ELEMENT 17: PERIODIC MANAGEMENT REVIEW OF PERFORMANCE
1.0 Purpose
To provide periodic reviews of the Biosolids Environmental Management System
(EMS) and its performance relative to policy commitments, goals, objectives and
established performance measures to ensure its continuing suitability, adequacy,
and effectiveness.
2.0 General/Background
At least annually, management personnel within the Butler County Department of
Environmental Services (BCDES) will conduct a thorough review of the
organization’s Biosolids EMS. The Division Heads of Environmental and
Operations, with assistance from the EMS Coordinator, will be responsible for
this review. The annual management review will address the following:
• Compliance with BCDES’ biosolids policy, and the need for possible
policy revision;
• Progress towards achieving program goals and objectives, and the
need for possible revision;
• Performance and suitability of biosolids management activities;
• Status of public participation and communications programs;
rd
• Internal or 3 party audit findings, including nonconformances and
corresponding corrective action plans;
• New, modified, or proposed legislation/regulations related to
biosolids management;
• Other relevant issues, changing circumstances, and/or proposed
changes to the biosolids management program.
The annual management review will be documented, as will all changes to
policies, plans, procedures and work practices that are made as a result of the
review.
3.0 Definitions
4.0 Responsible Persons
See Section 3 definitions link for details on teams noted within the manual.
BCDES’ Division Heads of Environmental and Operations are responsible for
annually reviewing the biosolids environmental management system and its
performance relative to policy commitments, goals, objectives and other
indicators of effectiveness. The EMS Coordinator is responsible for assisting
during the review, and for providing all necessary review documents, reports, and
other information.
Additionally, BCDES’ Strategic Planning Team is responsible for reviewing and
discussing pertinent EMS-related issues during annual meetings. The Division
Head of Operations and the Division Head of Environmental – both Strategic
Planning Team members – are responsible for facilitating this discussion.
Specifically, the Strategic Planning Team is responsible for “approving” program
goals for the coming year.
For an overview of roles and responsibilities related to this Biosolids EMS refer
to Element 7.
5.0 Procedures
This procedure describes how and when the annual program review will be
conducted, and also how the review and any associated program changes will be
documented.
1. The EMS Coordinator will schedule a meeting with the Division Head of
Environmental and the Division Head of Operations to review the
biosolids program. The meeting will generally take place in the fall.
2. Prior to the program and performance review meeting, the EMS
Coordinator will distribute to the Division Heads:
• The most recent annual Biosolids Program and EMS Performance
Report (Element 15),
• The most recent nonconformance and corrective action plan status
report (Element 14),
• The most recent internal or third party audit findings report (Element
16),
•.
3. The Division Heads will be asked to read the reports listed above before the
review meeting. If questions or concerns arise based on the content of any
of the reports, Division Heads may request that the EMS Coordinator
provide clarification via a summary paper or brief presentation to be
delivered at the review meeting.
4. At the program and performance review meeting, the Division Head of
Operations and the Division Head of Environmental, with assistance from
the EMS Coordinator and/or others involved with the program, will
review and discuss the following topics:
• Compliance with BCDES’ biosolids policy (Element 2), and the need
for possible policy revision;
• Progress towards achieving program goals and objectives (Element
5), and the need for possible revision;
• Performance and suitability of biosolids management activities;
• Status of public participation (Element 6) and communications
(Element 9) programs;
• Internal or third party audit findings (Element 16), including
nonconformances and corresponding corrective action plans
(Element 14);
• New, modified, or proposed legislation/regulations related to
biosolids management (Element 4);
• Other relevant issues, changing circumstances, and/or proposed
changes to the biosolids management program.
5. Program changes suggested by the review team will be recorded as they are
made.
6. At the end of the review session, proposed changes will be put to a vote.
Changes that are supported by a simple majority will be “approved”. The
EMS Coordinator will serve as the “swing vote” if necessary.
7. “Approved” changes will be enacted by the EMS Coordinator or other
suitable designee through the proper and systematic modification of EMS
Elements and associated materials (Element 12), including but not limited
to policy, roles and responsibilities (Element 7), monitoring and
measurement activities (Element 13), critical control points (Element 3),
operational controls/standard operating procedures (Element 10) and/or
training requirements (Element 8).
8. Sections specifically affected by approved changes will be notified through
standard internal communication methods. Training will be conducted as
needed to educate affected staff members on new or modified procedures,
etc.
9. General findings and comments resulting from the review process will be
documented in meeting minutes. Additionally, the EMS Coordinator will
develop an annual ‘Management Review Report’ to be disseminated
internally and published on the Department’s Biosolids EMS website.
6.0 Timeline
As described in Section 5.0 above, Management Review of the biosolids
environmental management system and its performance by the Division Heads of
Environmental and Operations will generally occur each year in the fall. The
Strategic Planning Team review of program goals and objectives will also
generally occur in the fall. Changes resulting from the review process will be
implemented in a timely fashion, based on the scope and nature of the change.
7.0 References/Attachments
References/Attachments list below may be used as a source of additional or
summary information.
Internal and 3rd Party Audit Findings Report; Current edition.
Biosolids Program and EMS Performance Report (BPPR); Current edition.
Nonconformance and Corrective Action Plan Tracking Spreadsheet.
EMS Element 1, ‘Documentation of EMS for Biosolids’ – BCDES Biosolids
EMS
EMS Element 2, ‘Biosolids Management Policy’ – BCDES Biosolids EMS
EMS Element 3, ‘Critical Control Points’ – BCDES Biosolids EMS
EMS Element 4, ‘Legal and Other Requirements’ – BCDES Biosolids EMS
EMS Element 5, ‘Goals and Objectives’ – BCDES Biosolids EMS
EMS Element 6, ‘Public Participation in Planning’ – BCDES Biosolids EMS
EMS Element 7, ‘Roles and Responsibilities – BCDES Biosolids EMS
EMS Element 8, ‘Training’ – BCDES Biosolids EMS
EMS Element 9, ‘Communication and Public Outreach’ – BCDES Biosolids EMS
EMS Element 10, ‘Operational Control of Critical Control Points’ – BCDES
Biosolids EMS
EMS Element 11, ‘Emergency Preparedness and Response’ – BCDES Biosolids
EMS
EMS Element 12, ‘EMS Documentation and Document Control’ – BCDES
Biosolids EMS
EMS Element 13, ‘Monitoring and Measurement’ – BCDES Biosolids EMS
EMS Element 14, ‘Nonconformances: Preventive and Corrective Action’ –
BCDES Biosolids EMS
EMS Element 15, ‘Periodic Biosolids Program Performance Report’ – BCDES
Biosolids EMS
EMS Element 16, ‘Internal EMS Audit’ – BCDES Biosolids EMS