollution prevention. The policy should be maintained by the organization under the document control procedures established for all EMS documents identified by the organization and /or required by the international standard. The organization is responsible for ensuring that the policy is generally available to employees. Employees and those persons working on its behalf should be able to verbalize the policy in their own words and in relation to their environmental duties within the system. The policy must be made available to the public when requested. Recordkeeping and documentation issues Obsolete versions of the policy shall be removed and the current policy should be maintained as a record in conformance with the relevant internal document control procedures. The scope of the environmental management system will need to be documented and recorded to show conformance with this international standard. ISSUE 2 REV 1 All rights reserved PAGE 12 OF 38

16 UNDERSTANDING THE STANDARD Records or other evidence of internal and external communications regarding the policy are the responsibility of the organization. 4.3 Planning Environmental aspects An organization with no existing EMS should initially establish its current position with regard to the environment by means of a review. The aim of this review should be to consider the environmental aspects of the organization as a basis for implementing its EMS in line and within its documented scope. The aspects identified shall demonstrate those activities of the EMS that the organization can control and those that it can influence. Along with existing products and processes, the organization will need to address planned, new or modified developments and activities. New developments and new or modified activities, products and services could include such activities as change to process, major construction, relocation, addition of a major process, commissioning and decommissioning of environmental pollution control equipment, etc. If one of these events occurs there shall be a way for the EMS to review the activity and modify applicable elements of the environmental management system, as needed. See Table A.1 of for more detailed examples of the establishment of environmental aspects. The organization must identify and evaluate the environmental significance associated with the impacts of their environmental aspects. The tools or methodology used for establishing significance (or risk evaluation) should identify the actual or potential impacts associated with each aspect during: Normal operational use Use during shut-down, start-up, maintenance or construction (abnormal situations) Emergency conditions Site, local, regional, and global impacts The organization will be required to keep documentation of their significant environmental aspects and be able to provide objective evidence that all environmental aspects have been kept updated and were considered in developing, implementing and maintaining its environmental management system. ISSUE 2 REV 1 All rights reserved PAGE 13 OF 38

17 UNDERSTANDING THE STANDARD Recordkeeping and documentation issues The organization shall keep documentation of the established aspects, impacts and their significance. Records of their updates and evaluations and their significant aspect documentation will be assessed to assure that the evaluation process is logical and repeatable Legal and other requirements The organization will need to identify those legal and other requirements that are appli cable to the organization based on the processes and programs at the site. All applicable legal and other environmental compliance requirements shall be identified and it shall be determined how these apply to the developed environmental aspects. The organization should provide ample objective evidence that applicable requirements are disseminated and reviewed, and are implemented in operational control requirements. If necessary, changes and updates to regulatory and other requirements will need to be managed by the sites. When establishing, implementing and maintaining its environmental management system these requirements will need to be considered. Recordkeeping and documentation issues The organization shall have some means to prove that new environmental compliance requirements have been applied to the organization s activities, operations and services in a timely manner. This could be a list maintained with all regulations and other requirements applicable to the site or access to web or intranet sites Objectives, targets and program(s) When first developed, the EMS and objectives and targets can be established to ensure compliance or even cost savings that may be related to environmental and site activities. As the organization s system matures, there will be a natural progression to using these criteria along with other environmental aspects which can be integrated into other business related decisions, perhaps integration of multiple business systems. The organization should use a tracking plan (or other spreadsheet process) to keep track of objectives and targets. One or more of the organization s identified significant aspects should be included as a planned objective and target for continual improvement. These objectives and targets should be in alignment with pollution prevention and continual improvement goals established in the environmental policy. During the selection of objectives and targets consider: ISSUE 2 REV 1 All rights reserved PAGE 14 OF 38

18 UNDERSTANDING THE STANDARD The environmental policy: would improvement of this significant aspect help meet the requirements of the environmental policy? Legal and other requirements: would improvement of this significant aspect help meet legal and/or other requirements? Technological options: are the options for improvement technologically feasible? Financial, operational and business requirements: are the options for improvement financially feasible? The views of interested parties: would the community/interested parties consider the improvement beneficial? The objectives and targets should be Specific, Measurable, Achievable, Results Oriented, and Time Bound (i.e. SMART objectives). There can be more than one program. The program(s) should clearly show the responsibility(s), means (actions) and timeframe for achieving the objectives and targets. This is often best presented in a scheduling and planning matrix in a spreadsheet format. Objectives and targets do not have to be set for all significant environmental aspects. But the significant aspects must be considered, and objectives and targets must be developed for some of the significant aspects at each relevant function and level in the organization. Recordkeeping and documentation issues Objectives and targets and their programs are required to be documented. Obsolete versions of past objectives and targets shall be removed as records and controlled as applicable under the organization s document control and record procedures related to the EMS. If the environmental management program and/or objectives and targets or the significant environmental aspect list are updated or modified, there should be a record. There may be other documentation the organization would use to manage their performance toward the established objectives and targets and this may be maintained to show conformance to the international standard. 4.4 Implementation and operation Resources, roles, responsibility and authority Management of the organization shall establish, maintain and implement a document that includes the names of individuals (including designees) who currently have responsibility to maintain and make improvements to the ISO program. Their roles and responsibilities shall be described, communicated and documented, including those for human resources, specialized skills, organizational ISSUE 2 REV 1 All rights reserved PAGE 15 OF 38

19 UNDERSTANDING THE STANDARD infrastructure, financial and technical resources. The document shall also identify the appointed ISO program manager (management representative) responsible for the implementation, maintenance, and reporting of the ISO elements as described in this guideline. Other organizational positions are also required to be included in the structure of the EMS. In addition, the assignment of roles, responsibilities and authorities should be considered for current and future management of the environmental management system. Management shall demonstrate support of the EMS by ensuring resources are available for effective management of the system. Recordkeeping and documentation issues The organization shall maintain documentation of the structure of the organization in relation to the EMS. Demonstration of these roles will be reviewed to ensure proper communication to appropriate employees. To be truly effective, the EMS should clearly define responsibilities and roles. This is best done through organizational charts and/or work process diagrams. As a minimum there should be a description of these roles and responsibilities within the EMS in a form that is determined by the organization Competence, training and awareness General awareness training shall be identified and conducted for all personnel directly employed by or working on its behalf. The training itself, shall address all requirements of elements (a) through (d) of Section of the ISO 14001:2004 standard. On-site contractors, contractors providing services, or temporary employees that can influence or impact achievement of regulatory compliance, conformance to the international standard, and/or environmental policy must be included in this training requirement. Operator training is required to be conducted for all personnel whose work involving operations, processes or services has a significant environmental aspect associated with it. Suppliers and contractors, temporary employees or any individual working on behalf of the organization that can influence or impact the achievement of regulatory compliance, conformance to the international standard, and/or environmental objectives and targets could be included in this training requirement. The manager responsible for the operator training must ensure that these employees have the appropriate education, training and/or experience to do their jobs in conformance with the EMS and the international standard. Recordkeeping and documentation issues A record of the training received is required to be retained and available for review and audit. Where the competence of personnel and contractors performing tasks associated with activities, products or services identified as having a significant ISSUE 2 REV 1 All rights reserved PAGE 16 OF 38

20 UNDERSTANDING THE STANDARD environmental aspect(s) is hinged on appropriate education and/or experience, records of education and/or experience should be available. Documentation shall also be available for those individuals working on behalf of the organization Communication Organizations shall implement and maintain a procedure on how to conduct internal communications between the various levels and functions of the organization. This is to make sure that information on the organization s significant environmental aspects and the ISO environmental management system is communicated and understood by all employees. The organization is required to implement and maintain a procedure for receiving, documenting the receipt of, and responding to relevant communications regarding environmental aspects and impacts or other issues, e.g. complaints or requests for emissions or discharge data from external interested parties. The procedure must include clear instructions on what, if any, information regarding the organization s significant environmental aspects is decided to be communicated externally. Recordkeeping and documentation issues Records should be maintained, as appropriate, that provide proof of internal communications. Note: Records providing proof of communication may include meeting minutes, newsletters, posters, etc.the organization is required to maintain a record of all external communications received from interested parties on environmental issues. Records should include the responses given by the organization Documentation This information constitutes the framework for the ISO EMS program. It should provide clear, auditable cross-references to all component pieces of the EMS. This should include environmental records, relevant operational control procedures, document control, calibration requirements, non-conformances and corrective and preventive action systems, health and safety related programs and procedures (as appropriate), emergency preparedness, and regulatory compliance documents and/or procedures. The documentation should be available for review by the registrar prior to the certification audit. Recordkeeping and documentation issues It is not a requirement in the ISO standard to prepare a controlled EMS manual, however, best practice is to document the EMS in a manner that is ISSUE 2 REV 1 All rights reserved PAGE 17 OF 38

21 UNDERSTANDING THE STANDARD clearly understood, repeatable and effective. Specific documentation required includes the policy, objective and targets, scope of the EMS and documents relating to significant environmental aspects including planning, operations and control of processes. Other documentation showing conformance with this international standard will need to be retained. The documentation can be in electronic and/or paper form Control of documents Documented procedures shall define the requirements for the identification, storage, protection, retrieval, retention time, and disposition of records. Records are maintained to provide evidence that EMS requirements are being achieved. The organization is responsible for identifying and maintaining those records which are essential to demonstrate compliance to the requirements of the standard. All documents required by the standard or in direct support of the EMS, must be controlled under site specific document control procedures. Any records are required to be managed as addressed in section of the ISO 14001:2004 standard. The emphasis should be on an effective EMS and not on a complex document control system. Documents in direct support of the program could include forms, legal requirements, calibration procedures and records, permits, regulatory compliance reports and audits, operational control procedures, measuring and monitoring procedures, and data. A document can be considered in direct support of the EMS if its absence or deviation could lead to a significant environmental risk(s). The organization shall establish, implement and maintain procedures to: (a) Ensure documents are approved before they are issued and used. As a minimum the documents shall be approved for adequacy prior to issuance. Documented procedures should be written by people knowledgeable in the activity to be controlled to ensure they accurately reflect the processes. An individual or group may be responsible for the review of documents. (b) The organization must have a system in place for review, update as necessary, and reapproval of documents. After the reviewers find the document acceptable, the designated authority approves it. The same function may write, review, and approve the documents. (c) Changes and the current revision status will need to be identified. These changes should be performed by the same functions that originally developed the documentation and have knowledge of the process. ISSUE 2 REV 1 All rights reserved PAGE 18 OF 38

22 UNDERSTANDING THE STANDARD (d) Applicable and up-to-date versions of all documentation must be available at the points of use. The procedures may be centrally located if personnel can exhibit knowl edge of where they are and what is contained in the procedure; keeping each of the procedures at the actual work place is not specifically required. Professional judgment must be exercised regarding accessibility of the documents and the effectiveness of the implemented system. (e) The standard states that organizations must ensure that documents remain legible, and readily identifiable. Accordingly, the organization must have a means of controlling and identifying documents. Examples include a controlled numbering, or other identification system for procedures; a registry of controlled documents; and defined formats for procedures, forms, records, etc. This system itself must be defined and fully documented. Care must be taken to ensure documents remain legible. (f) The organization must ensure that documents of external origin are identified and if distributed internally that their distribution is controlled. External documents may consist of such things as industry standards, international and national standards, and customer specifications. The organization shall have control methods which ensure that applicable revisions of these documents are available at appropriate locations. Therefore, there must be a mechanism to ensure that they are of the correct issue status, and for monitoring changes to the external documents themselves. This could be by the use of one of the commercial updating services available, or by simply contacting the originators of the standards on a regular basis to determine the issue status of the documents. Whatever method is employed, there must be evidence of its successful operation. (g) The system must be effective in preventing the unintended use of incorrect and/or obsolete documents. A process must be in place to preclude the unintended use of obsolete documents. This may be accomplished by their removal from the work area or through suitable identification such as stamping them as obsolete. Documents retained for a specific purpose must be suitably identified. Recordkeeping and documentation issues The organization can use document control procedures developed for other purposes such as for their ISO 9001 quality management system. Those elements that require certain documentation are listed as specific records within the Recordkeeping and ISSUE 2 REV 1 All rights reserved PAGE 19 OF 38

23 UNDERSTANDING THE STANDARD Documentation Issues sections of this guidance. Other records and documentation to be maintained will be determined by the complexity of the organization s EMS. This means that the document control system should be related closely to the complexity of the organization s activities and its own internal requirements Operational control The site should maintain standard operating procedures (SOPs) or other process-specific documents for each activity, operation or service having significant environmental risk (actual or potential impact) and/or which could lead to a deviation in policy, objectives and targets, or regulatory compliance. Each SOP should identify: Significant environmental aspects and/or related material or input associated with the process Operating criteria the operator should follow Key parameters and their acceptable operating range that the operator should monitor to assure environmental regulatory compliance and process safety Monitoring and measurement requirements that the operator should follow to ensure that the key parameters are within normal range The frequency of measurement and the expected records of measurement that the operator is required to maintain Critical environmental equipment Any calibrations and frequency of calibrations required to assure measurement accuracy The organization or person(s) responsible for calibrations Situations where non-conformance to operating procedures and/or key parameters could lead to possible non-conformance (resulting in deviations from the environmental policy and the objectives and targets) Education, training and/or experience required to operate the process or conduct the activity Recordkeeping and documentation issues The organization must have records showing that relevant employees and contractors have received training on the standard operating procedures related to their job, and that they are understood and followed. ISSUE 2 REV 1 All rights reserved PAGE 20 OF 38

24 UNDERSTANDING THE STANDARD Emergency preparedness and response The organization shall consider and have appropriate emergency preparedness and response procedures that cover all processes/activities categorized as having a significant environmental aspect. DNV will accept existing procedures as long as environmental accidents and emergency situations are addressed. Emergency preparedness and response procedures should: Describe potential accidents, spills, releases and emergency situations Identify how to prevent them from occurring Identify what to do to mitigate the environmental impacts associated with the situation Be updated to reflect lessons learned from past incidents and drills Test their emergency preparedness and response procedures periodically Recordkeeping and documentation issues The organization should have records showing that the above procedures are carried out and tested, if feasible. 4.5 Checking Monitoring and measurement Monitoring is a continuous assessment of performance over time. Measuring is a discreet check of the acceptability of a parameter usually using an instrument. Examples of environmental system components that could be monitored and measured are as follows: Tracking progress on policy and how the system links back to the policy Developing information to identify significant environmental aspects Monitoring emissions and discharges to meet legal requirements or other environmental requirements Monitoring water, energy or raw materials consumption to meet objectives and targets Providing data to support or evaluate operational controls Providing data to evaluate the organization s environmental performance Evaluating performance of the EMS Monitoring and measurement practices shall be implemented, as feasible, on all activities, processes, and services directly linked to the identified significant ISSUE 2 REV 1 All rights reserved PAGE 21 OF 38

25 UNDERSTANDING THE STANDARD environmental aspects and other key characteristics identified by the organization. All measuring and monitoring equipment related to a significant environmental aspect and/or operational control or objectives and targets that are capable of being calibrated, are required to be calibrated, if the absence of calibration could lead to a significant impact on the environment. The organization must document information for monitoring and measurement for applicable operational controls and conformity with objectives and targets. Calibrating and verifying monitoring and measurement equipment must be maintained and records retained. Recordkeeping and documentation issues Records showing calibration of monitoring and measurement equipment used to measure and/or monitor activities, processes, or services related to its significant aspects shall be maintained Evaluation of legal compliance As defined by section , the organization will need to demonstrate how their facility evaluates compliance with the applicable legal requirements and reviews other requirements, per section , impacting their site. The registrar will review the process(es) the site has established to ensure these evaluations are performed at an established frequency and that they fully assesses each program. Evaluation methods used could be as follows: Comprehensive regulatory audits (self assessments/consultant administered audits, regulatory visits, etc.) Document and/or records review Facility inspections Interviews of all levels of employees relating to compliance Project or work reviews Routine sample analysis or test results, and/or verification sampling/testing Walk-throughs and/or direct observations of environmental equipment or duties Recordkeeping and documentation issues Records of how the facility chooses to perform their evaluation of legal compliance will need to be retained by the organization. These will need to demonstrate that the site has a process for performing this function and that it is complete and addresses all relevant legal requirements and other requirements of the site. The process for ISSUE 2 REV 1 All rights reserved PAGE 22 OF 38

26 UNDERSTANDING THE STANDARD performing both evaluations (legal and other requirement reviews) will need to be addressed by the organization. Examples of this documentation could be audit checklists, lists of relevant legal requirements reviewed at specified intervals, comparisons of legal requirements with the processes of the site, etc Non-conformity and preventive and corrective action A corrective action is an action taken to eliminate the causes of a detected non-conformity in order to prevent it from recurring. A preventive action is an action taken to eliminate the causes of a potential non-conformity before it occurs. Both of these types of action must be taken to address the actual and potential non-conformities that could be related to these activities. Examples of items that could be addressed in the process of identifying non-conformities for corrective or preventive actions are as follows: Energy reduction targets are not achieved Maintenance requirements are not performed as scheduled Operating criteria (i.e. permitted limits) are not met Records of progress on objectives and targets are not being kept Responsibilities are not assigned as required for an important function of the EMS, such as emergency response Technicians are not following required procedures for sampling Training identified by the organization, as needed for certain job classifications, has not been given The organization shall have appropriate procedures for addressing non-conformities and implementing corrective and preventive actions in response to: Internal EMS audits and compliance self audits Emergency responses (accidents, incidents, and near misses) Non-conformities in standard operating procedures Employee and community concerns Such procedures should cover definitions of non-conformities, roles and responsibilities and the process for reporting them. Specifically, documents should define responsibility and authority and should define how to: Handle and investigate non-conformities Initiate and complete corrective and preventive action Identify and take action to mitigate any impacts caused by the non-conformities Document records of the non-conformities ISSUE 2 REV 1 All rights reserved PAGE 23 OF 38

27 UNDERSTANDING THE STANDARD Determine effectiveness of the corrective and preventive actions Ensure applicable changes are made to any related documentation Recordkeeping and documentation issues Records of non-conformities and corrective and preventive actions shall be maintained. Records should include: Description of actual or potential non-conformities (i.e. an accident/incident reporting form) Causes of non-conformites The corrective actions taken to eliminate the causes of actual and potential non-conformities Any procedural changes implemented and documented as a result of non-conformities Control of records The organization must have procedures, as appropriate, to identify, maintain and dispose of environmental records required by the standard. Examples of records which might be retained are described in ISO 14001, Annex A. The organization will need to have records available that demonstrate implementation and maintenance of an environmental management system. Recordkeeping and documentation issues Records must be legible, identifiable and traceable to the activity, product or service involved. They must be readily retrievable and protected against damage, deterioration or loss. Records should identify their expected retention time. They must be available for review and audit (meaning that they must be readily retrievable) and demonstrate conformance to the standard Internal audit The EMS must describe ISO internal audits at intervals planned by the organization, typically on an annual basis. It must identify audit procedures, scope, frequency, and methodologies, as well as the responsibilities and requirements for conducting audits and reporting. Environmental importance is to be determined by the organization according to their processes and regulatory requirements. The registrar may assess the capabilities and qualifications of the individuals conducting the internal EMS audits to ensure that they are competent and that the EMS audit ISSUE 2 REV 1 All rights reserved PAGE 24 OF 38

28 UNDERSTANDING THE STANDARD process is accurate and effective. The organization should show objective evidence of the impartiality and objectivity of the audit program conducted, including the selection of auditors. Recordkeeping and documentation issues The organization must maintain a record of all EMS audits conducted against the standard. 4.6 Management review A management review of the EMS must be carried out at planned intervals by top management. Review frequency depends on individual circumstances and will vary from organization to organization. Many organizations have found that bi-annual (twice per year) management reviews are appropriate, but this interval is not mandatory. Annual re views may be acceptable for a mature and effective environmental management system. Where changes are planned or are in the process of being implemented more frequent re view periods would be prudent. Note: If the site defines top management as the site manager and his/her top reports, this should be the responsibility of this group at the site. Top management, as defined by the organization, must determine whether or not the EMS is effective and conforms to current circumstances or should be revised. The review shall cover continual improvements, needs for changes to the environmental management system, the environmental policy and environmental objectives and targets. As a minimum, those activities listed within element 4.6 Management Review of ISO 14001:2004 shall be reviewed. Some specific topics or outputs from the management review could also include, but is not limited to: Summary of any agency inspections or assessments Follow-up actions from previous management reviews The need for changes to the EMS in light of changing circumstances, including: Advances in science and technology Planned changes in production activities, facilities, processes and products (note that these could also include production increase and slow down) Lessons learned from environmental incidents ISSUE 2 REV 1 All rights reserved PAGE 25 OF 38

29 UNDERSTANDING THE STANDARD Recordkeeping and documentation issues Records of the organization s management reviews must be retained and documented in such a way to demonstrate conformance with the standard. There should be an affirmative statement of the status of the EMS or if not, any necessary management action or plans needed to ensure success of the EMS. Ensure that any decisions and actions related to the other elements of the standard and continual improvement are captured within the documentation of the management review. ISSUE 2 REV 1 All rights reserved PAGE 26 OF 38

30 12 IMPORTANT QUESTIONS TO ASK YOUR REGISTRAR THE MOST MISINTERPRETED ELEMENTS OR ISSUES RELATED TO THE ISO STANDARD ARE: 1. What records are required under the standard? 2. What equipment must be calibrated and what records must be kept? 3. Must all elements of the EMS be addressed in an EMS manual? 4. Must the organization have environmental management processes for all significant environmental aspects? 5. How does the registrar judge the effectiveness of the identification of environmental aspects and the subsequent ranking process? 6. How does the registrar audit regulatory compliance related to aspects of the EMS? 7. What happens if the auditor identifies a potential regulatory non-compliance? 8. What happens if the organization does not achieve an objective and target? 9. Should all significant environmental aspects have documented operational control procedures? 10. What should an organization measure and monitor and which of these should be documented procedures? 11. How long must the organization have the EMS implemented before it can be certified? 12. Does the organization need to have completed a compliance audit prior to the certification audit? To find out the answers to these questions, visit the ISO services section of our website at ISSUE 2 REV 1 All rights reserved PAGE 27 OF 38

31 GLOSSARY OF TERMS TERMS AND DEFINITIONS FROM THE ISO 14001:2004 STANDARD: For the purposes of this document, the following terms and definitions apply: AUDITOR Person with the competence to conduct an audit. CONTINUAL IMPROVEMENT Recurring process of enhancing the environmental management system in order to achieve improvements in overall environmental performance consistent with the organization s environmental policy. NOTE: The process need not take place in all areas of activity simultaneously. CORRECTIVE ACTION Action to eliminate the cause of a detected non-conformity. DOCUMENT Information and its supporting medium. NOTE 1: The medium can be paper, magnetic, electronic or optical computer disc, photo graph or master sample, or a combination thereof. NOTE 2: Adapted from ISO 9001:2000 ENVIRONMENT Surroundings in which an organization operates, including air, water, land, natural resources, flora, fauna, humans, and their interrelation. NOTE: Surroundings in this context extend from within an organization (3.16) to the global system. ENVIRONMENTAL ASPECTS Element of an organization s activities or products or services that can interact with the environment. NOTE: A significant environmental aspect has or can have a significant environmental impact. ISSUE 2 REV 1 All rights reserved PAGE 28 OF 38

32 GLOSSARY OF TERMS ENVIRONMENTAL IMPACT Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organization s environmental aspects. ENVIRONMENTAL MANAGEMENT SYSTEM EMS is part of an organization s management system used to develop and implement its environmental policy and manage its environmental aspects. NOTE 1: A management system is a set of interrelated elements used to establish policy and objectives and to achieve those objectives. NOTE 2: A management system includes organizational structure, planning activities, responsibilities, and practices. ENVIRONMENTAL OBJECTIVE Overall environmental goal, consistent with the environmental policy, that an organization sets itself to achieve. ENVIRONMENTAL PERFORMANCE Measurable results of an organization s management of its environmental aspects. NOTE: In the context of environmental management systems, results can be measured against the organization s environmental policy, environmental objectives, environmental targets and other environmental performance requirements. ENVIRONMENTAL POLICY Overall intentions and direction of an organization related to its environmental performance as formally expressed by top management. NOTE: The environmental policy provides a framework for action and for the setting of environmental objectives and environmental targets. ENVIRONMENTAL TARGETS Detailed performance requirement, applicable to the organization or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives. INTERESTED PARTY Person or group concerned with or affected by the environmental performance of an organization. ISSUE 2 REV 1 All rights reserved PAGE 29 OF 38

33 GLOSSARY OF TERMS INTERNAL AUDIT Systematic, independent and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which the environmental management system audit criteria set by the organization are fulfilled. NOTE: In many cases, particularly in smaller organizations, independence can be demonstrated by the freedom from responsibility for the activity being audited. NON-CONFORMITY Non-fulfilment of a requirement [ISO 9000:2000, 3.6.2]. ORGANIZATION Company, corporation, firm, enterprise, authority or institution, or part or combination thereof, whether incorporated or not, public or private, that has its own functions and administration. NOTE: For organizations with more than one operating unit, a single operating unit may be defined as an organization. PREVENTIVE ACTION Action to eliminate the cause of a potential non-conformity. PREVENTION OF POLLUTION Use of processes, practices, techniques, materials, products, services or energy to avoid, reduce or control (separately or in combination) the creation, emission or discharge of any type of pollutant or waste, in order to reduce adverse environmental impacts. NOTE: Prevention of pollution can include source reduction or elimination, process, product or service changes, efficient use of resources, material and energy substitution, reuse, recovery, recycling, reclamation and treatment. PROCEDURE Specified way to carry out an activity or a process. NOTE 1: Procedures may be documented or not. NOTE 2: Adapted from ISO 9000:2000, ISSUE 2 REV 1 All rights reserved PAGE 30 OF 38

34 GLOSSARY OF TERMS RECORD A document stating results achieved or providing evidence of activities performed. NOTE: Adapted from ISO 9001:2000, ISSUE 2 REV 1 All rights reserved PAGE 31 OF 38

35 WHAT WE HAVE LEARNED Below is a collection of representative remarks gathered from ISO certified DNV customers or taken from DNV and industry publications. We consider each one of them a lesson learned. ISO represents the best framework of reference for the regional and international integration of industrial, commercial and environmental practices. They intend to create an entrepreneurial environmental culture and are characterized by permanently accompanying productive processes, which, as a whole, are constantly evaluating the impacts of these activities on the environment. Marco Encalada, OIKOS Corp. Mainstreaming an EMS helps businesses meet their customers needs and, in turn, achieve their own financial goals. It also helps to raise the level of awareness within a business workforce to environmental costs and impacts, many times overlooked because they are difficult to quantify. Russell V. Thornton, DNV, taken from Jan article in Industrial Hygiene News A company seeking to mainstream environmental issues and/or seeking to earn certification to ISO 14001, needs to begin with a strong management commitment to environmental responsibility. Ibid Any company considering implementation of ISO should keep in mind that the standards are tools to be applied as a means to an end. One must first consider the job, the issue, the problem, or the need before selecting the tool. David Huyett, Allied Signal The ISO standard allows the organization to determine the size and nature of the improvements to be made. The organization may identify many significant aspects that impact the environment. However, providing the organization is in compliance with regulatory requirements, it is allowed to determine where and how fast improvements will take place. Timothy Johnson, Toyota As a company integrates an EMS with other management systems within its organization, it will improve its ability to meet customer needs and expectations. Russell V. Thornton, DNV, taken from an August 1998 article in Pollution Equipment News ISSUE 2 REV 1 All rights reserved PAGE 32 OF 38

36 WHAT WE HAVE LEARNED The company had come to believe as early as 1997 that its employees and its customers would prefer to do business with an organization that espouses an environmental awareness. Bin Prasad, Rockwell Automation There has never been a global or even a national standard by which a company could be recognized as an environmental leader. Some companies have been successful through internal standards that involve one or two environmental areas; chemical management for instance, but there are few indicators that recognize leadership across the full range of environmental performance-pollution prevention, design for the environment, management systems, emergency planning, compliance, measurement against quantifiable goals and others. ISO does that for a company, providing a leadership perspective in the eyes of our customers and the public. Scot Frost, Hamilton Standard Aircraft Products The environmental policy must be appropriate to the nature and scale of the organization s activities, products and services. It must include a commitment to continual improvement, pollution prevention and compliance with relevant environmental legislation and regulations. Russell V. Thornton, DNV, taken from Dec article in Quality Digest On a day-to-day basis, ISO increases efficiency, discipline and clarity around environmental issues and related activities. Norm Ingram, BP Exploration (Alaska) Market demand, coupled with respect for nature, creates a strong possibility of a snowball effect as ISO and environmental certification becomes seen as both an obligation and a powerful marketing tool. Beatrice Frey, International Organization for Standardization Organizations should create a checklist applicable to the ISO standard as they plan for registration. They must identify environmental aspects and impacts in a way that is clear to the registrar. Because the registrar will use a checklist, prudent organizations are well advised to do the same. Russell V. Thornton, DNV, taken from Dec article in Quality Digest These questions have led directly to new recycling programs, which are good for the facility and good for the organization. We have seen with compliance and certification to ISO an ac- ISSUE 2 REV 1 All rights reserved PAGE 33 OF 38

37 WHAT WE HAVE LEARNED companying growth in the desire of employees to do things better. Mike Fetsko, Rockwell Automation Pollution prevention as a direct result of the ISO exercise has been surprising, measurable and even cost beneficial. Three specific examples are flared gas reduction, elimination of the use of a scale inhibitor and solid waste reduction. Norm Ingram, BP Exploration (Alaska) The increased awareness surrounding environmental issues by customers and suppliers alike is spurring process industries and other manufacturers throughout the world to look for the best ways to integrate an EMS into their day-to-day operations. Russell V. Thornton, DNV, taken from July 1998 article in Intech ISO standards can play an essential complementary role to regulations, by ensuring good management and compliance; by helping in decision making by consumers, manufacturers, governments and others, and by harmonizing business practices beyond the limits of national and regional borders. Dr. George Cornell, TC 207 chairman The wrong reason to implement ISO is to seek regulatory relief or leniency. An organization might hope to avoid routine Resource and Recovery Act (RCRA) inspections by implementing ISO However the proper motivation for implementing a focused environmental process should be to ensure the organization is ready when the regulators arrive. David Huyett, AlliedSignal We developed our ISO documents to be structured just like our ISO 9001 documents. We exercise document control in the same way. It is important to us that the two systems appear seamless. Ed Budd, Lucent Technologies The cost savings realized by organizations committed to environmental certification have surprised this auditor. Savings were always expected to accompany quality certification, but the magnitude of cost savings connected to environmental certification has surprised everyone. Archie Bice, DNV Waste reductions have been so successful that they have turned into cost savings. Debbie Watson, ABB T&D Company ISSUE 2 REV 1 All rights reserved PAGE 34 OF 38

38 WHAT WE HAVE LEARNED Our company recognizes that environmental performance is fundamental to our business. ISO is a route that sites worldwide can follow to have their environmental management systems externally verified. That is why we sought ISO compliance and certification. Norm Ingram, BP Exploration (Alaska) So that any of us may continue to enjoy the privilege and the benefits of oil and gas exploration and recovery in the coming years, it is indispensable to continue to apply, on a daily basis an appropriate environmental protection. ISO helps a company do just that. Gary Farrell, DNV Ideally (but not a requirement of the standard), an organization should tie objectives and targets to environmental costs and/or potential costs of a nonconformance. Remember, it is the process of setting objectives and targets with its associated discussions that have the greatest benefit to the organization. Russell V. Thornton, DNV ISO provides the discipline and structure to methodically approach environmental issues. Its role in the oil and gas industry will be to enhance the ability to benchmark and adopt best practices across different business assets and with other industries. Norm Ingram, BP Exploration In order to keep the setting of objectives and targets in the proper perspective and in conformance with the ISO standard, an organization should come to realize that the process is a continual one, and one that always takes into account previous steps taken in the development of the EMS. When formulated, objectives must relate to policy, and targets must relate to objectives. Russell V. Thornton, DNV Our goals are no accidents, no harm to people, and no damage to the environment. ISO is the linchpin helping us attain this goal. BPXA ISSUE 2 REV 1 All rights reserved PAGE 35 OF 38

39 WHAT WE HAVE LEARNED It is worth noting that the objectives and targets of the EMS need not be totally implemented at the time of a certification audit, but a company needs to have assembled sufficient evidence to show progress in the pursuit of its goals. A company can gather this evidence by means of an internal EMS audit that provides objective evidence of implementation, along with evidence that objectives and targets are being monitored and measured, and that progress is being tracked according to an established time frame. Russell V. Thornton, DNV The mission is to be the private oil company that produces with the greatest efficiency, and at the same time fully demonstrates its respect for people and the environment. The achievement of this mission is associated with concepts such as full compliance with legislation, prevention of contamination and a continuous improvement of our operations. Maston Cunningham, Occidental Exploration and Production Company Be practical. Refrain from writing elaborate procedures, and avoid issues over which the organization has no control. Clients ISSUE 2 REV 1 All rights reserved PAGE 36 OF 38

40 INTERPRETIVE GUIDELINES TO LIST OF ISO ARTICLES Goal for the 90 s, A Transition to Environmental Excellence, Smith, Gambrell & Russell. Outlook, Spring Managing Environmental Risk. Chemical Processing, October Environmental Risk Management. Practical Loss Control Leadership Revised Edition,1996. Use Practical Checklist to Assess Where Business Stands on Environmental Management, How to Prepare for Certification. BIC, September A Practical Checklist for ISO Quality Digest, December Integrating ISO 1400 with other Management Systems. PIMA s Papermaker, December How and When to Develop ISO Series EMS. Industrial Wastewater, January/February Integrating Customer Requirements with EMS. Environmental Management Report, January Seeking ISO Compliance -A Step-by-Step Guideline. InTech, July Um Check List Pratico para a ISO BQ Qualidada, June Case Study: Rockwell Automation Earns ISO Registration. Pollution Prevention Review, Spring Dealing with Ingredient List Request. Environmental Quality Management, Winter A Practical Checklist for Mainstreaming ISO into your Business. Pollution Equipment News, The Arctic Tundra, the Rainforest, and the Oil Companies, Pollution Prevention on the Front Line. Pollution Prevention Review, Summer ISO 14001: What s all the Fuss About. Environmental Quality Management, Summer Can ISO Play the High Stakes Game? A Tale of Two Petroleum Companies. Environmental Quality Management, Autumn New Relationships: ISO 14001, Lean Manufacturing, and Transportation. Environmental Quality Management, Spring ISO Reaches the Automotive Industry. Environmental Quality Management Volume 10, Number 1, Autumn Understanding the Benefits of TPA and Certification. Environmental Quality Management, Summer ANWR II Plenty of Ammunition in Debate over Drilling. Environmental Quality Management, December 15, ISSUE 2 REV 1 All rights reserved PAGE 37 OF 38

41 INTERPRETIVE GUIDELINES TO LIST OF ISO ARTICLES How Software Improvements can Prevent Pollution. Environmental Quality Management, Winter The Environment, E-Commerce, and Sustainability. Environmental Quality Management, Spring Energy Crisis: Do you have your EMS in Place? Environmental Quality Management, Summer To read these articles in their entirety, please visit the ISO Articles section of our website at ISSUE 2 REV 1 All rights reserved PAGE 38 OF 38

42 DNV Business Assurance Det Norske Veritas is an autonomous, independent foundation with the objective of safeguarding life, property and the environment. The DNV organization comprised of 300 offices in 100 countries with over 10,000 employees. For more information on our services please contact: DNV Business Assurance Phone: (281) Toll-free: 1 (877) Website: ContactUs@dnv.com For more information on our training courses please contact: DNV Academy Phone: (770) Toll-free: 1 (800) Website: , Det Norske Veritas Certification, Inc. All rights reserved.