iso 14001: 2015 - docs and records

ISO 14001:2015 Overview

Charlie [email protected](919) 515-4266

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What is ISO 14001?

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4.2 Environmental Policy

4.6 Management Review

4.5 Checking4.5.1 Monitoring and Measurement

4.5.2 Evaluation of Compliance

4.5.3 Nonconformity, Corrective Action and Preventive Action

4.5.4 Control of Records

4.5.5 Internal Audits

4.3 Planning4.3.1 Environmental Aspects

4.3.2 Legal/Other Requirements

4.3.3 Objectives, Targets and Programs

4.4 Implementation & Operation4.4.1 Resources, Roles, Responsibility & Authority

4.4.2 Competence, Training & Awareness

4.4.3 Communication

4.4.4 Documentation

4.4.5 Control of Documents

4.4.6 Operational Control

4.4.7 Emergency Preparedness/Response

Continual Improvement

ISO 14001 - 20044.1 General

Red = Identifying Env. IssuesBlue = Managing Env. Issues

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4 Context of Organization4.1 Understanding the organization and its context4.2 Understanding the needs & expectations of interested parties4.3 Determining the scope of the EMS4.4 Environmental management system

8 Operation8.1 Operational planning and control8.2 Emergency preparedness and response

5 Leadership5.1 Leadership and commitment5.2 Environmental policy5.3 Organizational roles, responsibilities and authorities

6 Planning6.1 Actions to address risks and opportunities

6.1.1 General6.1.2 Environmental aspects6.1.3 Compliance obligations6.1.4 Planning action

6.2 Environmental objectives and planning to achieve them6.2.1 Environmental objectives6.2.2 Planning actions to achieve environmental

objectives

Continual Improvement

ISO 14001 - 2015

7 Support7.1 Resources7.2 Competence7.3 Awareness7.4 Communication

7.4.1 General7.4.2 Internal communication7.4.3 External communication

7.5 Documented information7.5.1 General7.5.2 Creating and updating7.5.3 Control of documented

information

9 Performance evaluation9.1 Monitoring, measurement, analysis and evaluation

9.1.1 General9.1.2 Evaluation of compliance

9.2 Internal audit9.2.1 General9.2.2 Internal audit program

9.3 Management review

10 Improvement10.1 General10.2 Nonconformity and corrective action10.3 Continual improvement

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How Does ISO 14001-2004 Work?

Significant Aspects

4.3.1

What are the Environmental Issues?

Legal Requirements

4.3.2

Potential Emergencies

4.4.7

How are they managed?

Targets & Objectives

4.3.3

Training Programs

4.4.2

Operational Controls

4.4.6

Emergency Response Plans 4.4.7

How are they checked?

EMS Audits4.5.5

Compliance Evaluations

4.5.2

Emergency Drills4.4.7

How are “issues” fixed and improved?

Corrective / Preventive

Action 4.5.3

Management Review

4.6

Monitoring & Measurement

4.5.1

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How Does The New ISO14001-2015 Work?

Significant Aspects

6.1.2

Legal Requirements

6.1.3

Potential Emergencies 8.2 & 6.1.2

Targets & Objectives6.2.1/6.2.2


8.1

Emergency Response Plans 8.2

EMS Audits9.2


9.1.2

Emergency Drills8.2

Corrective / Preventive Action 10.1

Management Review

9.3


9.1.1

Risks & Opportunities

- General6.1.1

Planning Action

(to Address 6.1)6.1.4

Competence 7.2 &

Awareness7.3

Env requirements

for Procurement

Env Req’ts for the Design & Development

of product/ service

Env Aspects w/ Product Life

Cycle (transportation,

end of life, disposal)6.1.2, 8.1

What are the Environmental Issues?

How are they managed?

How are they checked on?

How are “issues” fixed and improved?

Planned or Unplanned Changes

6.1.2

Outsourced Processes

8.1

Communicate Req’ts to- outsourced processes- contractors- other (re: stages of LC)

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The New ISO 14001 Standard

• The revised ISO 14001 was published on Sept 2015.

• Some changes are:• From 5 pages to 11 pages• Elements (clauses) from 18 to 32• Structure same as ISO 9001 & other

Management System Standards (MSS) incorporating High Level Structure format > Context, Leadership, Planning, Support, Operation, Performance, Improvementht

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http://www.iso.org/iso/home/store/catalogue_tc/catalogue_detail.htm?csnumber=60857

http://www.iso.org/iso/home/store/catalogue_tc/catalogue_detail.htm?csnumber=60857

The New ISO 14001 Standard (1 of 2)

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The New ISO 14001 Standard (2 of 2)

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http://asq.org/quality-press/display-item/?item=T986Ehttp://www.iso.org/iso/home/standards_development.htm

http://asq.org/quality-press/display-item/?item=T986E

http://www.iso.org/iso/home/standards_development.htm

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8 Big Changes (1 of 3)

1) 4.1- Understanding the Organization and its context - by determining – A) External circumstances – political, regulatory, international, national, etc. B) Internal characteristics (i.e., strategic direction, culture, capabilities) C) Environmental conditions – that could affect the organization (climate, natural resource availability, etc.)

2) 4.2 - Understanding the Needs of Interested Parties. Who are the interested parties relevant to the EMS, What are their needs and expectations

3) 5.1 - Leadership and Commitment. Top Management must demonstrate its commitment to the EMS for a list of items, none of which are required to be documented or recorded (but it may help)

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4) 6.1.1 - Actions to address Risks and Opportunities – Must be “determined” on issues surrounding “context” as per 4.1 and “interested parties” as per 4.2, as well as for aspects and legal requirements

5) 6.1.2 - Environmental Aspects of Products – Considering life-cycle perspective. (i.e., environmental issues associate with design, use, end of life and disposal

6) 8.1 - Operational Controls - for product design and development for life cycle stages AND provide information about potential significant impacts on product delivery, use, end-of-life and disposal AND Environmental requirements for purchasing

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7) 10.2 - No Preventive Actions formally required (it’s all corrective action)

8) 7.5 - No mention of the word records (it’s all documented information)

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4.1 Understanding the organization and its context (1 of 4)

• Determine the internal and external issues relevant to the EMS.

• Include environmental conditions being affected or capable of affecting the organization

THIS IS - A HIGH LEVEL UNDERSTANDING- INCLUDE IMPORTANT ENVIRONMENTAL TOPICs- INCLUDE CHANGING CIRCUMSTANCES

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Understanding Aspects & Impacts is “extremely one dimensional” when compared to Understanding the Context if the organization*.

Understanding … includes the organization’s- direct and indirect environmental consequences- legal requirements- effects on your stakeholders by the EMS

* John Nolan (google search)

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Examples include:Env. Conditions – Climate, Air & Water Quality, Land Use, existing contamination, natural resource availability, biodiversity, etc.

External cultural, social, political, legal, regulatory, financial, technological, economic, natural and competitive circumstances, whether international, national, regional, or local

Internal characteristics or conditions of the organization such as activities, products and services, strategic direction, culture and capabilities (i.e. people, knowledge, processes and systems

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4.1 What does it look like ? (4 of 4)

Document the context in the EMS manual – or document meeting minutes where these issues are discussed (i.e. Management Review, etc.)

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4.2 Understanding the needs and expectations of interested parties

• This appears to be a duplicate requirement for listing compliance obligations (i.e. interested parties = regulatory agencies)

• Interested parties could be sponsors of voluntary requirements (contractual, trade associations, etc.)

• Corporate Management• Community Members• Others

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4.3 Determining the Scope of the EMS

• Similar to the 2004 standard (4.1 General Requirements)

• Consider• External and internal issues (as per 4.1)• Compliance obligations (as per 4.2)• Organizational units, functions and physical

boundaries• Activities, products and services• Control and Influence

How many times will we reference 4.1 and 4.2 in this standard ?

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4.4 Environmental Management SystemA general, overall requirement stating the org. must :

•- establish, implement maintain and continually improve an EMS that meets ISO 14001•- consider the knowledge gained in

• 4.1 - Understanding the organization and its context

• 4.2 – Understanding the needs and expectations of interested parties

References 4.1 and 4.2 - #2

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5.1 Leadership and CommitmentTop Management shall demonstrate leadership and commitment by

- taking accountability for the effectiveness of the EMS- ensuring policy and objectives are established- integrating EMS with business plan- ensuring resources- communicating the importance of EMS- ensuring the EMS meets "intended outcomes"- directing and supporting persons in the EMS- promoting continuous improvement- supporting other management roles

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5.2 - The Three Pillars (commitments) of Your Environmental Policy:

Company Policy Statement Compliance

Protection of the Environment Continual Improvement

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• Roles, responsibilities, and authorities must be • Assigned, documented, communicated• Determine and provide resources needed (7.1)

• Top Management must assign responsibilities for reporting on the performance of the EMS

5.3 / 7.1 - Organizational Roles, Responsibilities, and Authorities / Resources

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6.1.1 Actions to address risks and opportunities

Determine risks and opportunities associated with:- aspects - legal obligations- consider 4.1 and 4.2 (Ref’s - #3)- Determine potential emergencies (to be used in 8.2)

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6.1.2 Environmental Aspects & Impacts

Air EmissionsAir Pollution

StormwaterWater Pollution

PackagingLand Fill Space

TransportationAir Pollution

Metal ChipsMinerals Depletion

Energy UseFossil Fuel Depletion

WastewaterWater Pollution

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6.1.2 Significant Aspects6.1.2

… by using established criteria…

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6.1.2 Env. Aspects – Life Cycle… determine the environmental aspects … considering life cycle perspective…for activities, products and services THAT IT CAN CONTROL OR INFLUENCE …taking into account:- changes (MOC)- emergencies

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6.1.3 – Compliance Obligations

• Determine compliance obligations• Have access to them• Determine how they apply• Take them into account

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Example Legal Requirements

Legal Req’t Code AspectHazardous Waste Management

40 CFR 261 Haz Waste Disposal

Air Quality Permit 15A NCAC 2Q.0100

Air Emissions

Storm Water Exclusion

15A NCAC 2H.0126

Stormwater Run-off

Municipal Wastewater

Thomasville Code

Wastewater Discharges

6.1.4 – Planning Action

• Significant environmental aspects• Compliance obligations• Risk and opportunities

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Organization Shall Plan:

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Objectives—Result to be Achieved:

- Consistent with Environmental Policy- Considering Sig Aspects, Legal Req’ts &

Risks/Opportunities

Planning Actions (Programs): What will be done, Resources, responsible party & Due Date

6.2.1 & 6.2.2 – Objectives and

Planning Actions

Revision Date:

1 Jun-03

2 Aug-03

TitleMaintenance

Maintenance

2 - 3

1 - 2

Noise Minimization 2/20/2003

Date Completed

Date Due Date Completed

ResponsibilityTarget(s)

Objective:

Project Plan Title:

Decrease noise to below 80 dBA

Significant (S) / Legal (L) / Emergency (E)Impact(s):Aspect

Noise (from Compressor) Environmental Noise S/L

Build Wall

Qet Quote on Compressors

Investigate replacing all other "High Noise" Compressors

1 - 4

2 - 2

Employee

Select Vendor, Get apporved and Award Bid

Roy

Roy

Build wall around work area.Purchase low noise compressors.

Task #

1 - 1

Activity/ Product or Service

Maint. Work Area

2 - 1

Employee

Install Compressors

1 - 3

Date Due

Select Vendor, Get apporved and Award Bid

Qet Quote on Wall

Other Tasks - DescriptionResponsibility

Title

2 - 4

Example Objective & Plan

The term “Target” Not used.

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7.2 & 7.3 Competency and Awareness

7.2: Determine1) the necessary competence2) ensure competence3) training needs4) take action to acquire competency

7.3: Ensure persons are aware of1) the environmental policy2) Significant Aspects of their work3) Benefits of improved personal performance4) Implications of NOT conforming to the EMS (including compliance obligations)

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Specifying Environmental Training Needs

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7.2 & 7.3 - Competency and Awareness

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7.4, 7.4.2, & 7.4.3 - Communication: Internal and External

•Develop procedure for•Internal & External communication

•Document External Communications such as• Regulatory agencies• Community Complaints• Sustainability Issues w/ Customers• Others

•Decide if AND how to communicate externally about significant aspects

DH

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EMS Manual

Procedures

Work Instructions

Records

7.5.1 General- What ever is required by ISO 14001- What ever is needed for EMS effectiveness

7.5 - Documentation Information

7.5.2 Creating and Updating- Ensure identification- Format- review and approval7.5.3 Control of Documented Info- available, suitable, protected, - distribution, access, retrieval, use- storage, preservation, change control, retention & disposition- external documents

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Documented Information - Procedures- The 2015 std has replaced requirements for

“procedures” w/ requirements for “processes”

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Documented Information - Records- The term “Records” is not used in 2015 standard- However, the org. must still present “evidence” to

show they have• Determined ….• Identified• Developed Plans (more of a “procedure”)

ISO 14001:2015 - Docs and Records (1 of 5)

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ISO 14001: 2015 - Docs and Records (2 of 5)

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8.1 - Operational Planning & ControlEstablish processes needed

to meet the EMS, 6.1 and 6.2 by:

1) establishing criteria for processes, and

2) implementing control of processes to meet criteria.

i.e.,• Haz Waste Storage• Boiler Operation• Paint Booth Maintenance• Storm Water Sampling• Air Permit• Etc.

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8.1 - Operational Planning & ControlNew Pieces of the puzzle for 8.1: - Control planned changes, consequences of

unintended changes and mitigate the environmental impacts (MOC also is in 6.1.2)

- ensure outsourced processes are controlled or influenced (as stated in the EMS)

- Address Life Cycle (LC) perspective by• establishing env. controls in the design and

development process for each LC stage• Env. Requirements for procurement• Communicating env. requirements to

contractors• Consider providing info on env. impacts of the

different life cycle stages of product

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8.2 Emergency PreparednessRe: potential emergencies identified in 6.1.1

•Develop emergency preparedness & response plans

• Include plans for mitigating “environmental impacts”

• Test emergency plans (fire drills)

•Others

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Example - List of Potential Emergencies

# Potential

Emergencies or Accidents

Potential Impact Emergency

Response Plan to be Used

1 Floods Water Pollution from vehicles and machines EWI-001

2 Hurricanes Loss of Human Life EWI-001

3 Tornadoes Loss of Human Life EWI-001

4 Fire Air Pollution, Loss of Human Life EWI-002

5 Chemical Spills- small Employee Exposure (irritants mostly) EWI-003

6 Chemical Spills-large Employee exposure, Water Pollution EW-003

7 Waste Water Tote Spills Soil / Ground Water Contamination. EWI-004

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Determine- Performance metrics and comparison criteria- monitoring methods, when, where, etc.- evaluation of metrics (trends)- effectiveness of the EMSConduct Calibrations or VerificationsCommunicate performance data as per communication process

9.1.1 – Monitoring, Measurement, Analysis, and Evaluation - General

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9.1.1 – Monitoring, Measurement, Analysis, and Evaluation - General

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• Conduct an EoC against compliance obligations (6.1.3; used to be Legal & Other Environmental Requirements)

• Develop a process for EoCs wrt frequency • Conduct the EoC and Take Action if

needed• Maintain knowledge and understanding of

its compliance status

9.1.2 – Evaluation of Compliance ------ The 2nd Audit Program ------

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Example Compliance Evaluation Report

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9.2.1 & 9.2.2 – Internal Audit (1 of 2)

To Determine if EMS meets:

• ISO 14001 • EMS Procedures &

Programs

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9.2.1 & 9.2.2 – Internal Audit (2 of 2)

Establish an audit program for- frequency, methods, responsibilities

& reporting- Define audit criteria and scope- select auditors for objectivity and

impartiality- Ensure audit results are reported to

Management

NO REAL CHANGES FROM 2004

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9.3 – Management Review• Involve Top Management • Determine if EMS is

• Continuingly Suitable• Adequate• Effective

• BOTTOM LINE: Determine if EMS needs to be CHANGED

• Follow required Inputs and Outputs• Req’d Docs/Records:

- Management Review Schedule- Documented Minutes

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10.2 – Nonconformity and corrective action

• Control and correct the NC

• Mitigate environmental impacts (immediacy)

• Determine causes & action needed so that it does not

• recur (actual nonconformities)

• occur (potential nonconformities)

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10.1 – Improvement - General• Determine opportunities for improvement (see

also 6.1.1; 9.3

• Implement necessary actions to achieve “intended EMS outcomes”

10.3 – Continual Improvement• Continually improve the suitability, adequacy and

effectiveness of the EMS to enhance environmental performance

Auditing Tips

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• Good Auditors Take Time To develop• Audit Experience more important than

training class• Develop Your Audit Program For Your

Needs (Use Specific Questions)• Don’t Waste Resources on Duplicating other

inspections or audits• Audit Management for “ISO “ – Audit Non-

Management for “their” requirements• Reward Auditors for their Efforts

Thea Dunmire’s 6 Potential Pitfalls to ISO

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1) There is legal liability that could be uncovered by ISO 14001.

2) 14001 designates Top Management as responsible. This could connect TM to potential legal issues.

3) Treat audit findings and related confidentially especially with external auditors, registrars, etc.

4) Correct identified problems or there maybe potential – “willful violations.”

5) Written procedures can over-complicate EMS and create additional legal obligations.

6) Realize that records can implicate. “Get a handle” on all records “floating around”.

www.enlar.com

http://www.enlar.com/

The Newly Proposed ISO 14001 - BLOG

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http://www.ies.ncsu.edu/news-center/blog/the-new-dis-14001-2014-is-it-too-late-to-clean-it-up



ISO.org Revision Fact Sheet

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http://www.iso.org/iso/home/standards/management-standards/iso14000/iso14001_revision.htm



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Similarities 18001 with 14001

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How’s Does OHSAS 18001 Work

JHAs and Risks4.3.1

What are the OHS Issues Legal

Requirements4.3.2

Potential Emergencies

4.4.7

How are they managed ?

Objectives & Programmes

4.3.3

Training Programs

4.4.2


4.4.6

Emergency Response Plans 4.4.7

How are they checked on ?

OHS MS Audits4.5.5


4.5.2

Emergency Drills4.4.7

How are “issues” fixed and improved

Corrective / Preventive

Action 4.5.3.2

Management Review

4.6


4.5.1

Incident Investigation

4.5.3.1

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How’s Does ISO/CD 45001 Work

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ISO 14001:2004 - Level 2 Procedures

Identifying Environmental Aspects *Legal & Other RequirementsSetting Objectives, Targets, Programs *Environmental TrainingEnvironmental CommunicationDocument ControlOperational ControlsContractor ManagementEmergency Response PlanningMonitoring & MeasuringCompliance EvaluationCorrective & Preventive ActionEnvironmental RecordsInternal EMS AuditEMS Management Review

Recommended

Required

Red Add to 9000 Procedure

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EMS Manual

Procedures

Work Instructions

Records

How you do it

Evidence of what you do

Intent & Direction

What you do & who does it

7.5 - Documentation - Typical ISO 14001 Document System

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Links http://www.bms-services.com/iso-140012015/

http://www.bms-services.com/iso-140012015/

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6.2.1 xxx

14001: 2004 - Docs & Records (1 of 2)

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14001: 2004 - Docs & Records (2 of 2)

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Op Controls (part 2) …. Communicate relevant requirements to those external providers including contractors

Grounds keeping No pesticides allowed

Air Conditioning/Chiller servicing

Service technicians must show proper certification to handle Freon

On-site Construction

Contractors must follow our facility’s liquid waste disposal procedures

Shipping (trucking, transportation, bulk delivery, labeling)

All Shippers must check in with the Shipping/Receiving Dept. for instruction on our bulk chemical unloading procedures

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Other Legal RequirementsLegal Req’t Code AspectCorporate Environ. Policy

Company Web Site

Could be several

Customer Manadate for ISO

Customer Letter Could be several

Pallet Nemotode Treatment

Geographical Request Letter

Shipping

Customer Prohibition of Toxics

Customer Letter Raw Material Usage