ISO Monitoring and Measurement Nonconformance and Corrective and Preventative Action

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2 ISO Monitoring and Measurement Nonconformance and Corrective and Preventative Action

3 4.5.1 Monitoring and Measurement The organization shall establish and maintain documented procedures to monitor and measure, on a regular basis, the key characteristics of its operations and activities that can have a significant impact on the environment. This shall include the recording of information to track performance, relevant operational controls and conformance with the organizations environmental objectives and targets.

4 4.5.1 Monitoring and measurement 1. Identify key characteristics and develop process for tracking to show EMS performance. 2. Develop method for monitoring conformance with operational controls. 3. Develop method for tracking progress towards achievement of objectives and targets.

5 4.5.1 Monitoring and measurement 1. Identify key characteristics of operations and activities that can have significant impact and track a) Not just for aspects of objectives and targets but for all significant aspects/impacts. b) Provides early warning problems with specific aspects and impacts. c) Provides baseline for sig. aspects/impacts that may have future objectives and targets d) Intent is to go beyond management simply asking whether we were fined last quarter

6 Key Characteristics Surface water impact Air quality impact Natural resources impact Local aesthetics Landfilling Wastewater volume, pollutant loading, # and volume of spills, water quality analysis, violations Air emission, chemical consumption, air quality analysis Raw material, water, energy consumption noise level, traffic volume Solid waste volume, recycling volume

7 Total Phosphorus Jan-99 Jul-99 Feb-00 Aug-00 Mar-01 Sep-01 Apr-02 Month 6,000 4,000 2,000 0 Electrical Usage Kilow atts Used per Million Gallon Treated Concentration (mg/l) kwh/mg Jan Mar May Jul Sep Nov Chlorine Usage Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Month Biosolids Nickel lbs/mg Jan-98 Jul-98 Jan-99 Jul-99 Jan-00 Jul-00 Jan-01 Jul-01 Mo nt h

8 4.5.1 Monitoring and Measurement Direct Measurement Measuring a critical quantity or quality Indirect Measurement Filling out of forms during the process indicating tasks were performed correctly Periodic observations of tasks to ensure that it is being properly conducted Periodic interviews with personnel to ensure that they are aware of requirements

9 4.5.1 Monitoring and Measurement 2. Monitor conformance with operational controls a) Provides evidence to management that operational controls are being followed b) Typically relies on indirect measurements techniques Examples: observance performing procedure, interviews with operators during internal audits, review completed checklists or forms.

10 4.5.1 Monitoring and Measurement 3. Track progress towards achieving objectives and targets a) Provides evidence to management that progress is being made on objectives and targets b) Relies on direct and indirect measurement Examples: actual performance indicators, report by staff on program action steps, resulting documents, trainings, etc..

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14 4.5.1 Monitoring and measurement 1. Identify key characteristics and develop process for tracking to show EMS performance. 2. Develop method for monitoring conformance with operational controls. 3. Develop method for tracking progress towards achievement of objectives and targets.

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17 4.5.1 Monitoring and Measurement Monitoring equipment shall be calibrated and maintained and records of this process shall be retained according to the organizations procedures.

18 4.5.1 Monitoring and Measurement Monitoring equipment used to measure the identified key characteristics will need to be calibrated. May develop separate procedure for this requirement or include in other procedures. Typically a listing of equipment requiring calibration, reference of calibration method, frequency, and responsible party. Is calibration done internally or externally

19 4.5.1 Monitoring and Measurement The organization shall establish and maintain a documented procedure for periodically evaluating compliance with relevant environmental legislation and regulations.

20 4.5.1 Monitoring and Measurement A documented environmental compliance program should address at minimum Audit scope (areas to cover) Audit responsibilities Audit process (training, team structure) Audit schedule Audit reporting (format, distribution, follow-up)

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23 Relationship of to other elements requires procedures for control of activities that can have significant impact and require the establishment of objectives and targets and programs requires the identification of legal and other requirements requires the measurement of effectiveness of those controls requires the organization to track progress towards achievement requires periodic evaluation of compliance with requirements

24 4.5.2 Nonconformance and corrective and preventative action The organization shall establish and maintain procedures for defining responsibility and authority for handling and investigating nonconformance, taking action to mitigate any impacts caused and for initiating and completing corrective and preventative action.

25 4.5.2 Nonconformance and corrective Example nonconformance Inadequate procedure: Storm drain not sealed prior to acid unloading. Unloading procedure does not cover action Procedure not followed: scrubber maintenance is not being conducted as required (3 in 5 months) Failure to review aspects and impacts: Responsible party did not evaluate new raw material and preventative action Potential Outcome Release to environment Shut downs Releases Permit Violations Improper handling resulting in contaminati on Method of Discovery Actual release Routine Inspection EMS Audit Scrubber failure Routine inspection EMS audit EMS audit Corrective Action Place berm or other method of control at drain entrance Conduct maintenance to get back on schedule Complete aspect and impact analysis of new material Preventative Action Revise procedure Conduct Retraining Make supervisor accountable Replace pump Require all new chemical purchases to be reviewed by EE

26 4.5.2 Nonconformance and corrective and preventative action Clause essentially requires a systematic action plan to fix problems identified during monitoring and measurement and EMS audits. Need to consider developing a corrective and preventative action form to track and control activities to correct or prevent major non conformances and determine responsibilities and authorities.

27 Nonconformance Major or Minor

28 Monitoring and Measuring External Comunication Accident / Near Miss Routine Inspections Regulatory Agency Inspection Identify Nonconformance EMS Audit NO Evaluate & Record Major or Minor YES Root cause Corrective Measure Evaluate & close Resolve Issue No Additional Action Required YES Management Satisfied NO

29 4.5.2 Nonconformance and corrective and preventative action Any corrective and preventative action taken to eliminate the causes of actual or potential nonconformances shall be appropriate to the magnitude of the problems and commensurate with the environmental impact encountered.

30 4.5.2 Nonconformance and corrective and preventative action The organization shall implement and record any changes in the documented procedures resulting from corrective and preventative action.

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