ISO 14001 Standard is based on the management model of plan – do - check – act. Today we all be discussing the elements of the standard that deal with the checking process of the management system. This is one of the most critical elements to having a system built around continual improvement. Hopefully, most of us have completed the planning section: develop a policy determined the significant impacts and identified legal and other requirements and have used that information to come up with a listing of objectives and targets for the coming year and with those objectives and targets have put plans in place for how and who will be completing them. Most of you are probably in various stages of working on the elements in the doing part of the management model. You have begin assigning EMS related responsibilities, training, reviewing, etc. set up level one awareness training and may have begun identifying who needs trainings for operational control procedures that have been developed for significant impacts, you have been formulating how external communications will be handled and routed, identified emergency situations that could result in significant impacts and are setting up a proces for controlling these documents. We are now to the stage of setting up the system that will produce information on how effective the planning and doing phases are working. In order for management to make effective decisions on how well the system is working it must have information on its success and a process for handling this information.

ISO 14001 4. 5. 1 Monitoring and Measurement 4. 5 ISO 14001 4.5.1 Monitoring and Measurement 4.5.2 Nonconformance and Corrective and Preventative Action

4.5.1 Monitoring and Measurement The organization shall establish and maintain documented procedures to monitor and measure, on a regular basis, the key characteristics of its operations and activities that can have a significant impact on the environment. This shall include the recording of information to track performance, relevant operational controls and conformance with the organizations environmental objectives and targets. There are three paragraphs in element 4.5.1 which I will discuss separately.

4.5.1 Monitoring and measurement Identify key characteristics and develop process for tracking to show EMS performance. Develop method for monitoring conformance with operational controls. Develop method for tracking progress towards achievement of objectives and targets. There are three basics areas of monitoring and measurement.

4.5.1 Monitoring and measurement Identify key characteristics of operations and activities that can have significant impact and track Not just for aspects of objectives and targets but for all significant aspects/impacts. Provides early warning problems with specific aspects and impacts. Provides baseline for sig. aspects/impacts that may have future objectives and targets Intent is to go beyond management simply asking whether we were fined last quarter

Key Characteristics Surface water impact Wastewater volume, pollutant loading, # and volume of spills, water quality analysis, violations Air quality impact Air emission, chemical consumption, air quality analysis Natural resources impact Raw material, water, energy consumption Local aesthetics noise level, traffic volume Landfilling Solid waste volume, recycling volume

4.5.1 Monitoring and Measurement Direct Measurement Measuring a critical quantity or quality Indirect Measurement Filling out of forms during the process indicating tasks were performed correctly Periodic observations of tasks to ensure that it is being properly conducted Periodic interviews with personnel to ensure that they are aware of requirements Most of the previous examples where characteristics that are directly measured, the organizations will more than likely also use other methods of measurement that are indirect. These are often used for monitoring progress of objectives and targets and conformance with operational controls

4.5.1 Monitoring and Measurement Monitor conformance with operational controls Provides evidence to management that operational controls are being followed Typically relies on indirect measurements techniques Examples: observance performing procedure, interviews with operators during internal audits, review completed checklists or forms.

4.5.1 Monitoring and Measurement Track progress towards achieving objectives and targets Provides evidence to management that progress is being made on objectives and targets Relies on direct and indirect measurement Examples: actual performance indicators, report by staff on program action steps, resulting documents, trainings, etc..

4.5.1 Monitoring and measurement Identify key characteristics and develop process for tracking to show EMS performance. Develop method for monitoring conformance with operational controls. Develop method for tracking progress towards achievement of objectives and targets. There are three basics areas of monitoring and measurement.

4.5.1 Monitoring and Measurement Monitoring equipment shall be calibrated and maintained and records of this process shall be retained according to the organizations procedures.

4.5.1 Monitoring and Measurement Monitoring equipment used to measure the identified key characteristics will need to be calibrated. May develop separate procedure for this requirement or include in other procedures. Typically a listing of equipment requiring calibration, reference of calibration method, frequency, and responsible party. Is calibration done internally or externally

4.5.1 Monitoring and Measurement The organization shall establish and maintain a documented procedure for periodically evaluating compliance with relevant environmental legislation and regulations.

4.5.1 Monitoring and Measurement A documented environmental compliance program should address at minimum Audit scope (areas to cover) Audit responsibilities Audit process (training, team structure) Audit schedule Audit reporting (format, distribution, follow-up)

Relationship of 4.5.1 to other elements 4.4.6 requires procedures for control of activities that can have significant impact 4.5.1 requires the measurement of effectiveness of those controls 4.3.3 and 4.3.4 require the establishment of objectives and targets and programs 4.5.1 requires the organization to track progress towards achievement 4.3.2 requires the identification of legal and other requirements 4.5.1 requires periodic evaluation of compliance with requirements

4.5.2 Nonconformance and corrective and preventative action The organization shall establish and maintain procedures for defining responsibility and authority for handling and investigating nonconformance, taking action to mitigate any impacts caused and for initiating and completing corrective and preventative action.

4.5.2 Nonconformance and corrective and preventative action Example nonconformance Potential Outcome Method of Discovery Corrective Action Preventative Action Inadequate procedure: Storm drain not sealed prior to acid unloading. Unloading procedure does not cover action Release to environment Actual release Routine Inspection EMS Audit Place berm or other method of control at drain entrance Revise procedure Conduct Retraining Procedure not followed: scrubber maintenance is not being conducted as required (3 in 5 months) Shut downs Releases Permit Violations Scrubber failure Routine inspection EMS audit Conduct maintenance to get back on schedule Make supervisor accountable Replace pump Failure to review aspects and impacts: Responsible party did not evaluate new raw material Improper handling resulting in contamination Complete aspect and impact analysis of new material Require all new chemical purchases to be reviewed by EE

4.5.2 Nonconformance and corrective and preventative action Clause 4.5.2 essentially requires a systematic action plan to fix problems identified during monitoring and measurement and EMS audits. Need to consider developing a corrective and preventative action form to track and control activities to correct or prevent major non conformances and determine responsibilities and authorities.

Nonconformance Major or Minor

This chart depicts the typical process for taking corrective and preventative actions

4.5.2 Nonconformance and corrective and preventative action Any corrective and preventative action taken to eliminate the causes of actual or potential nonconformances shall be appropriate to the magnitude of the problems and commensurate with the environmental impact encountered.

4.5.2 Nonconformance and corrective and preventative action The organization shall implement and record any changes in the documented procedures resulting from corrective and preventative action.

4.5.1 and 4.5.2 To see Gastonia’s or procedures go to http://www.p2pays.org/iso/tools/manuals.htm