Checking and Corrective Action EPA Regions 9 & 10 and The Federal Network for Sustainability 2005

PlanningReview Policy Checking Operation EMS Flow

Checking & Corrective Action P rocedures shall be established for monitoring the EMS and correcting deviations. Requirements for procedures cover: Monitoring and measurement Nonconformance and corrective and preventive actions Records EMS audits

Monitoring and Measurement Regularly monitor and measure operations and activities with potential environmental impacts Record information tracking performance, relevant operational controls and conformance with the organization’s objectives and targets

Monitoring and Measurement (cont.) Calibrate and maintain monitoring equipment and retain records of these activities Establish procedures to evaluate compliance with relevant environmental legislation and regulations periodically

Nonconformance and Corrective and Preventive Actions E stablish and maintain procedures for handling and investigating nonconformance taking action to mitigate impacts initiating and completing corrective and preventive actions

Nonconformance and Corrective and Preventive Action (cont.) Ensure corrective actions are appropriate and commensurate with risk Record any changes resulting from corrective actions

Reasons for a Nonconformance Implementation differs from documentation System is not working Requirement is not addressed

Records Procedures must be maintained for the identification, maintenance and disposition of environmental records. Environmental records include training records, audit results, reviews, monitoring records, waste disposal records, etc. Records must be maintained to demonstrate conformance to EMS requirements.

Documents vs. Records Documents –Offer guidance or explain actions to be carried out –Can be changed Records – a special kind of document –Provide verification of things that have happened –Cannot be changed

Documents vs. Records Documents are materials that provide management directions: –internal standards and operating procedures –process information –organization charts –emergency plans Records include product information training records incident reports complaints and responses audit results management review meeting minutes

Records Properly maintained records will be legible be identifiable be traceable to the activity, services or product involved be stored and maintained to be easily retrievable be protected from damage, deterioration or loss have the retention time recorded

EMS Audit An organization’s programs and procedures for periodic audits should address audit scope frequency and methodologies responsibilities and requirements for conducting audits reporting of results

Audits should be scheduled regularly and based on the environmental importance of the activity and results of previous audits.