1. Continual Improvement Ensuring the EMS is Effective! Internal Auditing, Corrective Actions & Management Review

2. Why Audit? Five Reasons What is the objective? (14011) 1. Determine conformance of the auditee’s EMS to the EMS audit criteria. 2. To determine if the EMS has been properly implemented and maintained. 3. Identify areas for improvement. 4. Determine the ability of the management review process to ensure the continuing suitability & effectiveness of EMS. 5. To evaluate the EMS of an organization where there is a desire to establish a contractual relationship,... supplier or JV

3. Developing an EMS Audit System Resources- External or Internal? Frequency- How often should an area be audited? Training- Training & qualifications of auditors. Checklist- Develop audit checklist QS-9000- To integrate or not to integrate? Documentation- How to document audits & corrective actions

4. Resources Who will audit? Depending on the situation of the organization’s available resources two choices exists. External- The EMS may be audited by a consultant, corporate EH&S personnel, or some other qualified external individuals. Internal- may use internal personnel trained for EMS auditing. Must develop qualifications for those who will perform internal audits. Can use existing QS-9000 trained internal auditors but they must have EMS training.

5. Audit Frequency How often do I audit? A few things to consider: 1. Size of the organization 2. Types of processes 3. Significant Impacts 4. Emergency Response Requirements 5. The size and complexity of the EMS 6. Previous audits Each of these factors will determine the frequency of audits. ISO 14001 requires periodic audits.

6. Internal EMS Audit Training ISO Standards 14011& 14012 offer guidance on environmental auditing and EMS auditing. Formal training- classroom, lecture... On the job training- 4 environmental audits... Develop requirements for internal auditors

7. Integrating the EMS with QS-9000 Several elements of the EMS may be integrated with already existing QS-9000 procedures. a. Document Control b. Internal Auditing c. Nonconformance, corrective & preventive actions d. Management Review

8. Integration concerns PRO Simplify implementation, use existing resources, documentation & records can use existing record keeping system system. CON integration of the two systems could lead to audit trails from one system to another.

9. Audit / CA Documentation & Organization Database- electronic approach (MS Access) Manual file systems Canned software systems available.

10. Emergency Preparedness & Response Audit to improve effectiveness (14001)- some items to look for: a. identify potential for & ability to respond to accidents & emergencies. b. preventing & mitigating environmental impacts associated with emergencies. c. review & revise plans.... in particular, after the occurrence of accidents & emergency situations.

11. Emergencies Fire- type of response, emergency organization (RCRA requirement?), equipment, fire protection systems, loss control measures, environmental impact of fire / fire response, communication, training & awareness. Chemical Spills- chemicals onsite, type of response, Hazwoper team, SPCC plan, training & awareness. Tornado- communication of threat, severe weather shelters... Hurricane- planning, plant operations decision making, coordination w/ local emergency officials,

12. Emergencies cont. Hurricane cont. supplies, chemical management, localized flooding, production concerns, machinery shutdown, storm drains unobstructed... Flooding- determine flood history / flood plain for the area, local wetlands, storm water drainage, equipment & material for preventing flooding, determine how flooding will affect the organization. Transportation, supplies, employees, possible environmental impacts.

13. ASMO GNC Floyd Case Study Hurricane Preparedness- ESI-2000-016 addressed rain & wind related storm damage to be expected with a Hurricane. Investigated flood related issues when implementing ISO 14001 but determined that it would be highly unlikely for flooding to cause damage to the GNC facility. Floyd Management Review- after-action report on the affects of Hurricane Floyd & associated flooding. This report addressed all aspects of the the GNC location safety, environmental, transportation, communication, production, customer shipments, vendor shipments......

14. Case Study cont. Management Review- changes: a. Situations in which a reoccurrence of flooding on a similar scale might occur. River levels, rainfall amounts, 72 hour forecast... b. evaluation of prestorm preparations. c. shipping of product- advance schedule d. vendor shipments- double ship e. loss control measures- facility /property f. environmental impacts- stormwater, waste mgt., chemical mgt. (AST) g. communication systems- radios, phones (backup) cell h. evacuation- decision making

15. Case Study cont. changes cont. i. Back up power generation- short term / long term, budget j. Alternate transportation- charter buses, prestorm staging. k. Manpower / staffing- back up from Statesville plant, Michigan plant, Japan. l. coordination- with local officials prior to storm, mid crisis. m. community needs- after storm needs of community

16. Conclusion Internal auditing, corrective action, & management review can be effective tools for continual improvement & evaluating the effectiveness of the Emergency Response procedures and the overall EMS.