An Introduction
To
Environmental Management System (EMS)
And ISO 14001
A workshop
To the
Amman Chamber of Industry
Prepared by:
Munjed Al Sharif
Advisor, Water and Environment Sector
The Higher Council for Science and Technology
February. 2nd, 2009
1
Table of Contents
Content
Page
No.
1. Definitions of Environmental Audits
3
2. Fundamental Concepts, Principles and Skills of Environment
Auditing ( ISO 14010)
5
3. ISO 14001 Environmental Management System Basics and
Relevance to Environmental Auditing
7
4. Detailed Procedures for Conducting Environmental Audits
12
2
1.
DEFINITIONS OF ENVIRONMENTAL AUDITS
Environmental Audit
A systematic, documented verification process of objectively obtaining and evaluating evidence
to determine whether specified environmental activities, events, conditions, management
systems, or information about these matters conform with audit criteria, and communicating the
results.
1.1
Internal and External Compliance Audits
Organizations such as companies and government departments conducting financial audits
always make a clear distinction between audits conducted by internal staff v.s. external staff.
Internal Compliance Audit
An internal environmental compliance audit refers to an audit conducted by staff members of the
same organization being audited.
External Compliance Audit
An external environmental compliance audit refers to an audit conducted by persons not
considered to be employees of the organization bring audited. Typically an external audit would
be conducted by auditors employed by an independent environmental consulting firm.
1.2
Compliance Inspections by Government
Societies develop environmental regulations to protect individuals and to protect common
valued resources such as clean air and water. Human nature being what it is, not everyone will
always take action to necessarily ensure that they or their agents abide by the environmental
rules that society has set.
Jordan has a variety of environmental specifications and standards in place, however the Law of
Environment Protection No. (52) of 2006, importantly has been established as enabling
legislation which will create powers to develop more specifications and standards.
1.3
Environmental Management System Audit
Environmental Management System Audit - is a systematic and documented verification process
of objectively obtaining and evaluating audit evidence to determine whether an organization’s
environmental management system conforms to the environmental management system audit
criteria, and communicating the results of this process to the client. (ISO 14011; Sec. 3.2)
1.4
Other Types of Environmental Investigations
1)Environmental Site Assessment
2)Waste Audit
3)Energy Audit
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2.
FUNDAMENTAL CONCEPTS, PRINCIPLES AND SKILLS OF
ENVIRONMENTAL AUDITING (ISO 14010)
2.1
Driving forces for and benefits of conducting the principal
Types of environmental audits (industry & gov’t perspective)
The table below outlines the driving forces for and benefits of conducting an environmental
audit from both an industry perspective and government perspective.
INDUSTRY PERSPECTIVE
helps an industry to recognize and reduce
its existing and potential environmental
problems efficiently and effectively
GOVERNMENT PERSPECTIVE
government encourage the use of
environmental audits and should be assured
that regulators will not readily use the
findings of audits to identify areas where
they can prosecute
a decreased dependency on government
resources to enforce regulations as a result
of due diligence
due diligence which involves having
implemented systems and programs that
ensure all reasonable actions and
precautions are taken to prevent the
occurrence of an offense
avoidance of future environmental
damages, therefore increasing a company’s
savings
decrease in the incidence of legal problems
and a decrease of the rate at which
environmental liabilities are accumulated
have been reduced
effectiveness of the EMS is improved
improved public image
continuous improvement and quality
management
market pressures - failure to meet
environmental expectation of the market
can result in lost sales, customer boycotts
and difficulty in securing financing
personal accountability - individual
corporate officers, executives and directors
can now be personally accountable and
liable for the environmental performance of
parts of the organization of which they have
control
public tax savings
fewer court cases that the Crown needs to
be involved with
improved public image
market pressure - social pressures and
tourism pressures for a clean environment
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Other benefits:
• improving organizational and operational efficiency and effectiveness;
• improving communications and record keeping;
• improving awareness;
• clarifying responsibilities;
• clarifying goals and objectives and the criteria for measuring them;
• improving the effectiveness of programs and procedures;
• reducing the use of unauthorized procedures;
• improving morale’;
• improving market opportunities; and
• Preventing future problems by anticipating and preparing for them.
2.2
Audit objectives and scope
Before an audit starts the objectives and scope should be clear. The audit should be based on
objectives that are defined by the client. The scope is determined by the lead auditor, in
consultation with the client, to meet the objectives. The scope of the audit describes the extent
and boundaries of the audit.
Both the objectives and scope, once established, should be communicated to the auditee prior to
conducting the audit.
2.3
Audit criteria
Audit Criteria - are the policies, practices, procedures or requirements against which the
auditor compares collected audit evidence about the subject matter.
An essential step in an environmental audit is to determine the audit criteria.
The audit criteria should be at an appropriate level of detail and be agreed upon
by the lead auditor and the client, and then communicated to the auditee.
2.4
Selection of Audit Criteria
Audit criteria are the standards or measures of performance which the auditor will measure the
against. These measures of performance should be well understood by the auditee and the
auditor when the audit is being planned.
Typically there are three major types of audit criteria that may be considered for inclusion in an
environmental audit. These types of criteria are as follows:
Environmental Audit Criteria
Regulatory Standards
and
Government Guidelines/
Government Codes of Practice
ISO 14001
Management System
Performance
Criteria
5
Good Management
Practices (GEMPs)
and International
Standards
3.
ISO 14001 ENVIRONMENTAL MANAGEMENT SYSTEM BASICS
AND RELEVANCE TO ENVIRONMENTAL AUDITING
3.1
Overview of the ISO 14001 standard
ISO 14001 STANDARD
Introduction
The International Organization for Standardization (ISO) 14000 series is a collection of voluntary
environmental standards developed to assist organizations of all sizes and types throughout the
world to become more environmentally conscientious. Based on a management systems approach,
these standards do not set specific environmental performance goals, other than those called for in
applicable environmental legislation or by an organization's own policy, goals and objectives.
The cornerstone document of the series, i.e., ISO 14001, describes an EMS based on the following
components: Environmental Policy; Planning; Implementation and Operation; Checking and
Corrective Action and Management Review. Continual improvement is a fundamental component
of the EMS. With the exception of the first and last components, each component is broken down
into a number of sub-components. A brief description of each of the five sections and subsequent
sub-components is presented below, some of which has been extracted from ISO 14001 and ISO
14004.
ISO Section 4.2 - Environmental Policy
The environmental policy drives the implementation and improvement of an organization's
environmental management system so that it can maintain and potentially improve its environmental
performance. As such, the policy should reflect top management’s commitment to compliance with
applicable laws and continual improvement. The policy forms the basis upon which the
organization sets objectives and targets.
ISO Section 4.3 - Environmental Planning
Environmental Aspects - Environmental aspects are defined in ISO 14001 as follows:
"...an element of an organization's activities, products or services which can have a
beneficial or adverse impact on the environment. For example, it could involve a
discharge, an emission, consumption or reuse of a material, or noise."
This section is intended to provide a process to identify significant environmental aspects, that
should be addressed as a priority by the environmental management system. The process of
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identifying significant environmental aspects should consider the cost and time of undertaking the
analysis and the availability of reliable data.
Information already developed for regulatory or other purposes may be used in this process.
Organizations may also take into account the degree of practical control they may have over the
environmental aspects being considered. An organization with no existing EMS should, as a first
step, establish its current position with regard to the environment by means of a review. The aim
should be to consider all environmental aspects of the organization as a basis for establishing the
EMS. The process is intended to identify significant environmental aspects associated with
activities, products and services, and is not intended to require a detailed life cycle assessment.
Legal and Other Requirements - The organization shall establish and maintain procedures to
identify and have access to legal and “other” requirements to which the organization subscribes, that
are applicable to the environmental aspects of its activities, products or services.
Examples of other requirements to which the organization may subscribe are:
• Industry codes of practices
• Agreements with public authorities
• Non regulatory guidelines
Objectives and Targets - The objectives should be specific and targets should be measurable
wherever practicable, and where appropriate take preventative measures into account. When
considering their technological options, an organization may consider the use of best available
technology where economically viable, cost effective and judged appropriate by the organization.
Environmental Management Program - In order to address all of an organization’s objectives,
environmental management programs should be established. These programs form a key element to
the successful implementation of an environmental management system. Programs should address
schedules, resources and responsibilities for achieving the objectives and targets. The program may
include, where appropriate and practical, consideration of planning, design, production, marketing
and disposal stages.
ISO Section 4.4 - Implementation and Operation
Structure and Responsibility - The successful implementation of an environmental management
system calls for the commitment of all employees of the organization. Therefore, environmental
responsibilities should not be seen as confined to the environmental function, but may also include
other areas of an organization, such as operational management or staff functions other than
environmental.
This commitment should begin at the highest levels of management. Accordingly, top management
of the organization should establish the organization's environmental policy and ensure that the
EMS is implemented.
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Training, Awareness and Competence - The organization should establish and maintain
procedures for identifying training needs. The organization should also require that contractors are
able to demonstrate that their employees have the requisite training.
Management should determine the level of experience, competence and training necessary to ensure
the capability of personnel, especially those carrying out certain specialized environmental
management functions.
ISO 14004 outlines the basic steps in developing and implementing a training program:
• identification of employee training needs;
• development of a training plan to address defined needs;
• verification of conformance of training program to regulatory and organizational
requirements;
• training target employee groups;
• documentation of training received; and
• Evaluation of training received.
Communication - Organizations should implement a procedure for receiving, documenting and
responding to relevant information and requests from interested parties. This procedure may
include a dialogue with interested parties and consideration of their relevant concerns. In some
circumstances responses to interested parties' concerns may include relevant information about the
environmental impacts associated with the organization's operations.
Environmental Management System Documentation - The level of detail of the documentation
should be sufficient to describe the core elements of the EMS and their interaction and provide
direction on where to obtain more detailed information on the operation of specific parts of the
EMS.
Document Control - The intent of this section of the specification is to ensure that organizations
create and maintain documents in a manner sufficient to implement the environmental management
system.
• Operational Control - The organization shall identify those operations and activities that
are associated with the identified significant environmental impacts and which fall within
the scope of its policy, objectives and targets. The organization shall plan these activities,
including maintenance, in order to ensure that they are carried out under specified
conditions.
Emergency Preparedness and Response - The organization shall establish and maintain
procedures to identify potential for and respond to accidents and emergency situations, and for
preventing and mitigating the environmental impacts that may be associated with them. The
organization shall review and revise, where necessary, its emergency preparedness and response
procedures, in particular, after the occurrence of accidents or emergency situations. The
organization shall also periodically test such procedures where practicable.
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ISO Section 4.5 - Checking and Corrective Action
Monitoring and Measurement - The organization shall establish and maintain 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 organization's objectives
and targets. Monitoring equipment shall be calibrated and maintained and records of this process
shall be retained according to the organization's procedures. The organization shall establish and
maintain a procedure for periodically evaluating compliance with relevant environmental legislation
and regulations.
Non-Conformance and Corrective and Preventive Action - The organization shall establish and
maintain procedures, define responsibility and authority, for handling and investigating nonconformance, taking action to mitigate the impacts caused by non-conformance and for initiating
corrective and preventive action. Any corrective or preventive action taken to eliminate the causes
of actual and potential non-conformances shall be appropriate to the magnitude of problems and
commensurate with the environmental impact encountered.
Records - The organization shall establish and maintain procedures for the identification,
maintenance and disposition of environmental records. These records shall include training records,
and the results of audits and reviews. Environmental records shall be legible, identifiable and
traceable to the activity, product or service involved. Environmental records shall be stored and
maintained in such a way that they are readily retrievable and protected against damage,
deterioration or loss.
Environmental Management System Audit - The organization shall establish and maintain
programs and procedures for periodic environmental management system audits to be carried out, in
order to determine whether or not the environmental management system conforms to planned
arrangements for environmental management including the requirements of the ISO 14001 standard
and has been properly implemented and maintained, and provide information on the results of the
audit to management for review.
ISO Section 4.6 - Management Review
The organization's top management shall, at intervals it determines, review the environmental
management system, to ensure its continuing suitability, adequacy, and effectiveness. The
management review process shall ensure that the necessary information is collected to allow
management to carry out this evaluation. This review shall be documented.
3.2
Process for registration to 14001 and role of registrars
Typically, the registration process can be summarized by the following 7 steps:
Step 1:
Interview registrars and select one that you feel “comfortable” with
Step 2:
Complete questionnaire provided by registrar
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Step 3:
Step 4:
Step 5:
Step 6:
(typically
Step 7:
Pre-registration audit conducted by registrar to assess whether the EMS is
“auditable”
Registrar conducts documentation review (note that some registrars
conduct this step prior to pre-registration audit)
Registration audit conducted by registrar
Recommended for registration by registrar to accreditation body
Standards Council of Canada)
Annual surveillance audits conducted by registrar (can be done semiannually if preferred by company)
The objectives of the registration assessment are to confirm that the EMS is in conformity with
ISO 14001 and that the EMS is implemented and maintained at the site in question (CAN-P14).
It is therefore important to note that an EMS must meet the following in order for a registrar to
conduct a registration audit:
• be fully operational (i.e. the entire EMS has been audited at least once) and can
be shown to be effective; and
• at least one management review cycle has been completed and the results of
internal audits were reviewed.
3.3
Role of auditor certification bodies
Are independent organizations of individuals and companies dedicated to furthering the
development and professional practice of environmental auditing. The are also to certify
individuals to become
3.4
Role of accreditation bodies
Accreditation bodies are set up in each country to control the registration process and ensure that
organizations offering registration audits (Registrars) are operating in accordance with agreed
standards.
Some of the better known Accreditation bodies include:
Standards Council of Canada (SCC) – Canada, Registration Accreditation Board,
RAB) - United States Of America, United Kingdom Accreditation Service (UKAS) Britain
Registrars (also known as Certification bodies in some parts of the world) -, SGS International
Certification Services (SGS), British Standards Institute (BSI), Lloyds Register of Quality
Assurance (LRQA).
4.
DETAILED PROCEDURES FOR CONDUCTING
ENVIRONMENTAL AUDITS
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Environmental auditing has evolved as a discipline since the late 1970's. The practice of
environmental auditing has become widespread amongst larger companies in North America and
Europe. As discussed in Section 2.0, there are different types of environmental audits. This
training course has been customized to teach the participants the specific environmental audit
procedures which have been developed over the last several years. The process and details
associated with the audit are constantly undergoing improvement.
4.1
Pre-audit Planning and Preparation
• Select and schedule facility to be audited.
• Contact facility.
• Plan the audit. Gather and review background information and develop audit plan.
• Carefully identify audit scope in the audit plan.
• Determine proper size of audit team and duration of audit.
• Identify potential audit team members qualified and experienced enough to conduct
the audit.
• Confirm availability of audit team members for specific dates.
• Confirm with the facility the selected date for the audit. Make sure to check that
key facility staff will be present and available during the days of the audit. Also
inquire about any unusual issues at the facility which could interfere with the audit or
vice versa.
• Issue the facility manager written notice of the audit, including a brief description
of the schedule and a request of key staff to be present and available for interviews.
• Issue the facility a pre-visit audit questionnaire (see Appendix 7 for a sample
questionnaire which is available on disk and can be modified as needed by the audit
team).
• Complete travel and accommodation arrangements for the team.
• Inform team members if they will have any particular protocol assignments (e.g.
one auditor could be responsible for solid and special waste and air pollution issues).
• Distribute audit materials to the auditors:
–Protocol
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–Background materials provided by the facility as per the pre-audit information
request
• Auditors review the above information and the applicable environmental
regulations.
4.2
The Role, Preparation and Use of Audit Checklists
The environmental audit protocol is the set of procedures to be followed by the auditors to
complete the audit.
Protocols provide the auditor with specific guidance for the completion of the audit procedures.
The following 'action words' may be used throughout audit protocols as guidance to the auditor
to indicate the type of activity required to perform the procedure.
Confirm: add strength to, corroborate, make firm. (For example - Confirm that company rules
are enforced with contractors and their employees).
Review: look at, go over. (For example - Review the hearing protection program).
Verify: prove, substantiate, ascertain correctness (For example - Verify that the program has
been updated and determine the frequency).
Evaluate: assess, determine the value of (For example - Evaluate how effectively industrial
hygiene and occupational health issues are communicated to management)
4.3
Interviewing
Interviewing and data gathering from facility personnel is an integral part of most environmental
audit procedures. Notably, the quantity and quality of information obtained depends on the use
of effective interviewing techniques. Sound interviewing skills, therefore, are a key qualification
that each environmental auditor should bring to the audit.
4.4
The Opening Meeting
The opening meeting is important to the success of the audit because it is an opportunity to set a
positive tone for the rest of the audit. It is also the time to ensure that facility management know
what to expect during the audit. Typically, an opening meeting discussion guide is used.
The entire audit team should be in attendance at the opening meeting. It is usually best to let the
facility manager decide which staff should be present, but it is suggested that all managers
having environmental responsibilities as well as staff having major environmental roles be
present.
After the opening meeting, the audit team should conduct a facility orientation tour. Once this
orientation is complete, the audit team should administer the internal controls questionnaire to
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key facility management having environmental responsibilities. If it is not convenient to
conduct the orientation tour and then reconvene the key management personnel, then it is best to
administer the internal control questionnaire during the opening meeting.
4.5
Understanding and Assessing Internal Controls
Some facilities have an Environmental Management System to provide a framework for the
achievement of environmental objectives. A critical part of the audit involves the assessment of
the effectiveness of the Environmental Management System in attaining the facility's
environmental objectives.
4.6
Conducting Facility Inspections
• Complete any safety training required by the facility.
• Wear appropriate personal protective equipment.
• Get a facility map and use it for marking on what areas were inspected and what was
observed.
• Follow the process flow as the agenda for the initial inspection
• A "heads up" attitude is needed to observe and understand the significance of what
others may have overlooked in the past. Look for the unexpected as well as the
expected.
• Do a relatively short initial overall inspection making note of questions, planning to
return later to investigate details.
• If possible, try to be accompanied during inspections by someone from the facility (more
chance to ask questions and availability of a witness in case of a problem observed).
• Make working papers to document what areas were inspected and what was observed.
• Concentrate on noting problems and potential problems, but also make note of positive
findings. Such positive findings should be presented verbally at the close-out meeting.
4.7
Gathering Different Types of Audit Evidence
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• Audit information is any fact pertaining to the issues within the scope of the audit.
• Audit evidence is audit information that supports a particular finding or hypothesis.
The distinction drawn above is made to emphasize that the auditor can observe information that
supports a finding that there is a problem. One, however, can never know how other audit
information may not support a hypothesis or conclusion at the time, but later once other
information is collected, a pattern appears, establishing the basis for a new finding.
Types of Audit Information
Direct observation (inspection)
most reliable
Documentary evidence
Ð
Interviews
Ð
Circumstantial
4.8
least reliable
Working Papers and File Development
• Audits by their nature are sampling exercises because they are like a "snapshot in time".
• Even the most experienced auditor will not "see everything", but the auditor should try to
see as much as possible in the time allotted.
• It is possible to miss deficiencies; however it should be the audit team's objective to not
miss significant deficiencies.
• The concept of assessing risk in designing a sampling strategy is important. If the risk of
negative consequences (or materiality) is high, then a stronger degree of confidence
should be obtained. This implies that a larger sample size is required.
4.10
Verification of Audit Evidence
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The Need for Verification
The environmental audit program is essentially a program of verification. The audits are
intended to be a check on environmental performance. It must be clear to all involved that the
audits are not the system itself.
The concept of risk is central to understanding effective verification practices. Risk is a function
of the probability and magnitude of a negative outcome. Figure 5 illustrates the assessment of
environmental risk.
Probability x Magnitude = RISK
Methods of Verification
Verification basically involves the confirmation that a certain level of performance is being
achieved. It is best to have two or more sources of information corroborating the same
conclusion. Typically, it is best not to make important judgments based on verbal information
from one person.
• Use of verbal evidence as the only source of audit information on a topic being
investigated should generally be avoided. In the case of low risk issues and credible
interviewees, verbal evidence can be accepted.
• Consider whether the person supplying information has a vested interest or personal
agenda in disclosing or not disclosing certain facts.
• As possible, obtain documentary evidence and look at the physical premises before
conclusions are made. NEVER BE AFRAID TO ASK – COULD YOU SHOW ME
PLEASE?
• Make personal observations of the physical premises in question.
• "TRUST, BUT VERIFY".
• Auditors should feel free to ask to see all kinds of documents and to interview various
employees on site. Efforts should be made however not to give facility employees the
feeling that everything they say is being checked.
The Auditor's License to Ask the Question
15
4.11
Assessing Findings
The audit reports are exception based. This means that only the problems are reported on. As
such, we consider a finding to be the identification of a problem. As a general premise, there are
five different types of findings:
REG:
This finding refers to a legislative type deficiency. Legislation may either be a
regulation, a decree, a standing order, a permit requirement or an internal plant
regulation. This finding should be cross referenced with the title of the applicable
legislation and section or article referred to. The wording of the finding should be
similar to that which is used in the legal document being referred to.
EMS:
Environmental Management System Performance Criteria (following ISO 14001
requirements)
GEP:
This is a Good Environmental Practice. It may refer to procedures, practices or
other work directives which are not required either by law or policy, but may be
highly recommended for better or more efficient environment management. A
Good Environmental Practice is not a legal requirement, but a management
requirement for a better control.
LOCAL: Local attention item. Quite often these type of findings are indirectly related to the
scope of the audit being conducted.
Beyond classification of the different types of findings, the assessment of findings should take
place at various levels:
By the individual auditor:
1) While collecting evidence, make notes in the working paper and collect documentary
evidence on whether there is a potential finding.
2) After collecting sufficient evidence to believe there is a finding, write the finding as it
would appear in the close-out meeting report. Then, re-assess whether there is
sufficient evidence to support the finding.
3) Assess the importance of the finding.
By the audit team:
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1) During the team meetings at the end of each day, the team members should
have an opportunity to assess each others' findings. This is a time to challenge the
other auditors on each finding. Criteria for consideration are as follows:
- Are the facts stated in the finding correct?
- Is there enough evidence supporting the finding? (i.e. Verbal evidence only may
not be sufficient, written or physical evidence is likely necessary for most findings
that appear in an audit report. If verbal evidence only is available, then it will be
necessary to verbal evidence from several sources.
- Is the finding significant enough to appear in the final report, or should it be for
local attention only?
2) The team should agree that the wording of the finding is clear, concise and
factual.
4.12
Report Writing
-Content and distribution of report
-Client or auditee responsibility for follow-up
& corrective action
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