IEMA NE0311E. EMS an introduction S O U T H E R N. S O U T H E R N Consulting. Principles of a Deming management system. Check.

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1 IEMA NE0311E EMS an introduction Principles of a Deming management system 2

2 Structure of an EMS Manual Procedures Work Instructions Records Site Issues Task Issues Policy Objectives Targets Programmes Legal Compliance Prevention of Pollution Continual Improvement 3 Other Management Systems Quality ISO 9000 series, ISO 16949, ISO 27000, Health & Safety HSG65, BS 8800 & OHSAS Environmental ISO series, BS 8555, EMAS, PAS 99, PAS 2010, BS EN CSR ISO 26000, GRI, 4

3 ISO Management review 1. Policy 2. Aspects & impacts 3. Legal & other requirements 4. Objectives, targets a& management plans 12.Monitoring & measuring 13.ing compliance 14.Nonconformance 15.Records 16.Audit 5. Management structure 6. Training 7. Communications 8. cumentation 9. cument Control 10.Operational control 11.Emergency plans 5 BS8555 Phase 1 Phase 2 Phase 3 Phase 4 Phase 5 & 1. Audit programme 2. Nonconformance etc 3. Management review 4. Improve performance 5. Improve EMS 1. Commitment 2. Baseline assessment 3. Draft Policy 4. Develop Indicators 5. Draft EMS 1. Management structure 2. Training etc 3. Communications 4. cumentation & records 5. Emergency plans 6. EMS indicators 1. Legal requirements 2. Other requirements 3. compliance 1. Aspects & impacts 4. On-going compliance 2. Approve Policy 5. Develop compliance 3. Objectives & Targets indicators 4. Performance indicators 5. Develop management plan 6. Operational controls 7. Launch Policy, Objectives & targets and indicators 6

4 EMAS Goes further than ISO Initial Review Applies to: industrial activities local authorities SMEs Requires: Environmental Statement Initial Environmental Review Public environmental statement Dialogue with the public Employee involvement External verification 7 Policy Appropriate to the nature, scale and environmental impacts. Commitment to continual improvement and pollution prevention Commitment to comply with legal and other requirements which relate to its aspects Framework for reviewing objectives and targets cumented, implemented, maintained Communicated to all persons working for & on behalf of the organization Available to public 8

5 Exercise 1 Write the outline of an environmental policy Include the three commitments What positive messages should be included? Where does authority for the policy come from? What makes a good policy? 9 ning the EMS 10

6 Identifying Environmental Impacts and Aspects What does ISO require? How can an organisation identify the issues? How can an organisation prioritise? 11 Definitions: Aspects and Impacts Environmental Aspect An element of an organization s activities or products or services that can interact with the environment Cause Environmental Impact Any change to the environment whether adverse or beneficial, wholly or partially resulting from an organization s environmental aspects Effect Managed Measured 12

7 Environmental Aspects Direct or Indirect? Positive or negative? Significant? Normal / Abnormal / Emergency Conditions Past, Current and ned ivities 13 How to Identify Aspects Many different approaches You must: Identify all the issues Allow management to prioritise the most significant issues 14

8 Look at Each ivity in Detail Breakdown the organisation into a series of activities/functions Follow the flow of materials through the organisation Emissions to air Noise Waste heat Raw materials Energy Water Process Wastes Product & packaging By-products Process effluent Wasted water Run-off 15 Raw Material Conversion Can we: Identify the total number of holes? Gather data regarding the nature and extent of the leaks? 16

9 Identifying Significance If its significant; it needs to be managed Need to prioritise resources and time & focus on the important issues Need repeatable methods to identify and determine significant aspects 17 Determining Significance All identified aspects Significant aspects Trivial aspects significance criteria big fish minnows 18

10 Significance Criteria There is not prescribed methodology Common criteria include: Is the aspect governed by legislation? Is the aspect sensitive (a nuisance)? Is the aspects large in terms of volume or cost? es the aspect pose an unacceptable risk? 19 Risk Hi Lo f harm Hi Establish risk before any controls are in place Measure risk again after controls have been applied 20

11 Things to - Aspects that there is a procedure to cover the identification of aspects under the control of the organisation and under its influence (e.g. pollution caused by a supplier) the impacts relating to resource usage and pollution issues are both covered that the past, current and planned future activities are considered that impacts under normal and abnormal conditions are identified that significant aspects are determined using criteria which includes degree of damage to the environmental, concerns of the community and legal obligations that the procedure provides a mechanism for keeping the information up-to-date from the results of audits, complaints, changes in legislation and other relevant data that all significant aspects are addressed through objectives and targets, operational control, monitoring and measurement or emergency plans the procedure is being used Observe all areas to ensure no aspects/impacts have been missed Observe all areas to identify possible abnormal and emergency situations and check these have been identified 21 Structure of an EMS Significance Manual Procedures Work Instructions Records Site Issues Task Issues Policy Objectives Targets Programmes Legal Compliance Prevention of Pollution Continual Improvement 22

12 Objectives & Targets Objectives and Targets must be allocated against significant aspects Also consider legal, technological, fiscal, operational and business requirements Consistent with policy SMART S ignificant M easureable A chievable People Skills Money Time R esponsibility T ime-based 23 Programmes The who how by when New/modified developments & activities 24

13 Things to : Objectives, EMP objectives and targets are set on a regular basis targets can be measured and acceptability limits have been established objectives link to policy and consideration is given to significant aspects, legal requirements or views of interested parties targets relate to objectives there are sufficient details in the programme to ensure that the objectives and targets will be achieved that responsibilities have been allocated that progress towards the achievement of targets is being reviewed and that appropriate action is being taken that individuals have been made aware of and understand their roles and responsibilities 25 Legal and Other requirements In addition to legislation Local agreements with neighbours Voluntary standards / codes of practice Directives from corporate centre 26

14 Things to - Legislation the procedure identified all applicable environmental legislation and regulations, permits and consent levels etc. and that these are linked to environmental aspects the procedure considers other requirements to which the organisation subscribes e.g. code of practice, requirements of corporate policy/objectives and that these are linked to environmental aspects that all areas of the business are considered that there is a method available for keeping the information up-to-date awareness of those responsible for ensuring compliance that the procedure ensures distribution of the information and action to be taken when non-compliance is identified how the organisation ensures compliance with legislation, in practice records exist to demonstrate compliance with legal limits 27

15 Resources, Roles, Responsibilities & Authority Senior managers to ensure EMS is successful by providing: Authority Leadership Adequate resources Appoint a Management Representative 29 Things to : Roles & Responsibilities that the roles are defines & understood that reporting mechanisms are known that a management representative has been appointed that roles of committees, task forces etc. are defined that all elements of the system are covered e.g. legislative compliance, actions in emergencies, auditing that changes in responsibilities are updated in the documentation that the Environmental Management Representative is undertaking the tasks required by ISO

16 Competence, Training & Awareness Identify training needs & develop plan Train staff appropriate to their job Staff to be aware of : importance of the policy relevant significant aspects need to follow procedures what happens if these are not followed Staff shall to be competent 31 Exercise 2 Using the PDCA Cycle: write bullet points outlining actions necessary to plan, deliver and record environmental training to a workforce. 32

17 Excerpt: ISO 14001, The organization shall ensure that any person(s) performing tasks for it or on its behalf that have the potential to cause a significant environmental impact(s) identified by the organization is (are) competent on the basis of appropriate education, training or experience, and shall retain associated records. The organization shall identify training needs associated with its environmental aspects and its environmental management system. It shall provide training or take other action to meet these needs, and shall retain associated records. The organization shall establish, implement and maintain a procedure(s) to make persons working for it or on its behalf aware of a) the importance of conformity with the environmental policy and procedures and with the requirements of the environmental management system, b) the significant environmental aspects and related actual or potential impacts associated with their work, and the environmental benefits of improved personal performance, c) their roles and responsibilities in achieving conformity with the requirements of the environmental management system, and d) the potential consequences of departure from specified procedures. 33 Things to - Training the effectiveness of the procedure that training needs have been considered for all who may have significant impact on the environment (including contractors) that training programmes have been scheduled to ensure competence of all staff whose activities may have a significant impact on the environment criteria have been set and used for determining competence awareness programme covers specified items emergency preparedness and response training awareness of employees that training is maintained that new employees/contractors are trained training records 34

18 Communications Internal communication between all levels and functions Receiving, documenting and responding to relevant communication from external interested parties. Consider processes for external communication on significant aspects 35 Things to - Communication the procedure deals with two-way internal communication that procedure covers external communications with interested parties e.g. suppliers, contractors, neighbours, regulatory authorities that a decision is made on external communications regarding significant aspects and is dealt with by procedure or recorded elsewhere with reference in procedure that corrective and preventive action is taken when communication received about complaints or unacceptable situations or areas for improvement, or other concerns of interested parties procedure cross references to emergency situations that environmental performance is adequately communicated internally understanding of procedure, responsibilities, and actions of employees that electronic communications have been recorded and dealt with that verbal communications have been recorded and dealt with 36

19 EMS cumentation & cument Control Top level management manual required (mirror clauses) - use as a signpost cument control as per ISO 9000 paper or electronic files 37 Things to - cumentation the information explains the scope of the EMS and its main elements that related documents are cross-referenced in the description that the description is clear and understandable the distribution of procedures/documents is adequate to ensure effective functioning of the EMS that the procedures are being followed awareness of action by employees that records are not amended without authorisation 38

20 Operational Control How to carry out tasks in a manner that: Protects the environment Maintains compliance Staff, Suppliers and Contractors 39 Exercise 3 Procedures should address the policy requirements for legal compliance and environmental protection. Write bullet points for a procedure to wash a small car by hand Go through the steps What are the legal issue Establish how to do the job in a way that protects the environment 40

21 Excerpt: ISO 14001, The organization shall identify and plan those operations that are associated with the identified significant environmental aspects consistent with its environmental policy, objectives and targets, in order to ensure that they are carried out under specified conditions, by a)establishing, implementing and maintaining a documented procedure(s) to control situations where their absence could lead to deviation from the environmental policy, objectives and targets, and b) stipulating the operating criteria in the procedure(s), and c) establishing, implementing and maintaining procedures related to the identified significant environmental aspects of goods and services used by the organization and communicating applicable procedures and requirements to suppliers, including contractors. 41 Things to - Operational Control that all necessary operational control procedures exist including those required for support services, e.g. design, purchasing etc.(if deemed by the organization to be significant) the procedures contain the operating criteria the procedure to identifying significant environmental aspects takes into account goods and services used by the organisation that communication of information to suppliers and contractors is considered in operational control procedures or addressed by other means appropriateness of and conformance with all operational control procedures at least once during an audit cycle appropriateness of the operating criteria on action taken when results are outside the criteria on awareness and understanding of those operating the procedures maintenance activities if not covered by operational procedures control of contractors and their understanding of their role in the EMS training awareness of some operators and contractors 42

22 Emergency Preparedness and Response Establish and maintain procedures to identify potential for, and respond to, accident and emergency situations And for preventing and mitigating the environmental impacts that may be associated with them Mini PDCA cycle 43 Things to - Emergencies that procedure covers different types of level of emergencies that the procedures protect live, property and the environment that the complexity is in line with the potential damage or risk that the procedures identify authority for action and this is reflected in the structure and responsibilities that the procedure links to training that the procedure links to communications that the emergency procedures are practical and easy to follow that the list of key personnel/telephone numbers etc. is up-to-date that training and drills have been conducted the awareness of employees that equipment works e.g. fire alarms, water through showers, hoses etc. fire extinguishers have been checked that the procedure is reviewed the system for recording incidents/accidents/emergencies actions are taken after incidents/accidents/emergencies to revise plans and procedures if necessary internal and external communication plans 44

23 Monitoring and Measurement Performance - against defined criteria / KPIs Compliance permits, consents, conditions, etc. Targets against programme and outcomes : Calibration Certificates Registers User manuals Notes / records Calculations & assumptions 46

24 Things to - Monitoring that all key characteristics are covered by the procedure that frequency of monitoring and measurements are detailed there is a system to verify the validity of the results a sample of monitoring records appropriateness of procedure, acceptability criteria and frequency of monitoring and measurement against results that records are not amended without explanation and authorisation calibration process that monitoring and testing equipment is protected against damage or tampering on actions taken if results are outside acceptability criteria awareness of procedures by relevant personnel communication of performance results (4.4.3) 47 Evaluations of Compliance Procedures to periodically evaluate compliance with: legal requirements other requirements Keep records of results 48

25 Things to - Evaluation of compliance the procedure identified all applicable environmental legislation and regulations, permits and consent levels etc. and that these are linked to environmental aspects the procedure considers other requirements to which the organisation subscribes e.g. code of practice, requirements of corporate policy/objectives and that these are linked to environmental aspects that all areas of the business are considered that there is a method available for keeping the information up-to-date how the organisation ensures compliance with legislation, in practice. records exist to demonstrate compliance with legal limits whether actions are taken if outside acceptable limits awareness of those responsible for ensuring compliance 49 Non-conformance and Corrective &Preventive ions Responsibility and authority for: handling and investigating non-conformance for initiating, completing and signing-off corrective and preventive actions Reasonable number for the size and complexity of operations? Proportional to potential impacts and reasonable timeframe? ively managed and pursued? Records up-to-date? 50

26 Things to - Non-conformances that the procedure defines responsibilities and authorities for investigation and action that the procedure includes: identifying the cause of the non-conformance identifying and implementing the necessary corrective action implementing or modifying controls necessary to avoid repetition recording any changes in written procedures resulting from the corrective action that the procedure can be applied to a wide range of activities e.g. complaints. monitoring and measurements, audits that there is a follow-up mechanism to ensure: action is taken within agreed timeframe effectiveness of action that the procedure is used in all relevant situations on follow-up mechanism on action taken when preventative action is not implemented within agreed timeframe on reporting of non-conformance and subsequent action on the awareness of the procedure by relevant personnel that action cross-links to other parts of the system e.g. up-date aspects, complaint communication, document control 51 Control of Records Identification, maintenance and disposition of environmental records Clear and legible Easily retrievable Include training records and the results of audits and reviews 52

27 Things to - Records that all records used in the system are identified that retention times have been established and recorded that control procedure is established (4.4.5) that new records e.g. from objectives and targets, new employees, are incorporated in the system that records are easily retrievable, legible, protected against damage or loss and are not amended the retention time for records on communication of information from records on action if there is a non-conformance on awareness of generation and control of records by relevant personnel the records are providing relevant information whether records have been amended the back-up system for electronic data 53 Internal Audit Periodic EMS audits to: assess if the EMS conforms to planned arrangements assess if the EMS has been properly implemented and maintained provide information to management Are they effective? Are the right questions asked Are answers challenged Certification bodies assess the effectiveness of internal audits to determine how long they need to spend on assessments 54

28 Things to - Audits that responsibility and requirements includes use of trained auditors independent of activity audited that identification of opportunities for improvement is included in objectives of the audit that programme reflects environmental importance of activity and results of previous audits training of auditors auditors are independent of activity audited audit reports and evidence of audit activities that schedule covers all clauses of standard, all procedures and all activities at least once in the audit cycle performance against programme methodology used that opportunities for improvement are sought organisation and control of audits that non-conformance arising from previous audits are checked reports of results of audits are provided to top management (this usually occurs during the management review meetings) 55 Management Review Review the suitability of the EMS Review measurement results Review need for changes Reset objectives and targets 56

29 Things to - Management Review that the review is conducted by top management that the purpose of the review is to identify and implement improvements in the EMS that the review considers at least items a) to h) in 4.6 of the standard that the review follows a procedure or guidance in the manual that observations, conclusions and recommendations are documented for necessary action 57 Conclusion 3 policy principles SMART objectives Mini PDCAs for training, operational control, emergency preparedness and nonconformities Keep up to date Feedback information 58

30 Night, night 59