Contractor Management and ISO 14001:2004 2008 EMS Conference, Roanoke, Virginia October 8, 2008 Dr. Victor Gray CVGray & Associates LLC victor@cvgray.org www.cvgray.org 804-307-4955

Contractor Management and ISO 14001:2004 Outline What is ISO 14001:2004 ISO 14001:2004 Requirements Importance of Contract Management Control Application of Operations Control (Clause 4.4.6)

What is ISO-14001:2004

What Are ISO Environmental Management Standards EMS helps an organization to establish and meet its own policy goals through objectives and targets, organizational structures and accountability and management controls and review functions - all with top management oversight. EMS does not set requirements for environmental compliance, nor do the standards establish requirements for specific levels of pollution prevention or performance. The Environmental Management Systems’ Specification Document calls for environmental policies which include a commitment to both compliance with environmental laws, and prevention of pollution.

What Are ISO Environmental Standards ISO's Environmental Standards (EMS) are a series of voluntary standards and guideline reference documents which include: Environmental Management Systems, Eco-labeling, Environmental auditing, Life cycle assessment, Environmental performance evaluation, Environmental aspects in product standards. The focus on management “distinguishes these standards from performance" standards.

ISO-14001 EMS Specification Standard Environmental Management Systems - Specification with guidance for use. This standard is the main management systems specification document in the ISO 14000 series. It contains the required elements that must be satisfied by an organization seeking registration or certification for its Environmental Management Systems to the standard. It’s the only standard to which an organization can be audited.

What ISO-14001:2004 is Not and Does Not: Is not a Product standard; Is not a Performance standard; Does not establish levels for Pollutants or Performance; Does not establish Test Methods; Does not require initial Performance Testing; Does not require or establish a Final Performance Goal; Does not require the meeting of Zero Emissions; Does not mandate Best Practice Technology; Does not require the disclosure of Performance Levels; Does not require the disclosure of Audit Results.

The ISO 14001:2004 EMS Standard Contains Requirements for the Following: An environmental policy supported by top management, Identification of environmental aspects and significant impacts, Identification of legal and other requirements, Environmental goals, objectives, and targets that support the policy, An environmental management program, Definitions of roles, responsibilities, and authorities, Training and awareness procedures, Processes for communication of the EMS to all interested parties, Documentation and operational control procedures, Procedures for emergency response, Procedures for monitoring and measuring operations that can have a significant impact on the environment, Procedures to correct nonconformance, Record management procedures, A program for auditing and corrective action, Procedures for management review.

ISO-14001:2004 Background

ISO-14001:2004 Background The ISO-14000 series: An evolving family of environmental management standards. The International Organization for Standardization (ISO) was founded in 1946 in Geneva, Switzerland, with its key mission to promote trade by developing international voluntary consensus standards. The ISO 14000 series is a voluntary set of standards intended to encourage organizations to systematically address the environmental impacts of their activities. The Standards have been developed by ISO under the TC 207 committee. The goal of the TC 207 committee is to develop a common approach to Environmental Management Systems that is internationally recognized. ISO 14001 was adopted in 1996 as an International Standard for guiding the development of Environmental Management Systems.

ISO-14001:2004 Background continued The ISO 14001 EMS is defined as: "that part of the overall management system that includes organizational structure, planning activities, responsibilities, practices, procedures, processes, and resources for developing, implementing, achieving, reviewing and maintaining the environmental policy" (ISO 14001: 1996). The current version (2004) is the second version which updates and replaces the 1996 version.

The Plan, Do, Check, Act Continual Improvement Cycle ISO-14001:2004 Requirements The Plan, Do, Check, Act Continual Improvement Cycle

ISO-14001 Requirements Environmental planning takes into account the following paragraphs of Section 4.3 PLANNING: 4.3.1 Environmental aspects 4.3.2 Legal and other requirements 4.3.3 Objectives & targets The “Planning” phase of the continual improvement cycle requires that plans are formulated to fulfill the Environmental Policy's Objectives and Targets.

ISO-14001 Requirements The implementation (Do) and operation of your E.M.S. takes into account the following paragraphs of Section 4.4 Implementation & Operation: 4.4.1 Resources, Roles Responsibility and Authority 4.4.2 Competence, Training and Awareness 4.4.3 Communication 4.4.4 Environmental Management Systems Documentation 4.4.5 Document Control 4.4.6 Operational Control 4.4.7 Emergency preparedness & response The “Do” phase of the continual improvement cycle requires the development of capabilities to support the implementation and on-going operations of the organization in support of the E.M.S.

ISO-14001 Requirements Environmental Checking takes into account the following paragraphs of Section 4.5 Checking . 4.5.1 Monitoring & Measuring 4.5.2 Evaluation of Compliance 4.5.3 Nonconformity, Corrective and Preventive Action 4.5.4 Control of Records 4.5.5 Internal Audit Monitoring and measuring ensures the success of your environmental performance and that its meeting stated objectives and targets.

ISO-14001 Requirements Environmental system management review takes into account the following paragraphs of Section 4.6 Management Review: 4.6 Management Review The entire Environmental Management System should be continually monitored, and be subject to periodic reviews.

Importance of Contract Management Control

Importance of Contract Management Control on your site (Clause 4. 4 Importance of Contract Management Control on your site (Clause 4.4.6 Operational Control) Your EMS should require that any person performing work or services on your site, who has the potential to cause a significant environmental impact should be aware of the requirements and importance of the EMS and are competent to perform the job assigned. For Contractors performing an operation or activity that has the potential where environmental impacts are significant, these controls should take the form of documented procedures.

Application of Contract Management Control

Application of Contract Management Control on your site What forms can these controls take? Procedure(s) for 4.4.6 and contractor management Develop Operating Criteria Documented instructions for Contractors on site Videos of safety and environmental actions needed Training prior to coming on campus Completed form (which becomes a record of agreement when it is signed) “Environmental Briefing Contractor Methods Statement” can be a technique used to inform contractors of your requirements.

Environmental Management Basics Example The environmental manager is : _____________ (contractor signs off on each point) Supplier / Contractor understands the importance of compliance with relevant environmental legislation and regulations, and the consequences of non-compliance. All Suppliers / Contractors working at the facility are required to comply with and ensure their employees and any Suppliers / Contractors or agents comply with the facility’s Environmental Management System (EMS) and environmental policy. All Suppliers / Contractors acknowledge receiving or were made aware of the facility’s environmental policy, as well as applicable system procedures and work practices. Suppliers / Contractors shall not discharge anything to drains and/or sewers without the prior approval from the facility’s environmental manager. Spills and other releases to the environment must be immediately reported to the environmental manager. Suppliers / Contractors shall provide adequate spill release prevention, as approved by the environmental manager. Suppliers / Contractors shall immediately notify the environmental manager of any abnormal conditions found during work at the facility. Suppliers / Contractors shall properly label, store, and dispose of all their waste materials used in-site in accordance with facility procedures and all legal requirements. If facility personnel are required to work with potential hazardous materials brought on-site by a contractor, prior approval of that material by the environmental manager is required. Suppliers / Contractors shall minimize the efforts of noise, order, light, fugitive dust emissions, and traffic movement on and/or adjacent to facility property. Suppliers / Contractors shall obtain, prior to commencing work, all necessary environmental approvals or permits and present copies of such permits to the environmental manager. Suppliers / Contractors were informed of actions to be taken during an actual emergency situation. The Suppliers / Contractors understand that the facility may interrupt Supplier / Contractor activities that violate policies and/or all legal requirements.

All ISO 14001:2004 EMS actions in regard to Contractor Management should be: Documented Part of plan of facility operational control Actions recorded Part of initial Contract negotiations Part of the Internal Audit process

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