Hi you folks. I need your timely help. And your single word or an answer shall be most appreciated.

What's the significant environmental aspects for my production process?

Our product is the rubber printer roller. The roller is a rubber roll assembled to a steel shaft. The problem is that we can not easily identify the significant EA during our early production process. The process are as follows:
1) to add some additives to silicon gel or rubber powder;
2) to mix them in a machine till finally become a thin layer paste;
:confused: We have particle and gases emission into a pipe but we don't konw whether it's SO, SO2
3) to dry this paste with natural air ;
4) to punch it in an injection-like stamping machine; the temperature of inner chamber is around 200 selsius degree. We don't whether there is SO, SO2 ect.emitted into a pipe.
5) to cut the pressed roller into the required sizes;
6) to assembly it to a steel shaft;
7) to grinding the surface t oa smooth condition;:confused: we do collect the grinding dust but don't whether there is still some kind of gases emitted into a pipe.
...

We have no treatment of the dischaged air by pipe. We don't whether there is OS, OS2,and OS3 in the gases.

Thank you in advance.

Partner I don't know how to say this other than we can't tell you. Significance is based upon established or determined criteria of the organization and not from some list. What is significant to me or anybody else may or may not be for you. You have to do this one yourself.

Here are some links that may help...


Discussion: Significant Aspects (Clause 4.3.1), Operational Controls (Clause 4.4.6) (http://elsmar.com/Forums/showthread.php?t=7461)

ISO 14001 Aspects and Impacts - The Chicken Bone Thread (http://elsmar.com/Forums/showthread.php?t=1547)

ISO 14001 with No SIGNIFICANT Environmental Aspects - Small Service Company (http://elsmar.com/Forums/showthread.php?t=8279)

Maybe someone here can throw out some guesses / possibilities as a start.

Thanks for the links, Randy. They're good places to start. I've always liked the "Chicken Bone" thread.

Thank you, Randy and Marc. Thank you for your timely response. Randy is right, maybe I did not express myself clrearly. What I like to know is that what the usual environmental aspects in a production process like ours are. For significant ep, we can judge by our critiera. But the first step is we must know what the eps are in our process. Frankly speaking, due to lack of knowledge of organic and inorganic chemistry, we can not identify all the eps in our process. We'd like to learn something from someone with this kind of expertise---rubber industry knowledge.

Thank you, Randy and Marc. Thank you for your timely response. Randy is right, maybe I did not express myself clrearly. What I like to know is that what the usual environmental aspects in a production process like ours are. For significant ep, we can judge by our critiera. But the first step is we must know what the eps are in our process. Frankly speaking, due to lack of knowledge of organic and inorganic chemistry, we can not identify all the eps in our process. We'd like to learn something from someone with this kind of expertise---rubber industry knowledge.

Forget all that chemistry garbage...identifying aspects and determining significant isn't rocket science and it sure isn't chemical engineering, it's as basic as it gets. You're trying to over engineer the process...STOP!!!!!

Basic aspects for everyone;

energy usage
waste materials (related to production and general trash)
raw materials
chemical materials
potable water
waste water

Read the links from beginning to end and you should be able to understand how truly simple a process it is.

Dear Friend,

You may try a simple input-output model to identify the environmental aspects of your process. For example, take the stage "add additives to silicone gel or rubber and mix them to get a thin paste etc". The inputs may be (a) additives, (b) silicone gel (or rubber), (c) energy, (d) machinery etc. (the list is indicative). The desired output is "thin paste of silicone gel or rubber". The undesired outputs like (a) used container for additivies, (b) used container of silicone gel, (c) packing materials for rubber,silicone etc., (d) wasted energy (energy used when there is no production) etc., may be identified as "ASPECTS" (i.e. elements of your activity that can cause environmental impact, direct or indirect). This way you may build up a list of aspects for all the activities that form your manufacturing process. As you have indicated you may establish a procedure for identifying significant aspects from the above list.

Hope the above method works for you.

With best wishes,

Ramakrishnan

Thank you. Randy and Dr. L. Ramakrishnan,

We have no problems in identifying the above-said eps. But we want to know whether the emitted gases is SO2or somthing else. Is there anything else besides SO2? Are these gases hazardous or not? We do have tolarable value in China. If it exceeds the limit, a treatment project shall be needed.

Hope to know more on this aspect.

Forget all that chemistry garbage...identifying aspects and determining significant isn't rocket science and it sure isn't chemical engineering, it's as basic as it gets. You're trying to over engineer the process...STOP!!!!!Absolutely not!

Before you can understand the significance of an aspect you have to know the chemistry behind it. If, as I suspect, the process described by Yasunari Kuo is a solvent based one then you have to understand the chemistry of what is being discharged from the process as process waste - emissions to air. The main reason for knowing what is going up the pipe is that in many countries (and from memory China is one) there is strict regulation on VOC emissions (Volatile Organic Compounds). If there is regulation around the emission of VOCs (my guess at this stage) then this affects the significance of the aspect. I know you and I disagree on this one Randy but the impact of the aspect and the legal regulation of any aspect have a huge impact on the significance evaluation process.

Dr. L. Ramakrishnan is right - you can start with a mass balance for what is going into your process and what is coming out as finished product. You can then decide on that basis what is being discharged from the process as waste (VOCs for instance), evaluate what regulation applies at the national and local level and then decide what controls you need to have in place to control and / or monitor the emissions and demonstrate legal compliance.

Absolutely not!

Before you can understand the significance of an aspect you have to know the chemistry behind it. control and / or monitor the emissions and demonstrate legal compliance.

Show me the shall................You're talking apples and oranges Paul....

It'll be tonight before I can take the time to elaborate, but the trail you are laying is going in the wrong direction and will accomplish nothing but confusion of the part of the poor soul seeking help.

I loook forward to reading your elaboration, Randy. Far from attempting to confuse Yasunari Kuo I am trying to help him to understand the processes he has in place so that the organization has an accurate picture of the environmental impacts it has.

Basic aspects for everyone;

energy usage
waste materials (related to production and general trash)
raw materials
chemical materials
potable water
waste water

Read the links from beginning to end and you should be able to understand how truly simple a process it is.
Rather than oversimplify it to a "one size fits all" list of generic aspects each organization needs to understand the aspects that apply and any relevant legislation. This to me is a critical difference from 9k to 14k - an understanding of the technology of the waste streams by both the company and the auditor is needed before you can assess the effectiveness of the EMS.

P.S. The quote you have put in from my post is not a direct quote.

You know you're right about the quote...lack of attention to detail on my part...Dr R. contributed part of it:o

Anyway to continue....The determination of significance doesn't need to have anything to do with the understanding of environmental chemistry, waste streams or the man in the moon.

Significance determination is totally based upon criteria established by the organization which it deems to be important to them and developing a methodology of its choosing that will essentially differentiate those aspects of less environmental importance from those of a greater importance with importance being decided by the organization. The importance or significance does not have to align with any science, legal or any other requirements in but can be soley based on nothing more than organizational cultural values in many ways similar to the process of establishing O&T's.

Signifance determination of aspects in an individual organizational activity that can vary across the entire spectrum...What is significant to one may or may not be significant to another. I'll use an illustration to help explain significance.....

In the Southern part of the US (Arkansas, Alabama, Georgia, etc)...the open display of a shotgun or rifle in a gunrack located in the real window of a pickup truck or the open wearing of a holstered pistol in Arizona is not identified as an activity worthy of note..nobody really cares (it's not significant).....now perform the same activity in NYC, Chicago or London, the event will be one of great significance especially to the one displaying the firearm. Significance like beauty is in the eye of the beholder....So what we may identify as significant may or may not be to our friend and the opposite holds true.

Our friend, as well as anybody else performing the task of signifance determination has to identify himself those factors that of import to them such as controllability, legal requirements, cost potential for harm, views of the public or any other value they choose and then develop a method to weigh one aspect against another.

Now if you can show the specific shall that makes the above incorrect I'll kiss your naked fanny in the middle or Terminal A @ DFW. ;) :lol:

I think the right answer is somewhere between Randy and Paul's answer.

Randy, I agree with your explanation up to a degree. It is left to the organization to determine significance. But it cannot be read to imply any old arbitrary assignment would be acceptable (and I don't that was your point). There has to be thought and a logical basis to the conclusion, or I might write it up as not effective.

I agree with Paul to a degree, that some understanding of SO and SO2 would be needed, but a basic user level would be adequate. You don't need the services of a chemist, etc.

The shalls in the standard are basic but pretty clear. The aspects already exist in the organization. They are the activities and materials used. The significance of the impacts have to be determined in a realistic manner, (though it certainly could vary between Arizona and NYC, or LA). Legal requirements will vary from country to country, but they must be determined as well. And the needs of interested parties need to be considered. None of these could be construed as arbitrary.

I agree with Paul to a degree, that some understanding of SO and SO2 would be needed, but a basic user level would be adequate. You don't need the services of a chemist, etc.


Thanks for the comments, but I'm gonna disagree about the "science" aspect of your argument.

ISO 14001 was developed in such a fashion that any type of organization, doing any type of activity, any place on the earth could meet its requirements. The abiguity and abstractness of significance determination was for a specific purpose and that purpose was to not require, demand or extort organiztions to do anything other identify through their means those aspects they deam to be of greater importance than any other. The understanding of SO, SO2, NOX, E=MC2 or anything else is actually irrelevant if they don't want to go down that trail. They can have as many crazy things they want and identify their trash and electricity as the most significant if they so choose. To tell someone they need to be a chemical engineer or scientist and apply those mathmatics involved to adequately identify significant aspects is a falsehood and definitely misleading for a novice an the inexperienced..or anyone else for that matter. It is intended to be a simple process for an important reason...so anybody regardless of literacy, education and scientific background could do it.

Thanks for the comments, but I'm gonna disagree about the "science" aspect of your argument.

ISO 14001 was developed in such a fashion that any type of organization, doing any type of activity, any place on the earth could meet its requirements. The abiguity and abstractness of significance determination was for a specific purpose and that purpose was to not require, demand or extort organiztions to do anything other identify through their means those aspects they deam to be of greater importance than any other. The understanding of SO, SO2, NOX, E=MC2 or anything else is actually irrelevant if they don't want to go down that trail. They can have as many crazy things they want and identify their trash and electricity as the most significant if they so choose. To tell someone they need to be a chemical engineer or scientist and apply those mathmatics involved to adequately identify significant aspects is a falsehood and definitely misleading for a novice an the inexperienced..or anyone else for that matter. It is intended to be a simple process for an important reason...so anybody regardless of literacy, education and scientific background could do it.



Randy, you may be changing my comments. I agreed with everything you explained, except I cautioned the selection cannot be arbitraay. I even included the shalls that were involved.

I most definitely DID NOT say "To tell someone they need to be a chemical engineer or scientist and apply those mathmatics involved to adequately identify significant aspects is a falsehood and definitely misleading..."

I fully agree they do not have to be chemists or experts. But they have to have a reasonable "user's level of knowledge" and would be expected to know Sulfuric acid cannot be poured down a drain. That would not comply with the legal regulations in most parts of the world.

I don't think we are disagreeing in principles. I am not a chemist by any stretch. Every organization I audit has had an adeqaute and effective understanding of the materials they use. If they had any questions, they consulted with their vendors, or other knowledgeable persons.

My only point was it cannot be arbitrary, or inappropriate. That would never pass a witness audit. If you don't agree with that last statement, I would be surprised, but we would then have to choose to disagree.

Sincerely, Hjilling

The determination of significance doesn't need to have anything to do with the understanding of environmental chemistry, waste streams or the man in the moon. We disagree.
In order to understand significance you have to understand impact
In order to understand impact you have to understand what is in your waste
In order to understand what is in your waste you have to understand your processes
In this case in order to understand your processes you have to understand the chemistry

I'll leave the man in the moon to you.:biglaugh:

Significance determination is totally based upon criteria established by the organization which it deems to be important to them and developing a methodology of its choosing that will essentially differentiate those aspects of less environmental importance from those of a greater importance with importance being decided by the organization. The importance or significance does not have to align with any science, legal or any other requirements in but can be soley based on nothing more than organizational cultural values in many ways similar to the process of establishing O&T's.Wrong again. If an organization has a polluting process and wants certification because they are economical with paper clips then I'll send them to you. If they want to implement a management system that assesses its aspects, evaluates the significance of their impacts and puts in place a management system that makes a difference to the environment then I will be happy to carry on talking to them about certification. The base line is compliance with legislation with improvement on top.

If the company doesn't understand its processes then it cannot know if it is complying with legislation

Signifance determination of aspects in an individual organizational activity that can vary across the entire spectrum...What is significant to one may or may not be significant to another. I'll use an illustration to help explain significance.....

In the Southern part of the US (Arkansas, Alabama, Georgia, etc)...the open display of a shotgun or rifle in a gunrack located in the real window of a pickup truck or the open wearing of a holstered pistol in Arizona is not identified as an activity worthy of note..nobody really cares (it's not significant).....now perform the same activity in NYC, Chicago or London, the event will be one of great significance especially to the one displaying the firearm. Significance like beauty is in the eye of the beholder....So what we may identify as significant may or may not be to our friend and the opposite holds true. Not an area of expertise of mine, I confess, so I can't comment on the legislation in the States behind the analogy. Now in the UK you can't walk around with a pistol because it is illegal - which kind of supports my argument. Legislation makes the wearing of the gun significant - as an individual I may choose to determine this as not significant but I am wrong - and may live to be told so.

Our friend, as well as anybody else performing the task of signifance determination has to identify himself those factors that of import to them such as controllability, legal requirements, cost potential for harm, views of the public or any other value they choose and then develop a method to weigh one aspect against another.
Any auditor worth their salt will also assess the significance evaluation process and determine if it is a genuine attempt to identify environmental impact or so much window dressing. In the case we are discussing (remember that?:confused: ) if the company doesn't even know what is going up the chimney the significance evaluation process doesn't amount to much.

Now if you can show the specific shall that makes the above incorrect I'll kiss your naked fanny in the middle or Terminal A @ DFW. ;) :lol: Thank you for this (second) offer. Again I am going to have to decline.

ISO 14001 was developed in such a fashion that any type of organization, doing any type of activity, any place on the earth could meet its requirements. The abiguity and abstractness of significance determination was for a specific purpose and that purpose was to not require, demand or extort organiztions to do anything other identify through their means those aspects they deam to be of greater importance than any other. :It was precisely because some people and, more importantly, some certification bodies are treating ISO 14001 as a paperwork exercise and not related to environmental significance that the 2004 revision tried to make more clear the link between scope / aspects / legislation and improvement (and drew out the legislative compliance as a stand alone clause)

The understanding of SO, SO2, NOX, E=MC2 or anything else is actually irrelevant if they don't want to go down that trail. They can have as many crazy things they want and identify their trash and electricity as the most significant if they so choose. To tell someone they need to be a chemical engineer or scientist and apply those mathmatics involved to adequately identify significant aspects is a falsehood and definitely misleading for a novice an the inexperienced..or anyone else for that matter. It is intended to be a simple process for an important reason...so anybody regardless of literacy, education and scientific background could do it.Bull***t. This is dangerous stuff.....

In most countries in the world (I can speak directly for the UK, China, Romania, France, Belgium and the Czech Republic with some knowledge of other countries) there are limits on what organizations can put in the air, water and into the ground as pollutants. These are directly regulated by the nation state or local regulatory bodies. They issue permits to specify maximum permitted levels of NOx, SOx, Fluorocarbons, CODs, BODs, VOCs and any other acronym you care to mention (I would elaborate but my fingers are getting tired). If they catch you breaching those limits they are likely to fine you.

While I agree it is not intended to be elitist. Registration to the standard is meant to be awarded to organizations that understand where they sit in the environment and play their part in maintaining that environment and improving it.

I tried once to explain the reasoning behind significance evaluation on another thread and it was ignored.
http://elsmar.com/Forums/showpost.php?p=124396&postcount=13

I stand by the post and stand for organizations that play their part in pollution prevention and environmental improvement. I oppose organizations that have ISO 14001 certification as window dressing - and anyone who supports that.

I wholeheartedly agree with Paul. According to Randy's comment, an organization could blatantly disregard scientific data and "align" their significance determination based on cultural issues. So, if it would cost US$10 million to install a scrubber to minimize air pollution, but senior management makes a decision NOT to invest the $10M and self award them the $10M as year end bonus, that means that they could "manipulate" the significance determination criteria any way they want to justify not having to install the scrubber...That is laughable. An ISO 14001 certificate should mean something. As it relates to Environmental Performance. I have already mentioned 3 other times in this Forum that the IAF guide to ISO Guide 66 states that it is a responsibility of the EMS 3rd party audit team to ensure that the criteria established to determine significance must be SOUND. Further, due to external pressure, the Accreditation Bodies are trying to make CB's accountable. Read, for example, ANAB Heads up # 61 (http://www.anab.org/HTMLFiles/docs/HeadsUp/HU61.pdf), which states that outputs matter. For EMS and QMS. It does not address specifically the issue of significance determination, but the underlying message is that the certified systems must deliver on the INTENT of the Standard. Who determines what the intent is? The IAF Guide to ISO Guide 66 (http://www.compad.com.au/cms/iaf/workstation/upFiles/400489.IAF-GD6-2003_Guide_66_Issue_3_Pub2.pdf)would be a pretty good start.

AM I the only one who thinks we might have a few ships passing each other in the night? Although most, if not all, of what I know about the subject came from this site, I think maybe I can align the various views here. At the risk of appearing totally whacked, here goes. Let's start with this quote from Paul:



In most countries in the world (I can speak directly for the UK, China, Romania, France, Belgium and the Czech Republic with some knowledge of other countries) there are limits on what organizations can put in the air, water and into the ground as pollutants. These are directly regulated by the nation state or local regulatory bodies. They issue permits to specify maximum permitted levels of NOx, SOx, Fluorocarbons, CODs, BODs, VOCs and any other acronym you care to mention (I would elaborate but my fingers are getting tired). If they catch you breaching those limits they are likely to fine you.

I stand by the post and stand for organizations that play their part in pollution prevention and environmental improvement. I oppose organizations that have ISO 14001 certification as window dressing - and anyone who supports that.

OK, now, Randy has stated that the companies are free to determine what is significant. It is a cultural thing. But lets say right now that he is, technically speaking, correct. So who is right?

How many corporate cultures would willingly expose themselves to the slings and arrows (not to mention fines and lawsuits) that accompanies the wrath of the environmental authorities? I know that sometimes business decisions have been made, so maybe a better question would be how many 14001 companies have been caught making environmentally questionable "business decisions"? Is there evidence that there is an effect?

Therefore, I would like to offer the possibility that in practice both positions are correct.

Although I may have just created an aspect that will lead to an impact. That of a hostile posting environment. TAKE COVER!!!:lol:

I haven't deviated from anything provided below.

I've copied the material from documents paid for by my corporation (DSEQ, Inc) for my private use and under agreement I may use it as long as do not print and sell it or offer it for sale.

Excerpted from ISO 14001:2004, A.3.1

In some locations cultural heritage can be an important element of the surroundings in which an organization operates, and therefore should be taken into account in the understanding of its environmental impacts.
Since an organization might have many environmental aspects and associated impacts, it should establish criteria and a method to determine those that it considers significant. There is no single method for determining significant environmental aspects. However, the method used should provide consistent results and include the establishment and application of evaluation criteria, such as those related to environmental matters, legal issues and the concerns of internal and external interested parties.
When developing information relating to its significant environmental aspects, the organization should consider the need to retain the information for historical purposes as well as how to use it in designing and implementing
its environmental management system.
The process of identification and evaluation of environmental aspects should take into account the location of activities, cost and time to undertake the analysis, and the availability of reliable data. The identification of environmental aspects does not require a detailed life-cycle assessment. Information already developed for regulatory or other purposes may be used in this process.
This process of identifying and evaluating environmental aspects is not intended to change or increase an organization's legal obligations.

From ISO 14004:2004
4.3.1.5 Determining significant environmental aspects
Significance is a relative concept; it cannot be defined in absolute terms. What is significant for one organization may not be significant for another. Evaluating significance involves applying both technical analysis and judgement by the organization. The use of criteria should help an organization to establish which environmental aspects and associated impacts it considers significant. Establishing and applying such criteria should provide consistency and reproducibility in the assessment of significance.
When establishing criteria for significance, an organization should consider the following:
a) environmental criteria (such as scale, severity and duration of the impact, or type, size and frequency of an environmental aspect;
b) applicable legal requirements (such as emission and discharge limits in permits or regulations, etc.);
c) the concerns of internal and external interested parties (such as those related to organizational values, public image, noise, odour or visual degradation).
Significance criteria can be applied either to an organization's environmental aspects or to their associated impacts. Environmental criteria can apply to both environmental aspects and environmental impacts, but in most situations they apply to environmental impacts. When applying criteria, an organization can set levels (or values) of significance associated with each criterion, for example based on a combination of likelihood (probability/frequency) of an occurrence and its consequences (severity/intensity). Some type of scale or ranking can be helpful in assigning significance, for example quantitatively in terms of a numeric value, or qualitatively in terms of levels such as high, medium, low or negligible.
An organization may choose to evaluate the significance of an environmental aspect and associated impacts, and may find it useful to combine results from the criteria. It should decide which environmental aspects are significant, e.g. by using a threshold value.
To facilitate planning, an organization should maintain appropriate information on the environmental aspects identified and those considered significant. The organization should use this information to understand the need for and to determine operational controls. Information on identified impacts should be included as appropriate.
It should be reviewed and updated periodically, and when circumstances change to ensure it is up to date. For these purposes, it can be helpful to maintain them in a list, register, database or other form.
NOTE The determination of significant environmental aspects does not require an environmental impact assessment.

When you say that The understanding of SO, SO2, NOX, E=MC2 or anything else is actually irrelevant if they don't want to go down that trail. They can have as many crazy things they want and identify their trash and electricity as the most significant if they so choose. ..so anybody regardless of literacy, education and scientific background could do it. you are basically inferring that they can disregard toxic waste, pollutants etc... and develop a significance determination criteria that would NOT include obvious HIGH impact aspects of their operation and artificially control less significant ones. For example, a nuclear processing facility could disregard their toxic waste as a significant aspect and consider printer cartridges/toner as a significant one. To me, this just does not make sense. That is why the IAF Guide to ISO Guide 66 requires the CB auditors to test the significance determination criteria for soundness. If a CB auditor is not up to challenge the organization's significance determination criteria, s/he is failing to follow the IAF rules, therefore contravening the rules of accreditation.

Randy, thanks for posting the excerpts. I am well aware of the content of the sections you posted and agree with them fully. In fact, I happily embrace the thoughtful approach ISO has brought to this difficult subject of environmental performance. Without that, the program would fail.

I would suggest the excerpts perfectly agree with what I have been trying to say.

Yes, it is left to the organization to determine significance, but in a "thoughtful manner ...with consideration of technical issues."

It does not have to be high level chemistry, but can't be oblivious, either. It has to consider financial, technical and regulatory issues. It cannot be arbitrary.

It also cannot ignore the comments that Paul and Sidney made from the standard, and from Guide 66. These statements all have to be taken into consideration.

It cannot be arbitrary. It has to be a thoughtful and legitimate selection, or it serves no benefit to the environment. Ths would seem to be a perfectly reasonable and consistent, and value-added interpretation. I might add, none of my clients have had any issues with this, and readily followed this approach.

Best regards.

I'm not saying that anything can be disregarded, I'm stating if the determination criteria and methodology do not identify significance it doesn't matter what the aspect is...

In the San Grabiel Valley is a large plume of perchlorate contaminated water. There is a company that is part of the EPA's remediation program and is paying annually to clean the water. When they put together their EMS...registered initially by Intertek...the criteria and methodology they used for aspect significance determination did not identify the perchlorate plume as a significant aspect (they had been one of the major contributors to its generation). Why? Because through their process they identified that everything that could be done was being done, and it was being controlled. The criteria they used gave perchlorate contaminated water a lower score than the utilization of electricity and the generation of solid waste. The electricity they were using was contributing to tons of air emissions being generated and thousands of barrels of oil being burned to generate it. The trash was contributing to the continuing burden of landfilling in LA County. These were aspects of significant environmental impact based on the established criteria and methodology.

What has been stated by everyone about all the science, chemistry, legal jumbo and references to ANAB decisions (which btw matter not one bit to an organization not subject to ANAB grumblings and wishing to just self declare) castrates the essence of 4.3.1 and that is for an organization to be able to take all things into consideration, determine those of what it decides to be of greater value such as legal, controllability, views of parties, potential environmental effect, influence or any number of others and through its own logic differentiate one from another. This doen't mean an organization can ignore a polluting activity, but if it (the activity) is already governed by identified law and processes are in place controlling it and nothing else can be done about it why must it be identified as significant over something that has no legal requirements and controls that also may directly or indirectly impact the environment? The 4.3.1 process allows organizations to look beyond the law and science and seek environmental performance improvement in areas not being managed through traditional concepts and schemes.

4.3.1 is not about the law, it is not about science, it is about identifying and managing environmental impact (or at least it helps to initiate the process)

...the criteria and methodology they used for aspect significance determination did not identify the perchlorate plume as a significant aspect (they had been one of the major contributors to its generation). Why? Because through their process they identified that everything that could be done was being done, and it was being controlled. Isn't that the essence of determining significant aspects? So you ensure that operational controls are in place? So, in this case, the perchlorate contamination might not be managed as part of the EMS, ie, O&T's, CA's, etc.... If they are indeed doing all that could be done, in terms of controlling this aspect and perchlorate has a high environmental impact, what would have been the problem identifying it as a significant aspect? They are, as you saying, already controlling it. Doing all they can do about it. By leaving it outside of the significant aspects list, then you might have less oversight over that aspect. I understand your reasoning, but do not agree with it.

If they are indeed doing all that could be done, in terms of controlling this aspect and perchlorate has a high environmental impact, what would have been the problem identifying it as a significant aspect?

There's no problem

1st...it's just that the criteria and methodology used didn't identify it as significant

2nd....they had no real control and no potential of control or influence (one of the criteria) because it was being managed by a consent decree

Taking Randy's example I think this gives a good example of why we have such vastly different posts when I think the principles are not that far apart.

In the San Grabiel Valley is a large plume of perchlorate contaminated water. There is a company that is part of the EPA's remediation program and is paying annually to clean the water. Describes the current state well. The company is polluting and this state has been accepted by the regulatory authority.
When they put together their EMS...registered initially by Intertek...the criteria and methodology they used for aspect significance determination did not identify the perchlorate plume as a significant aspect (they had been one of the major contributors to its generation). In my opinion this aspect should still have been identified as significant - I'll explain below.

Why? Because through their process they identified that everything that could be done was being done, and it was being controlled. The criteria they used gave perchlorate contaminated water a lower score than the utilization of electricity and the generation of solid waste. The electricity they were using was contributing to tons of air emissions being generated and thousands of barrels of oil being burned to generate it. The trash was contributing to the continuing burden of landfilling in LA County. These were aspects of significant environmental impact based on the established criteria and methodology. This is where the significance issue comes in.
Yes waste to landfill is significant in this instance - it is a pollutant and it creates problems. The company were managing waste prior to the EMS (presumably).
Similarly with energy. As Randy has explained energy usage impacts on the environment through use of fossil fuels and emissions to atmosphere. At the time of applying for an EMS the company were managing usage.
So for both of the above the company has evaluated this aspect as significant - why not emissions to water - it satisfies the same criteria?

The issue in the above example seems to be the cost to do something about it. I reject this as a determination of significance.

The cost may mean it is prohibitive to deal with some of the company's significant aspects - it doesn't make them insignificant.


What has been stated by everyone about all the science, chemistry, legal jumbo and references to ANAB decisions (which btw matter not one bit to an organization not subject to ANAB grumblings and wishing to just self declare) castrates the essence of 4.3.1 and that is for an organization to be able to take all things into consideration, determine those of what it decides to be of greater value such as legal, controllability, views of parties, potential environmental effect, influence or any number of others and through its own logic differentiate one from another. This doen't mean an organization can ignore a polluting activity, but if it (the activity) is already governed by identified law and processes are in place controlling it and nothing else can be done about it why must it be identified as significant over something that has no legal requirements and controls that also may directly or indirectly impact the environment? The 4.3.1 process allows organizations to look beyond the law and science and seek environmental performance improvement in areas not being managed through traditional concepts and schemes.

4.3.1 is not about the law, it is not about science, it is about identifying and managing environmental impact (or at least it helps to initiate the process)EMS is about the law, it is about the chemistry / science.

The "legal jumbo" you talk about is in place because some (hopefully a very few these days) feel they are above the law and can pollute to line their pockets, hence governments apply the science and produce the laws.

The point is not that you have to take only the aspects that are governed by legislation or where there is scientific evidence that the results of the process adversely impact on the environment. The point is that the company must understand its processes before it can evaluate aspect significance. To recommend otherwise on this Forum sews an element of doubt in readers minds and devalues ISO 14001 registration.

I take the point about ANAB but the reason ANAB, IAF and other bodies get involved is that already ISO 14001 registration is being attacked as being meaningless for the environment. They, and all like minded people want it to mean something. In the same way that ISO 9001 registration should say something about the quality of a product you buy from a registered firm.

Looks like it's time for me to stop trying to sell snow to Eskimo's I guess and for me to seek another career because I have apparently been leading folks down the wrong path.:uhoh:

I really thought that an organization could use out-of-the-box thinking and creativity and incorporate them into the EMS implementation process but it appears I was mistaken. Apparently the only valid approach is that of a myoptic, diminished perrifial vision process of determining significance...oh yeah I remember...TUNOPIA!:frust:

Ya'll realize of course I just had an attack of smart asz and couldn't fight it off don't ya? :mybad: My medication isn't working.

I really thought that an organization could use out-of-the-box thinking and creativity and incorporate them into the EMS implementation process but it appears I was mistaken. Apparently the only valid approach is that of a myoptic, diminished perrifial vision process of determining significance...oh yeah I remember...TUNOPIA! There is no conflict between innovation and performance, but the goal is not to be innovative. It is to deliver on environmental performance. And don't forget that Ken Lay was lauded more than once as the most innovative CEO in America. We all know now where his out of the box corporate thinking led us to.
Going through some motions should not lead to an ISO 14001 certificate. It should require going through some meaningful motions.

Who has the absolute right to determine where performance improvement is to be made and what the improved performance will consist of in an EMS, the organization or outside parties?

I really thought that an organization could use out-of-the-box thinking and creativity and incorporate them into the EMS implementation process but it appears I was mistaken. You're absolutely right to encourage innovation in the organization choosing how to address their significant aspects. I have seen some great ways of involving people in saving waste and energy on audit.
Apparently the only valid approach is that of a myoptic, diminished perrifial vision process of determining significance...oh yeah I remember...TUNOPIA!:frust: Far from myopic what I am trying to encourage is people to be aware of the full picture for environment and then to try and address the biggies first - the old Pareto principle.

It doesn't stop organizations using innovative techniques to address some of the less significant aspects - particularly if it gets involvement of the employees. The peripheral vision bit is being able to see beyond the obvious - not an ability to ignore what is in front of you.

Who has the absolute right to determine where performance improvement is to be made and what the improved performance will consist of in an EMS, the organization or outside parties?
The answer to this question: the organization implementing ISO 14001 has the right to determine where performance improvement is to be made, but, and in case of an external certification, the registrar has the absolute responsibility to ensure that the course decided by the organization makes sense from an environmental perspective. Rubber stamping an ineffective EMS and granting it an ISO 14001 certificate should not happen. And many stakeholders are already voicing their discontentment.

ISO 14001 was developed in such a fashion that any type of organization, doing any type of activity, any place on the earth could meet its requirements. The abiguity and abstractness of significance determination was for a specific purpose and that purpose was to not require, demand or extort organiztions to do anything other identify through their means those aspects they deam to be of greater importance than any other. The understanding of SO, SO2, NOX, E=MC2 or anything else is actually irrelevant if they don't want to go down that trail. They can have as many crazy things they want and identify their trash and electricity as the most significant if they so choose. To tell someone they need to be a chemical engineer or scientist and apply those mathmatics involved to adequately identify significant aspects is a falsehood and definitely misleading for a novice an the inexperienced..or anyone else for that matter.It is intended to be a simple process for an important reason...so anybody regardless of literacy, education and scientific background could do it. :eek: I am very surprised with this statement. In this very forum, you expressed, several times, your disagreement with registrars that would hire EMS auditors that had none or very little Environmental specific knowledge. According to your post, you support an ignorant (from an environmental perspective) individual to be granted the authority to determine significance of aspects. It just does not add up. Actually, in my interpretation, it would contravene the requirements of ISO 14001 4.4.2 which requires people to be competent for their functions. Someone (or a group) tasked with the responsibility to determine the criteria to establish significance has a very important (if not fundamental) contribution to the EMS. I would sure hope that these people are not illiterate, uneducated and do have a grasp about the chemical, biological and physical attributes of the products and biproducts present in their EMS.

Ya'll realize of course I just had an attack of smart asz and couldn't fight it off don't ya? :mybad: My medication isn't working.


Maybe have the doc write ya a stronger prescription, Randy, cuz this time there's a bunch of us regulars that think you're on the short end on this debate...

Have a Merry Christmas, or Kwaanza, or Ramma... or whatever the heck we're s'pose to say this week...

The peripheral vision bit is being able to see beyond the obvious - not an ability to ignore what is in front of you.Well said. :applause: