ISO 14001 Environmental Management System EMS Auditing Overview

ISO 14001 Environmental Management System (EMS) Auditing Overview for the Department of Interior Linda Baetz, EMS-LA and Jim Wood, P. E. , EMS-LA U. S. Army Center for Health Promotion and Preventive Medicine

Discussion Topics • • • EMS Requirement – Background Preparing for External EMS Audits Joint Compliance/EMS Audits Evolution of Army EMS Auditing Army EMS Audits – Lessons Learned • Army EMS Auditor Training (External & Internal Auditors)

EMS Requirement - Background • EO 13148 – Required Federal Agencies to implement EMS • EO 13423 – Reinforced EMS implementation at “all appropriate levels” and EMS use as “primary management approach” • OFEE EO 13423 Instructions – Requires external audits [initial & follow-up (3 -yr cycle)]

Preparing for External EMS Audits (Phase I - Document Review Phase) • Understand ISO 14001 Standard • Review EMS “Gap Analysis” Results (and determine if “gaps” resolved) • Understand your DOI-Agency specific EMS Manual/procedures • Review of DOI-Agency specific EMS Manual/procedures (ISO 14001 conformance)

Preparing for External EMS Audits (Phase II – Internal Audit Phase) • Conduct an internal EMS audit (using trained auditors) • Implement corrective/preventive action(s) based on internal audit • Understand the different types of nonconformance (i. e. , major vs. minor) and the level of resources & commitment for resolution

Preparing for External EMS Audits (“Common” Nonconformance Issues) • ISO 14001, 4. 1 (General Requirements) • Has the “scope” of the EMS been documented?

Preparing for External EMS Audits (“Common” Nonconformance Issues) • ISO 14001, 4. 2 (Environmental Policy) • Does the policy address all of the mandatory “commitments”? • Has the policy been communicated to “all persons working on behalf of the organization” (i. e. , contractors & subcontractors)?

Preparing for External EMS Audits (“Common” Nonconformance Issues) • ISO 14001, 4. 3. 1 (Environmental Aspects) • Are the aspects “documented” and kept up-to-date? • Are the “significant” aspects taken into account in the EMS?

Preparing for External EMS Audits (“Common” Nonconformance Issues) • ISO 14001, 4. 3. 2 (Legal and Other Requirements) • Do the “legal and other requirements” apply to the “environmental aspects”?

Preparing for External EMS Audits (“Common” Nonconformance Issues) • ISO 14001, 4. 3. 3 (Objectives, Targets, and Programs) • Have “significant environmental aspects” been considered when establishing objectives/targets? • Do the programs designate “responsibilities”, “means”, and “time-frames” to achieve objectives & targets?

Preparing for External EMS Audits (“Common” Nonconformance Issues) • ISO 14001, 4. 4. 1 (Resources, Roles, Responsibility and Authority) • Has EMS Management Rep. been appointed? • Have roles, responsibilities, and authorities been “documented” and “communicated”?

Preparing for External EMS Audits (“Common” Nonconformance Issues) • ISO 14001, 4. 4. 2 (Competence, Training, and Awareness) • Has “competence” been determined for persons with potential to cause significant environ. impacts? • Are “training needs” identified? • Has “awareness” been provided to persons working on “behalf of the organization”?

Preparing for External EMS Audits (“Common” Nonconformance Issues) • ISO 14001, 4. 4. 3 (Communication) • Do external communication “procedures” match actual “business practices”? • Has the “record of decision” (regarding external communication of significant environmental aspects) been “documented”?

Preparing for External EMS Audits (“Common” Nonconformance Issues) • ISO 14001, 4. 4. 4 (Documentation) • Does the EMS documentation include all of the mandatory requirements?

Preparing for External EMS Audits (“Common” Nonconformance Issues) • ISO 14001, 4. 4. 5 (Control of Documents) • Do “procedures” (e. g. , approval, review, update/re-approval, revision, removal of obsolete documents, etc. ) match actual “business practices”? • Are “documents of external origin” addressed?

Preparing for External EMS Audits (“Common” Nonconformance Issues) • ISO 14001, 4. 4. 6 (Operational Control) • Have operational controls been developed for those activities & operations with significant environmental aspects? • Are those operational controls being “implemented” at the “user level”?

Preparing for External EMS Audits (“Common” Nonconformance Issues) • ISO 14001, 4. 4. 7 (Emergency Preparedness and Response) • Are emergency preparedness & response procedures periodically tested (where practicable)?

Preparing for External EMS Audits (“Common” Nonconformance Issues) • ISO 14001, 4. 5. 1 (Monitoring and Measurement) • Are “key characteristics” of operations (that can have significant environmental impact) being monitored and measured? • Are there calibration records for any associated monitoring and measurement equipment?

Preparing for External EMS Audits (“Common” Nonconformance Issues) • ISO 14001, 4. 5. 2 (Evaluation of Compliance) • Is there a process for the periodic evaluation of compliance with legal and other requirements? • Are records available of those periodic compliance evaluations?

Preparing for External EMS Audits (“Common” Nonconformance Issues) • ISO 14001, 4. 5. 3 (Nonconformity, Corrective Action & Preventive Action) • Do procedures also address “preventive” actions? • Do procedures address corrective & prev. action “effectiveness”? • Do the “procedures” match the actual “business practices”?

Preparing for External EMS Audits (“Common” Nonconformance Issues) • ISO 14001, 4. 5. 4 (Control of Records) • Do procedures address the “retention times” & “disposal” of records? • Are records legible, identifiable, and retrievable?

Preparing for External EMS Audits (“Common” Nonconformance Issues) • ISO 14001, 4. 5. 5 (Internal Audit) • Has an Internal Audit Program been implemented (e. g. , schedule established; auditors identified & trained; audits conducted)? • Does the selection of auditors & the conduct of the audits ensure objectivity & impartiality of the audit process?

Preparing for External EMS Audits (“Common” Nonconformance Issues) • ISO 14001, 4. 6 (Management Review) • Has the management review process been implemented? • Does the management review process incorporate all of the required inputs?

Joint Compliance/EMS Audits (Different Approaches) • Army Environmental Performance Assessment System (EPAS) External Audits – Active Component Installations • Concurrent Compliance/EMS Audit • Dedicated EMS Audit Team • Separate Compliance & EMS Audit Reports

Joint Compliance/EMS Audits [Different Approaches (Cont. )] • Army EPAS External Audits – Reserve Component Installations • Installation Compliance Audit is Conducted First • Follow-up EMS Audit (conducted months after the compliance audit) • Root Cause Analysis (from compliance audit) is used to Formulate EMS Audit Plan

Joint Compliance/EMS Audits [Different Approaches (Cont. )] • Defense Logistics Agency (DLA) Compliance and EMS Audit Programs • Separate Compliance & EMS Audit Schedules (no integration between compliance & EMS audits) • DLA EMS Focus – “Multi-site Organizational EMS” vs. “Facilityspecific EMS”

Joint Compliance/EMS Audits (Key Points) • Compliance auditing and conformance auditing are VERY different skills sets • If joint compliance/EMS audits are conducted, the audit team needs to include “dedicated” EMS auditor(s) (with no compliance audit responsibilities)

Joint Compliance/EMS Audits [Key Points (Cont. )] • EMS Lead Auditor needs to have full responsibility for conduct of the EMS portion of the audit (e. g. , preparing EMS audit, briefing results, preparing report, etc. ) • Compliance auditors may provide site-specific “feedback” (e. g. , training records, current plans/procedures, operational controls, etc. )

Joint Compliance/EMS Audits [ [Key Points (Cont. )] • If contractor EMS auditors are used, consider specifying that the auditors be RABQSA-certified (ensures level of competence) • If contractor EMS auditors are used, consider “Nondisclosure Agreements” (prevents contractor from using DOI EMS practices in support of other clients)

Joint Compliance/EMS Audits [Key Points (Cont. )] • If EMS support contractors have assisted with the “implementation” of the EMS, do NOT use those same contractors to “audit” the EMS (avoids conflicts of interest) • EMS support contractors can still be used to address audit findings (if needed), but they need to be “independent” of the audit

Evolution of Army EMS Auditing • FY 85 – 91: Army Environmental Audit Program (multiple protocols, compliance medias only) • FY 92 – 00: Army Environmental Compliance Assessment System (ECAS) Program [standard protocol (TEAM Guide); Army Supplement to TEAM Guide (included Env. Program Mgt. )]

Evolution of Army EMS Auditing (Cont. ) • ECAS Env. Program Mgt. evaluations included several components of an EMS audit • FY 01 – Present: Army EPAS Program [Army Supplement to TEAM Guide revised to include “EMS” section (ISO 14001)] • Env. Program Mgt. assessors trained as EMS auditors

Army EMS Audits – Lessons Learned • Many contractor-prepared EMS manuals/procedures do not reflect installation business practices • Some Army Commanders equate EMS “nonconformance” to regulatory “noncompliance” • Some Army installations tend to regard EMS as a “Program” vs. a “management system”

Army EMS Audits – Lessons Learned (Cont. ) • Command emphasis on EMS can vary with changes in installation leadership (integration of EMS with “sustainability” has worked well at some installations) • Incorporation of “tenants” into host installation EMS can prove challenging.

Army EMS Auditor Training (Training External Auditors) • Army Environmental Command (AEC) hosts ISO 14001 Lead Auditor Course (open to potential auditors & funds attendance) • EMS auditor trainees are assigned to participate in EMS audits (AEC funds travel) with experienced (e. g. , USCCHPPM) EMS auditors until capable of serving as auditor

Army EMS Auditor Training (Training External Auditors) • Core Group of Experienced EMS Auditors Still Conduct the Majority of Army EMS Audits • Expanding the “Army Pool” of Experienced Auditors is a Major Challenge (multi-year effort) • EMS Auditor Pool MUST be Expanded (“Core Group” cannot support all Army EMS audits)

Army EMS Auditor Training (Training Internal Auditors) • General EMS internal auditor training (interview techniques, reviewing objective evidence, preparing findings, and practical exercise using “generic manual”) • Installation-specific EMS internal auditor training (above basics of internal EMS audits & practical exercise using installation manual)

Questions Linda L. Baetz, EMS-LA (410) 436 -5234 linda. baetz@us. army. mil James D. Wood, P. E. , EMS-LA (410) 569 -3325 jim. wood@us. army. mil