Workshop CC. Best Management Practices ISO 14001:2015 Revving Up Management Support. Wednesday, March 22, :00 a.m. to 9:15 p.m.

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1 Workshop CC Best Management Practices ISO 14001:2015 Revving Up Management Support Wednesday, March 22, :00 a.m. to 9:15 p.m.

2 Biographical Information Tim W. McDaniel, CIH, CSP, EHS Manager Navistar, Inc Urbana Rd., Springfield, OH Tim started his career with the Regional Air Pollution Control Agency in Dayton, Ohio in 1985 as an inspector and permit writer. After two years he went to work at Navistar, first as a contract consultant and then with Navistar full-time in He was promoted to Environmental Manager and then EHS Manager. During this time Navistar has received awards from US EPA and Ohio EPA for pollution prevention. The Springfield Assembly Plant has been registered to ISO since Tim s current responsibilities include ISO 14001, regulatory participation in Ohio and environmental management at the Springfield Assembly Plant. He also serves on the Clark County Solid Waste Management District Policy Committee and the Clark County LEPC. Tim is a graduate of Eastern Kentucky University with a B.S. In Environmental Resources and he received both an MS and MA from Indiana University in Environmental Science and Ecology, respectively. Jerry Skaggs, PE, CPEA, CP EnMS, Managing Consultant Trinity Consultants Inc Brooktree Road, Suite 103, Wexford, PA cell jskaggs@trinityconsultants.com Mr. Skaggs is a Managing Consultant in the Trinity EHS Performance and Risk Management Business Line program for regulatory compliance and management systems. He has 18 years of auditing experience, and 19 years of environmental consulting, facility operations and environmental programs oversight and management experience. He assists clients in establishing programs and ensuring compliance through auditing of their environmental, occupational health and safety, security, quality, Responsible Care and energy systems. He has conducted over 750 audits of industrial locations aircraft, automotive and vehicle assembly, ceramic, chemical, coatings, electronics, farm machinery assembly, foam, foundry, labeling and closures for wine industry, laboratories, glass, logistics and warehousing, mining, natural gas, non-ferrous metals, paint, paper and pulp, petroleum, plastics, printing, rubber and tire, recycling, rum refining, starch, steel, water and wastewater and wire and cable facilities to various environmental, occupational health and safety, quality, energy, military and bottled water standards. He has held positions of Environmental Business Line Manager, Global Sustainability Program Manager, Environmental Manager and Project Officer.

3 ISO 14001:2015 Revving Up Management Support Tim McDaniel Environmental Manager Navistar, Inc.

4 Outline Part I Getting Ready Management Support Working with Management to define Context and Scope

5 Medium and Heavy Duty Truck Assembly Plant in Springfield Welding, Painting and Assembly 1400 employees Registered to ISO since 2003 Individual registrations at manufacturing sites No corporate registration Not combined with ISO 9001 registration

6 ISO 14001:2015 Countdown Must be registered to 2015 by September, 2018 Currently registered to ISO 14001:2004 Coordinate with your Registrar options to transition Desktop reviews and document reviews by Have some sections audited during regular surveillance audits Have a special audit just to focus on the 2015 changes Registrars expect backlog of last minute requests Plan and coordinate with your Registrar now Extra audit time comes with a charge

7 Getting Ready Study up The Pitch to Management The Big Changes Scope Context Risk based approach

8 Study Up Read and compare Mark up Educate yourself Articles, blogs Online or classroom training Measure the Gap Prepare your presentation to Mgt.

9 How Easy is it to Obtain Management Support? Distractions, Culture, Personalities, Organizational structure, etc. Long term or short term planners Corporate or Locally driven

10 Be Persistent (without whining) Present the need for a special management review Use the side door if needed Elevate if necessary

11 The Pitch Present in a format and time allowance suitable for the audience If you are already ISO registered, document as a management review Be Specific regarding ISO 14001:2015 update How changes affect leadership Requests you are making as a result of changes Budget Working Group Project plan timing, etc.

12 So far First Management Review Presented overview of changes Requested action target date & small group tabled Second Management Review Target date set and small groups identified Small groups meeting Context and Scope Corporate staff direction needed Follow up and again Working group established

13 4.1 Understanding the organization and its context The organization shall determine external and internal issues that are relevant to its purpose and that affect its ability to achieve the intended outcomes of its environmental management system. Such issues shall include environmental conditions being affect by or capable of affecting the organization. No method prescribed in the Standard Choose a process to determine issues Issues and Interested Parties Table Strengths Weaknesses Opportunities Threats (SWOT) analysis May choose to formalize your method as an procedure within your EMS but not required to do so (promotes consistency and easier to follow during audits)

14 5.1 Leadership and commitment Top management shall demonstrate leadership and commitment with respect to the environmental management system by: b) ensuring that the environmental policy and environmental objectives are established and are compatible with the strategic direction and the context of the organization (emphasis added) Need to have top management involved for the EMS to be effective and it helps to demonstrate to the Registrar that they are demonstrating leadership

15 4 Context of the organization Context Needs Expectations Compliance Obligations Scope

16 Top Management Working Group for Defining Context During Management Review the Quality Manager and Paint Manager volunteered Env. Manager prepared before the first meeting examples of how others determine context and list of potential issues During meetings Selected a method to determine context Listed issues first draft then sent it to Corporate for review

17 Issue Nature Relevant Interested Parties 1 New changed External Regulatory authorities regulatory Employees/UAW/WHQ requirements 2 Local community 3 Energy Availability, Clean Energy 4 Corporate values and Culture 5 Solid Waste Management landfill availability flow External External Neighbors/farmers Government agencies WHQ Community (peak usage availability) Risks Opportunities Potential Actions Cost to comply may mean less money for competing projects. Inability to meet the requirements. Legal liability, fines Nuisance (noise, traffic). Environmental incidents Spills Cost Restrictions Energy, Demand cutback at request Internal WHQ Incompatibility of corporate Values with local culture Cost increase Changes in expectations/ requirements External WHQ Community / Solid Waste District Cost increase Lack of choice Closest landfill reaches nears capacity and Improved relation with regulators Classified as minor instead of major Improved relation with local government Cost reduction Enhanced profitability CSR image improved Enhanced image Improved access to market place Improved relation with regulators New products new Investment locally More material recycled or reused. Identification of lega requirements Determination of applicability Implementation of controls Participation with So Waste District, LEPC Community engagement, Outreach to local emergency respond Identification of ene saving opportunities Energy managemen Culture programs Community engagement Working with UAW Returnable containe new recycle or reuse streams

18 SWOT Analysis Helpful Harmful External Internal STRENGTHS OPPORTUNITIES WEAKNESSES THREATS

19 4.2 Understanding the needs and expectations of interested parties The organization shall determine: a) the interested parties that are relevant to the environmental management system; b) the relevant needs and expectations (i.e. requirements) of these interested parties; c) which of these needs and expectations become its compliance obligations. Which leads to Compliance Obligations 2005 version: The organization shall evaluate compliance with other requirements to which it subscribes.

20 Compliance Obligations Greater emphasis than prior standard on nonregulatory obligations Compliance obligations of interested parties include: Regulatory Contractual Voluntary (become compliance when you agree to conform to them) ISO or other registrations EPA or DOE voluntary reduction programs Trade Association codes of practice Commitments to community partners Expectations of customers, neighbors, other third parties

21 4.3 Determining the scope of the environmental management system The organization shall determine the boundaries and applicability of the environmental management system to establish its scope. When determining this scope, the organization shall consider: a) the external and internal issues referred to in 4.1; b) the compliance obligations referred to in 4.2; c) its organizational units, functions and physical boundaries; d) its activities, products and services; e) its authority and ability to exercise control and influence Once the scope is defined, all activities, products and services of the organization within that scope need to be included in the environmental management system. The scope shall be maintained as documented information and be available to interested parties.

22 5.2 Environmental policy Top management shall establish, implement and maintain an environmental policy that, within the defined scope of its environmental management system (emphasis added)

23 Top Management Working Group for Defining Scope During Management Review the HR Manager and Controller selected Env. Manager prepared before the first meeting list of activities and areas on Navistar property with questions directed to role of Plant Top Management versus other Navistar Management not at the plant During meetings Review property areas and organizational responsibilities of Top Management First draft of Scope, sent to Corporate Environmental for review

24 Scope What s in, what s not? What has changed? 2005: If a part of an organization is excluded from the scope should be able to explain (Annex A of 2005) 2015: Once the scope is defined, all activities, products and services of the organization within that scope need to be included in the ems 2015: Factual and representative statement should not mislead interested parties 2015: Must be available to interested parties

25 Physical Boundaries Separate operational unit Leased farm land Leased farm land After manufacturing and drive away company Navistar owns about 500 acres Two operating units Leased farmland controlled by World Headquarters

26 Organizational Boundaries Two operating units Report to different Directors at World Headquarters SAP plant manager has some oversite for TSC. Some environmental management is shared (TRI reporting, Stormwater permitting) others are not (Air permit, SPCC plans, waste ID numbers) SAP and TSC report to two different directors, neither in Springfield. Other Corporate functions personnel reside at facility Operations Assembly Plant Plant Mgr. Maintenance World Headquarters Truck Service Center Manager Operations

27 Dec Jan Feb Mar No change required

28 Next steps Finalize date with Registrar Participate on Corporate work group for common approaches Updated corporate procedures (Compliance obligations) Life cycle of products (What belongs to manufacturing) Opportunity to hit the reset button What made sense in 2003 may not now. Start over with processes and procedures if I want to parallel systems until I am ready to go live.

29 Conclusion ISO 14001:2015 Provides a Great Opportunity to Engage Top Management Time is running out, don t delay getting started. New elements in the Standard require more input and direction from Top Management Don t do all the work for them Getting the Context and Scope right is critical to the success of the EMS

30 ISO 14001:2015 Nuances of the Revised Standard Jerry Skaggs, PE, CP EnMS, Managing Consultant EHS Performance and Risk Management March 21-22, 2017 Cincinnati, OH

31 Introduction The revised ISO 14001:2015 standard has a number of new requirements and nuances that need to be understood. The approach uses the High Level Structure to allow for integration with other standards. The following discussion is on the major differences or changes in the standard.

32 Clause 4.1 Organization and its Context What issues can affect your EMS both positively or negatively? How do changes affect your EMS? Understanding your context sets the stage for your EMS!

33 Clause 4.2 Needs and Expectations What interested parties are relevant? What are their needs? Do these become obligations?

34 Clause 4.2 Needs and Expectations Relevant Interested Parties Needs Obligations

35 Clause 5.1 Leadership Top Management demonstrates leadership and takes accountability! Directs and supports persons to contribute. Supports other leadership roles to demonstrate their leadership.

36 Clause Planning Action Plan actions to address significant aspects, compliance obligations, risks and opportunities. How to integrate actions into EMS or business processes Consider multiple options

37 Clause 7.5 Documented Information Documents and records are addressed as documents Create, update, and control all documents

38 Clause 8.1 Operational Planning Life cycle perspective: Controls Procurement Communicate to providers

39 Clause 8.1 Operational Planning (cont d) Use End of Life Treatment Transportation/ Delivery Disposal Impacts

40 Clause 10.2 Nonconformity and Corrective Action Concept of Preventive Action deleted Determine if similar nonconformities exist or could occur

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