ISO 14001:2015 Overview Charlie Parrish

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ISO 14001:2015 Overview Charlie Parrish charles_parrish@ncsu.edu Add value . . . or just work . . . Encourage . . . gain understanding . . .requirements So you can determine pros and cons So you can decide what is right . . . What is right today . . . 6 mo. 1 yr. Number of drivers propelling . . . 148% increase in registrations . . . Jun. ‘98 Registered companies encouraging Consumer and interest groups favoring/patronizing companies with EMS Dry cleaning example Study the standard, listen, ask question . . . What is right for your company? Process standard vs performance standard Charlie Parrish charles_parrish@ncsu.edu (919) 515-4266

What is ISO 14001? The International Organization for Standardization (ISO) is a worldwide federation of national standards bodies from more than 145 countries, one from each country. ISO is a non-governmental organization established in 1947 and based in Geneva, Switzerland. Its mission is to promote the development of standardization and related activities in the world with a view to facilitating the international exchange of goods and services, and to developing cooperation in the spheres of intellectual, scientific, technological and economic activity. ISO's work results in international agreements which are published as International Standards and other types of ISO documents. The three primary governance groups of ISO are: The ISO General Assembly, which is the annual meeting of all ISO members, and its agenda typically includes actions relating to the review of the ISO annual report, approval of ISO’s multi-year strategic plan, and ISO’s finances. The ISO Council, which meets twice a year and is responsible for the development of ISO’s multi-year strategic plan, the development of the ISO annual budget, ISO’s relations with other external organizations, and other political/strategic decisions and the general operations of ISO.   The ISO Council consists of the principal officers of ISO and eighteen elected member bodies, including ANSI for the USA. The ISO Technical Management Board (ISO/TMB), which meets three times each year and reports to and advises the ISO Council on all matters concerning the organization, coordination, strategic planning, and programming of the technical work of ISO.   The ISO/TMB consists of the ISO Vice President for Technical Management and twelve elected member bodies, including ANSI for the USA. ANSI is the sole U.S. representative and dues-paying member of the International Organization for Standardization (ISO), and as a founding member of the ISO, ANSI plays an active role in its governance. ANSI is one of five permanent members to the governing ISO Council, and one of four permanent members of ISO’s Technical Management Board. Through ANSI, the USA has immediate access to the ISO standards development processes. ANSI participates in 78% of all ISO technical committees and subcommittees, and ANSI holds the leadership roles for approximately 20% of all ISO technical committees and subcommittees. Important sources for more information

4.4 Implementation & Operation ISO 14001 - 2004 4.1 General 4.6 Management Review 4.2 Environmental Policy Continual Improvement 4.5 Checking 4.5.1 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 Planning 4.3.1 Environmental Aspects 4.3.2 Legal/Other Requirements 4.3.3 Objectives, Targets and Programs 4.4 Implementation & Operation 4.4.1 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 Red = Identifying Env. Issues Blue = Managing Env. Issues

ISO 14001 - 2015 Continual Improvement 10 Improvement 10.1 General 10.2 Nonconformity and corrective action 10.3 Continual improvement 9 Performance evaluation 9.1 Monitoring, measurement, analysis and evaluation 9.1.1 General 9.1.2 Evaluation of compliance 9.2 Internal audit 9.2.1 General 9.2.2 Internal audit program 9.3 Management review 4 Context of Organization 4.1 Understanding the organization and its context 4.2 Understanding the needs & expectations of interested parties 4.3 Determining the scope of the EMS 4.4 Environmental management system Continual Improvement 5 Leadership 5.1 Leadership and commitment 5.2 Environmental policy 5.3 Organizational roles, responsibilities and authorities 8 Operation 8.1 Operational planning and control 8.2 Emergency preparedness and response 7 Support 7.1 Resources 7.2 Competence 7.3 Awareness 7.4 Communication 7.4.1 General 7.4.2 Internal communication 7.4.3 External communication 7.5 Documented information 7.5.1 General 7.5.2 Creating and updating 7.5.3 Control of documented information 6 Planning 6.1 Actions to address risks and opportunities 6.1.1 General 6.1.2 Environmental aspects 6.1.3 Compliance obligations 6.1.4 Planning action 6.2 Environmental objectives and planning to achieve them 6.2.1 Environmental objectives 6.2.2 Planning actions to achieve environmental objectives

How Does ISO 14001-2004 Work? What are the Environmental Issues? Significant Aspects 4.3.1 Legal Requirements 4.3.2 Potential Emergencies4.4.7 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 Audits 4.5.5 Monitoring & Measurement 4.5.1 Compliance Evaluations 4.5.2 Emergency Drills 4.4.7 How are “issues” fixed and improved? Corrective / Preventive Action 4.5.3 Management Review 4.6

How Does The New ISO14001-2015 Work? What are the Environmental Issues? Outsourced Processes 8.1 Planned or Unplanned Changes 6.1.2 Env Aspects w/ Product Life Cycle (transportation, end of life, disposal) 6.1.2, 8.1 Risks & Opportunities- General 6.1.1 Significant Aspects 6.1.2 Legal Requirements 6.1.3 Potential Emergencies 8.2 & 6.1.2 How are they managed? Communicate Req’ts to - outsourced processes - contractors - other (re: stages of LC) Env requirements for Procurement Env Req’ts for the Design & Development of product/ service Competence 7.2 & Awareness 7.3 Operational Controls 8.1 Planning Action (to Address 6.1) 6.1.4 Targets & Objectives 6.2.1/6.2.2 Emergency Response Plans 8.2 How are they checked on? EMS Audits 9.2 Monitoring & Measurement 9.1.1 Compliance Evaluations 9.1.2 Emergency Drills 8.2 How are “issues” fixed and improved? Corrective / Preventive Action 10.1 Management Review 9.3

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

The New ISO 14001 Standard (1 of 2)

The New ISO 14001 Standard (2 of 2) http://asq.org/quality-press/display-item/?item=T986E http://www.iso.org/iso/home/standards_development.htm

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)

8 Big Changes (2 of 3) 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

8 Big Changes (3 of 3) 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)

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 DIS 14001 protection of the environment

4.1 Understanding the organization and its context (2 of 4) 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 DIS 14001 protection of the environment * John Nolan (google search)

4.1 Understanding the organization and its context (3 of 4) 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 DIS 14001 protection of the environment

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.) DIS 14001 protection of the environment

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 DIS 14001 protection of the environment

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 DIS 14001 protection of the environment How many times will we reference 4.1 and 4.2 in this standard ?

4.4 Environmental Management System A 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 DIS 14001 protection of the environment References 4.1 and 4.2 - #2

5.1 Leadership and Commitment Top 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

5.2 - The Three Pillars (commitments) of Your Environmental Policy: Company Policy Statement Compliance Protection of the Environment Continual Improvement DIS 14001 protection of the environment - Top Management must establish, implement & maintain define the policy

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

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)

6.1.2 Environmental Aspects & Impacts Air Emissions Air Pollution Energy Use Fossil Fuel Depletion Packaging Land Fill Space Metal Chips Minerals Depletion Stormwater Water Pollution Transportation Air Pollution Wastewater Water Pollution

6.1.2 Significant Aspects … by using established criteria… 6.1.2 Just some example significance criteria … by using established criteria…

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 Just some example significance criteria

6.1.3 – Compliance Obligations Determine compliance obligations Have access to them Determine how they apply Take them into account

Example Legal Requirements Legal Req’t Code Aspect Hazardous 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

Organization Shall Plan: 6.1.4 – Planning Action Organization Shall Plan: Significant environmental aspects Compliance obligations Risk and opportunities

6.2.1 & 6.2.2 – Objectives and Planning Actions 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

Example Objective & Plan Do it right! - Follow procedures to comply with regulations and NNBNA requirements. Keep it clean! - Prevent pollution by following instructions, preventing releases, and containing any that do occur. Make it better! - Do your part by suggesting ideas for improvement through the use of Preventive Action Requests. The term “Target” Not used.

7.2 & 7.3 Competency and Awareness 7.2: Determine 1) the necessary competence 2) ensure competence 3) training needs 4) take action to acquire competency 7.3: Ensure persons are aware of 1) the environmental policy 2) Significant Aspects of their work 3) Benefits of improved personal performance 4) Implications of NOT conforming to the EMS (including compliance obligations)

Specifying Environmental Training Needs

7.2 & 7.3 - Competency and Awareness

7.4, 7.4.2, & 7.4.3 - Communication: Internal and External DH 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 NOTE: “Internal Communication / Roles & Responsibilities” is often a problem area. One approach is to set up “Internal Customers” – as per www.pullthinking.com

7.5 - Documentation Information 7.5.1 General - What ever is required by ISO 14001 - What ever is needed for EMS effectiveness 7.5.2 Creating and Updating - Ensure identification - Format - review and approval EMS Manual Procedures 7.5.3 Control of Documented Info - available, suitable, protected, - distribution, access, retrieval, use - storage, preservation, change control, retention & disposition - external documents Work Instructions Records

Documented Information - Procedures - The 2015 std has replaced requirements for “procedures” w/ requirements for “processes” Examples: Chiller for odor control device WWTP Air pollution control devices Cooling water/boiler Blowdown

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”) Examples: Chiller for odor control device WWTP Air pollution control devices Cooling water/boiler Blowdown

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

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

ISO 14001: 2015 - Docs and Records (3 of 5)

ISO 14001: 2015 - Docs and Records (4 of 5)

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

8.1 - Operational Planning & Control Establish 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. Examples: Chiller for odor control device WWTP Air pollution control devices Cooling water/boiler Blowdown

8.1 - Operational Planning & Control New 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 Examples: Chiller for odor control device WWTP Air pollution control devices Cooling water/boiler Blowdown

8.2 Emergency Preparedness Re: potential emergencies identified in 6.1.1 Develop emergency preparedness & response plans Include plans for mitigating “environmental impacts” Test emergency plans (fire drills) Others

Example - List of Potential Emergencies

9.1.1 – Monitoring, Measurement, Analysis, and Evaluation - General Determine - Performance metrics and comparison criteria - monitoring methods, when, where, etc. - evaluation of metrics (trends) - effectiveness of the EMS Conduct Calibrations or Verifications Communicate performance data as per communication process

9.1.1 – Monitoring, Measurement, Analysis, and Evaluation - General Key Characteristics =

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

Example Compliance Evaluation Report

ARE YOU DOING WHAT YOU SAID YOU’D DO? 9.2.1 & 9.2.2 – Internal Audit (1 of 2) To Determine if EMS meets: ISO 14001 EMS Procedures & Programs ARE YOU DOING WHAT YOU SAID YOU’D DO?

Establish an audit program for 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

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

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)

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

Thank you!

Auditing Tips 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 There is legal liability that could be uncovered by ISO 14001. 14001 designates Top Management as responsible. This could connect TM to potential legal issues. Treat audit findings and related confidentially especially with external auditors, registrars, etc. Correct identified problems or there maybe potential – “willful violations.” Written procedures can over-complicate EMS and create additional legal obligations. Realize that records can implicate. “Get a handle” on all records “floating around”. Thea Dunmire tdunmire@enlar.com ENLAR Compliance Services 3665 E Bay Dr #204C, Largo, FL 33771 www.enlar.com 727-754-3670   I still provide management system training, consulting and auditing services – focusing on environmental and OH&S management systems and compliance. I just launched a new product focused on assisting organizations in making the transition to the ISO 14001:2015 standard atwww.iso14001expert.com www.enlar.com

The Newly Proposed ISO 14001 - BLOG 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 http://www.iso.org/iso/home/standards/management-standards/iso14000/iso14001_revision.htm

Similarities 18001 with 14001 25% to 40% system compatibility. This does not mean that 25% to 40% of your system is in place. However, I believe most small- and medium-sized companies will find significant commonality. How many shall statements in ISO 14001? 52 How many shall statements in ISO 9000? 137

How’s Does OHSAS 18001 Work What are the OHS Issues JHAs and Risks 4.3.1 Legal Requirements 4.3.2 Potential Emergencies4.4.7 How are they managed ? Objectives & Programmes 4.3.3 Training Programs 4.4.2 Operational Controls 4.4.6 Emergency Response Plans 4.4.7 How are they checked on ? OHS MS Audits 4.5.5 Incident Investigation 4.5.3.1 Monitoring & Measurement 4.5.1 Compliance Evaluations 4.5.2 Emergency Drills 4.4.7 How are “issues” fixed and improved Corrective / Preventive Action 4.5.3.2 Management Review 4.6

How’s Does ISO/CD 45001 Work

ISO 14001:2004 - Level 2 Procedures Required Recommended Red Add to 9000 Procedure

7.5 - Documentation - Typical ISO 14001 Document System Intent & Direction EMS Manual What you do & who does it Procedures How you do it Work Instructions Evidence of what you do Records

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

protection of the environment 6.2.1 xxx DIS 14001 protection of the environment

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

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

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

Other Legal Requirements Legal Req’t Code Aspect Corporate Environ. Policy Company Web Site Could be several Customer Manadate for ISO Customer Letter Pallet Nemotode Treatment Geographical Request Letter Shipping Customer Prohibition of Toxics Raw Material Usage