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Washington State Department of Ecology An Environmental Management System Alternative to Pollution Prevention Planning Using Auditing to Improve Your EMS.

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Presentation on theme: "Washington State Department of Ecology An Environmental Management System Alternative to Pollution Prevention Planning Using Auditing to Improve Your EMS."— Presentation transcript:

1 Washington State Department of Ecology An Environmental Management System Alternative to Pollution Prevention Planning Using Auditing to Improve Your EMS and Achieve Organization Goals – Part 2 February 26, 2013 2012 -2013 Webinar Series Partners: National Pollution Prevention Roundtable Stewardship Action Council The Auditing Roundtable

2 2012 -2013 Webinar Series Overview Introduction to EMS – National Pollution Prevention Roundtable September 25, 2012 – Introduction to Ecology’s EMS Program – EMS Overview – ISO14001 Gap Analysis Tool Introduction to EMS – Part 2 National Pollution Prevention Roundtable October 16, 2012 – Ecology’s EMS Program – Toxics Reduction Overview – Objectives & targets 2

3 2012 -2013 Webinar Series Overview EMS Implementation Part I – Stewardship Action Council (November 5, 2012) – Monitoring & Measurement EMS Implementation Part II – Stewardship Action Council (December 11, 2012) – Ecology EMS Program – Global Reporting Initiative – Communications & Engagement 3

4 2012 -2013 Webinar Series Overview EMS Auditing Session I - The Auditing Roundtable (January 22, 2013) conducted by Dennis Sasseville, Senior Associate with Normandeau Associates. – Ecology EMS Guidance – Preparing for and Conducting EMS Audits – Understanding EMS Auditing – EMS Auditor Qualifications – Pre-Audit Planning & Preparation – Conducting the EMS Audit EMS Auditing Session II - The Auditing Roundtable (February 26, 2013) – Audit Reporting, Evaluations and Management Review 4

5 Ecology EMS Alternative Provides flexible approach to P2 planning. Meets RCW 70.95C; Chapter 173-307 WAC requirements Work with Ecology to demonstrate operating EMS is in place. 5

6 EMS Alternative Process  Work with regional Ecology staff at earliest opportunity.  Submit request describing how EMS meets P2 planning criteria.  Submit EMS documentation for regional staff review & collaboration. 6

7 EMS Alternative Process  Host an Ecology EMS Site Visit.  Conduct Facility Periodic Assessment ( at least once every five years – 3 years recommended.  Submit annual progress report via TurboPlan or e-mail supporting materials to regional staff. 7

8 Ecology’s Pollution Prevention Criteria 2.1 Pollution Prevention Policy 2.2 Implementation 2.3 Monitoring & Measurement 8

9 9 DRAFT

10 10 DRAFT – EMS Checklist

11 Environmental Management Systems Training (EMS): Presented by Dennis Sasseville, Senior Associate Normandeau Associates The Auditing Roundtable EMS Auditing Part II: Using Auditing to Improve Your EMS and Achieve Organization Goals

12 Using Auditing to Improve Your EMS and Achieve Organizational Goals Part 2 – EMS Audit Reporting and Management Review Presented by: The Auditing Roundtable Dennis Sasseville, Certified Lead Auditor, CHMM February 26, 2013

13 Key Theme: Management System Auditing Can Drive Environmental & Sustainability Improvements How does audit reporting help to drive organizational success? Getting the most value out of the Management Review process. How can I ensure that my EMS is functioning well and providing the performance improvements and goal attainment that my organization seeks?

14 Agenda – Part 1 (review) Preparing for and Conducting EMS Audits – Principles of Management System Auditing – EMS Auditor Qualifications – Tried-and-True Auditing – Extracting Value from Your Auditing Program – The Role of The Auditing Roundtable in The Auditing Profession

15 Agenda – Part 2 EMS Audit Reporting & Management Reviews Developing the audit report – who, what, when & why. Common Findings in EMS audits Is the auditor’s job now complete, or are they part of the follow up? Preparing for and conducting a management review. Adding value – putting the audit and management review in a business framework.

16 The EMS Model

17 Audit Reporting

18 General Audit Steps Contact Points & Areas to Be Audited Gather Pertinent Background Info Determine Audit Scope Assign & Review Audit Criteria Develop Audit Plan Prepare Opening Conduct In-brief Tour Facility Gather Audit Data oInterviews oObservations oRecords review Data Analysis/ Preliminary Findings Closing Meeting Close Open Issues Prepare/Submit Draft Audit Report Respond to Comments Complete/Submit Final Report Provide Compliance Assistance Track Corrective Action Close Audit Pre-visit Post-visit Site Visit

19 Writing Audit Findings “Formulating audit results is a skill that adds significant value.” J. P. Russell, ASQ Quality Progress Magazine, 2006

20 Close Out All Open Issues Follow-up with facility for any clarifications or to fill gaps not already addressed Follow-up with research for any necessary interpretations of the standards (ex. ISO 14001, Responsible Care, etc.) Resolve whatever needs resolving: – Unclear site situations or documentation – Divergent audit team opinions

21 Writing Audit Findings Citation Audit Criteria Responsible Party Completion Date Root Cause Description Priority Level

22 Writing Audit Findings Each finding should provide sufficient detail so that someone not involved in the audit can understand exactly what the issue was Write findings in past tense – Audit is a “snapshot” in time Clearly state non-conformance in the first sentence – following sentences provide supporting detail Condition expected vs. condition found

23 Writing Audit Findings Most commonly in management system auditing, findings are grouped or characterized as… – Major nonconformance – Minor nonconformance – Opportunities for improvements – Positives

24 Writing Audit Findings Vague … “The facility had no environmental awareness.” Better … “The environmental awareness training was seriously deficient as only 30% of employees were aware that the site had an environmental policy.” Be specific Do not overstate facts

25 Writing Audit Findings Vague…“The objectives and targets were incomplete.” More helpful…“The formal targets were not specific and quantitative. Each lacked a time line for completion and an assignment of responsibility” Avoid generalities

26 Writing Audit Findings Poor…“Employees had not received Environmental Awareness training.” Improved… “Three out of six maintenance technicians at the site had not received environmental awareness training as required the company’s EMS procedure EL-10.” Avoid generalities

27 Writing Audit Findings Poor… “The lack of documented procedures for drain disposal could lead to a major shutdown of the City’s wastewater treatment plant.” Improved … “There were no written procedures for drain disposal of lab wastes, and no copy of City sewer ordinance or wastewater limits on file.” Avoid extreme or speculative language

28 Writing Audit Findings Poor… “John Doe and Fred Warts openly ignored EMS procedures” Improved… “The audit team observed several maintenance personnel circumventing the site’s Universal Waste handling SOP…” Do not focus criticism on individuals

29 Writing Audit Findings Poor… “The site did not follow ISO 14001 requirements for its environmental policy.” Improved… “The site’s environmental policy does not fully conform to 4.2 (g) of ISO 14001:2004. There were no provisions for making the policy available to the public.” Give accurate & specific references

30 Writing Audit Findings It is generally permissible to aggregate common findings from different... – Operations – Locations – Business units …if that is helpful to the overall understanding of the manager system under review.

31 Writing Audit Findings But use caution if combining findings that reflect multiple conformance issues… How many different issues are here? – “Newly hired, untrained maintenance staff placed unlabeled boxes of spent fluorescent bulbs in the landlord’s dumpster on orders from their supervisor.”

32 Writing Audit Findings Above all, keep in mind that you are reviewing a management system… …EMS auditors should look for trends in practices and processes - systemic issues, not micro non-compliances Specific nonconformances, or non- compliances, are important insights & indicators into the health of the MS.

33 Common Non-conformances Environmental policy: – Vague or broad, sweeping statements – “Striving” not “complying” – Not defining “other requirements” Legal requirements: – Legal requirements not adequately identified – Update procedure not adequately maintained

34 Common Non-conformances Environmental aspects: – Insufficient identification and inventory of aspects or not keeping environmental aspects inventory up to date when organizational changes occur Objectives and targets: – Non-specific targets - not adequately quantified or measurable

35 Common Non-conformances Roles, Responsibilities & Authority: – Responsibilities not clearly defined Training: – Training needs & requirements not adequately defined – Effectiveness & competency not considered

36 Common Non-conformances Document control: – Uncontrolled or obsolete documents in circulation or use Operational control: – Lack of procedures related to significant aspects of goods and services used by organization and communicating those procedures/requirements to suppliers and contractors

37 Common Non-conformances Monitoring and measurement: – Lack of calibration records for monitoring equipment – Compliance audit not conducted in last three years or not a multi-media audit EMS internal audit: – Lack of defined audit schedule and frequency

38 Common Non-conformances Records: – Lack of established retention time for environmental records – Records that are not readily retrievable or traceable to specific activities within the EMS Management review: – Not adequately documented. Outputs not specific

39 Reporting Audit reporting process: – Usually issued within 3-4 weeks – Responsibility of Lead Auditor – Should cover all major items discussed during closing meeting – Avoid confidential and regulatory information

40 Reporting Contents of audit report: – Brief summary of audit process – May list individuals interviewed & documents reviewed – Results of audit – Details of nonconformities and observations – May include auditor checklist (but often not) – Process for audit follow-up & closure

41 Audit Report Considerations: – When does the clock start on the corrective action timeline? – What in the draft report gets changed? – Who gets the draft? Who gets the final? – What if you do not get timely responses? – What if there are “repeat offenses”?

42 Follow-up Purpose of follow-up: – To verify the implementation and effectiveness of stated corrective action to address nonconformity How do you evaluate management system effectiveness?

43 Follow-up Role of EMS Auditors in Corrective Action EMS auditors are not required to provide assistance in corrective action unless requested Should do so only if qualified; auditor skills may not adequately translate to corrective action skills But, EMS auditors should be following up on corrective actions in subsequent audits of the same site/operation

44 When Good Audits Go Bad…  Trouble-shooting  Course correction  Prevention Address your audit process like it was a part of your management system – it is!

45 45 Management Review – Why? ISO 14001 Requirements (Element 4.6) : Periodic Top management involvement Collect & disseminate information (“inputs” Make decisions Document the review & “outputs”

46 Management Review – How/Who? Schedule at least annually Include people that have the information and people that have the authority to take action Ensure someone takes minutes that include issues discussed and action items as a result Assess how upcoming changes may affect your EMS

47 47 Management Review – What? Evaluation of the suitability of the environmental/EHS policy, and the need for any changes Review of environmental objectives, targets and performance to those targets Review of findings from internal management system and compliance audits

48 48 Management Review – What? Review of any environmental/OH&S incidents Review changed circumstances in operations, products, services, legislation, customer requirements, or other stakeholder requirements Review of any communications from interested parties/stakeholders

49 Management Review – Ask… Did we achieve our objectives? Why not? What should we do? Is our policy still relevant? Are we applying resources properly? Are we fixing problems when we find them? Are we avoiding problems in the first place?

50 Management review - Ask Are we monitoring the EMS and what does this monitoring tell us? What effects have changes in materials, products or services had on our EMS and its effectiveness? Do changes in laws or regulations require us to change some of our approaches? What stakeholder concerns have been raised?

51 Management Review Policy changes Changes to objectives and targets Planned changes Improvements to the EMS Resources Management Review - Outputs

52 Management Review To add value to the review process, consider the business viewpoint & implications

53 53 The Road Ahead for EMS Integrated into other management systems (H&S, quality, food safety, etc.) A driver & enabler for sustainability initiatives A business management system – Risk, risk, risk – The coming revisions to ISO 9001 and ISO 14001 will emphasize risk- management & internal controls approaches

54 Auditing Roundtable Overview Promote best practices in EHS Compliance and Management Systems Auditing domestically and Internationally Establish Auditing Standards Participate in agency policy setting efforts Certified Professional Environmental Auditor (CPEA) certifications offered through BEAC

55 Certification Programs Through the Board of Environmental, Health and Safety Auditor Certification (BEAC) and JV with the Institute of Internal Auditors: Offer Personal Certification Credentials in: – Environmental Management Systems – Responsible Care – Environmental Compliance Auditing – Health & Safety Compliance Auditing – Safety Process Auditing (under development)

56 Roundtable Interest Groups Auditor Resources Health & Safety International Management Systems – ISO 14001 – Internal Audit Legislative & Regulatory – Legal Issues – Standards Green House Gas Conflict Minerals

57 For More Information about The Auditing Roundtable Web Site: www.auditing-roundtable.org Kathy J. Rieth, Managing Director 15111 N. Hayden Road Suite 160355, Scottsdale, AZ 85260-2555 Telephone (480) 659-3738 FAX (480) 659-3739 Email kathy@auditing-roundtable.org

58 For More Information on BEAC Web Site: www.beac.org Wendy Acha, Certification Administrator BEAC, 247 Maitland Avenue Altamonte Springs, FL 32701-4201 Telephone (407) 831-7727 FAX (407) 830-7495 Email beac@theiia.org

59 Presenter’s Contact Information Dennis Sasseville, RABQSA LA, CHMM ISO and Sustainability Manager @Normandeau Associates, Inc. (603) 637-1184 dsasseville@normandeau.com

60 Questions?


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