View Full Version : ISO 14001 Environmental Aspects and Impacts - The Chicken Bone Thread
Woraphot 1st November 1999, 05:12 AM I am working ISO-14001 EMS,
I am looking for some example format of environmental aspect analysis and rating system to identify any activities that can have a significant environment impact. Your suggestion would be appreciate.
Thanks,
Jon Shaver 1st November 1999, 09:27 AM You should use your own criteria. Provided they are credible, you will better understand them & they will be "yours".
As a suggestion, consider the "risk" of an event/aspect as a function of its "likelihood" of occuring & the "severity" of its consequences (impact). You could rate each & then use a simple function (multiply the two ratings, for example) to get a priority ranking.
For instance,
aspect = large hazardous chemical release
severity = 8 (scale of 1 to 10)
likelihood = 5 (scale 1 to 10)
risk = 40
aspect = excessive amount of "X" in stormwater runoff
severity = 4
likelihood = 6
risk = 24
aspect = total loss of contents of a storge tank
severity = 10
likelihood = 1
risk = 10
#1 above has the greatest risk.
Its often quite arbitrary, but if its based on credible evidence the method works well.
Jon
Randy 1st November 1999, 11:54 AM Jon is pretty much right on from everything I have seen. There is no standard way of weighing aspects that I know of unless the Europeans or Japanese have one. You may try looking at those groups. They have their act together more than us sophisticated Americans in the 14000 world.
Jon Shaver 1st November 1999, 02:32 PM There are some rather sophisticated ways to identify & measure risks being used by us slobs in USA, but they are mostly exercises in academia.
In the real world simple works best & devising your own (credible) rating criteria is the practical way to go.
Randy 1st November 1999, 04:05 PM No argument from me.
4.3.1 The organization shall establish and maintain..........
The way I look at it is the way it's stated in the standard. The "organization" can use a method like the one you described, a Ouija board, or chicken bones dropped from a bag onto the ground.
How it is done is optional. Establishing and maintaining the system is all that's mandatory.
pdboilermaker 1st November 1999, 09:51 PM For our registered system, we simply counted up the number of each type of waste e.g. solid refuse, air pollutant, water pollutant, etc. and established a pie chart that broke aspects down into a percent of our overall waste.
We then attacked the biggest item the first year, the second biggest the second year {while keeping the 1st program going}.
Forcing continual improvement, it works great, simple yes, easy to understand yes, easy for people on the floor to understand yes, easy to put into place yes,
All these yes answers made the choice easy for us.
Dean Hill
[This message has been edited by pdboilermaker (edited 01 November 1999).]
Randy 1st November 1999, 11:49 PM Makes sense to me. You guys came up with your own system, it works and you can quantify it.
I smell conformity in the air.
Woraphot 2nd November 1999, 03:36 AM Thanks Jon, Randy and pdboilermaker for your suggestion to give some idea of analysis. I hope that I could start the EMS with nice shot.
Thanks,
Jon Shaver 2nd November 1999, 09:16 AM Personally I like Randy's chicken bones idea.
So long as your method(s) for evaluating env'l aspects is appropriate for your operations and has a valid scientific basis you should be OK. Auditors / Registrars are getting anal about the science involved, though, so you may want to get a qualified expert opinion to support your basis.
PD - remember that waste is not the only env'l aspect in most organizations.
Jon
[This message has been edited by Jon Shaver (edited 02 November 1999).]
Randy 2nd November 1999, 10:22 AM That's right Jon about waste not being the only aspect. Most people though are not thinking 3 dimensionally when trying to identify aspects. It even happened at one of my employers other locations.
About the anal thing. I'm pretty sure your right, and I am very vocal about this. Even at this time from what I gather, a majority of the 14000 auditors out there working for registrars, are not environmental professionals. Some may have a smathering of training but thats it.
I consider myself a professional. I hold 2 credentials (1 granted by the Cal. EPA, and not counting my EMS-PA) in the environmental field. I've been working in the environmental field in California for 10 years. I've worked on developing a Risk Management Plan (CAA 112(r)) and all kinds of other neat stuff. I'm not an expert, but I know my way around 40CFR and Cal. Title 22. Nobody in the ISO 14000 world cares because I'm not an EMS-LA. I have nothing worthwhile to contribute. I think I have referenced this line of thought before.
Sooner or later somebody with a certificate is going to step in it. And in my opinion whoever stated that the EMS was conforming to the 14000 standard, without a good professional involved in the process, was in error.
Be that is it may, how are things?
Jon Shaver 2nd November 1999, 10:30 PM Randy - seems we share a lot of interests and opinions. I agree with your thoughts about auditors working with Registrars and have come to the conclusion that most companies out there do too. Using a QMS auditor to deal with scientific matters just isn't practical. This, IMHO, is the main reason why ISO14001 has not taken hold here.
Like you, I've done a fair amount of RMP work - there's still a few places that need help - & have developed a useful approach to process safety management & emergency planning. Starting to get some interest in ISO14001. I'm a PAuditor for EMS & QMS & accredited EMS trainer, but don't really count those qualifications for much.
Too bad we live on opposite coasts, but if there's ever an opportunity here or there lets talk.
Jon
Marcus 19th July 2001, 10:47 AM We are looking into 14001. Currently we don't have any toxic chemicals in house. What Aspects should be listed? The only things we have are things like liquid paper, Tech Spray, (freeze) no clean flux, powerclean, (floor cleaner) conductive cleaner for conductive table tops, soldering iron tip cleaner.... all of these have warnings on the back, but do not indicate they are harmfull to the environment, just humans.
Randy 19th July 2001, 02:48 PM You use electricity, generate solid waste, use water, have air emissions, make noise, use paper, the list goes on. Check the stuff below
Energy
· Natural Gas
· Electricity
· Fossil Fuel
Materials
· Raw materials
· Processed materials
· Recycled materials
· Reused materials
Natural Resources
· Water
· Land use
Chemicals
· Hazardous materials
· Hazardous waste
Packaging
· Paper
· Cardboard
· Plastic
· Aluminum
· Steel
· Wood
· Other materials
Facilities and Equipment
· Design
· Operation
· Maintenance
Office Administration
· Paper
· Toner
Solid waste
· Waste water
· Trash
Noise
· Internal to operation
· External
Think about what you do and how it can interact with the environment.
Marc 19th July 2001, 04:29 PM Excellent list! Thanks, Randy!
goose 20th July 2001, 01:47 AM read 3.2 of the definitions:
Environment includes surrounding,in which the organization operates including, air water land natural resources, flora, fauna, humans, and their interrelation.
Also aspects can be positive as well as negative.
Randy 30th August 2001, 09:14 AM A question has popped up and my mind froze, so I figured I'd use some of your brain cells. Para 4.3.3 states "The organization shall establish and maintain documented environmental objectives and targets, at each relevant function and level within the organization." Does this mean to you that every department like Human Resources, Finance, and Executive has to have O&T's? Or that the relevent funtions are those that have been identified by being the owners of the Significant Aspects? Every department within every organization has Aspects, but not all Aspects are significant and only the significant ones require addressing.
The folks I'm helping are using a procedure based upon a matrix and mathematical formula to determine their SA's. They only identified 2, and these 2 SA's are influenced by the company as a whole (electrical usage and solid waste), and the O&T's for them set up for the company as a whole to improve upon them. What do you think? Do we need to have an O&T for every department?
Jon Shaver 6th September 2001, 12:31 PM Randy - The way I interpret it, you don't need to have o & t at each function/level. You need to have o & t and establish / maintain these at each relevant function / level. There is a difference of course.
Randy 6th September 2001, 12:39 PM That's how I've always looked at it too. I just wanted to bat it about a little to see if I might be going off track.:)
Sam 7th September 2001, 09:39 AM "Or that the relevent funtions are those that have been identified by being the owners of the Significant Aspects? Every department within every organization has Aspects, but not all Aspects are significant and only the significant ones require addressing."Randy,
Being new in this arena, I have chosen to interpret that para. the same as you. But, I'm not sure, I've already had someone ask me about toner cartridges and how we control disposal. In that case all of our departments have copiers and printers. That could be a case for O&T from each department.
I'm going through a pre-assessment audit on 09/27 so I will know then if I'm correct.
goose 7th September 2001, 11:57 AM Randy and Sam,
We have significant aspects which cross into several departments, some of these have O/T at the plant level and are measured from an overall plant perspective. Since our system is new we are almost establishing a baseline.
Once we mature a bit plans are to collect and stratify data by department to see the impact on overall objective.
We just completed Step 1 of 2 Step 14001 Registration process and the registrar was ok with this approach.
Randy 7th September 2001, 12:05 PM Unless toner cartridges have been identified as a Significant Aspect or as an element of a SA who cares as long as you dispose of the according to applicable regulations/requirements. Because of some of the components of many cartridges, they can be considered/classified as hazardous waste (an Aspect) and and should not be tossed into the trash (an Aspect). The best thing to do is recycle / reuse toner cartridges if that option is available.
Remember you only have to address those aspects that are significant with specific O&T's. Many of your other aspects though may have regulatory or other requirements that require them to be addressed also, or that you may want to address. The decision is yours as to your non-significant aspects and what to do with them.
Don't get wrapped around the axle.
db 2nd October 2001, 05:42 PM I agree with Randy, we use a matrix and mathematical formula as well. That is how we determine if the aspect is “significant”. We also include “business need” as part of the formula. That way if there is something that will have a large payback, you can move it closer to the top.
As far as “each relevant function and level within the organization” we use this example. Suppose you decide you need to reduce the amount of paper sent to solid waste disposal (read landfill). One option is to utilize recycling. The objective might be to reduce solid waste, and the target might be by x amount. Some functions such as engineering and the office will probably need different controls than production. The targets for them could be different, yet all departments support the overall objective of reducing solid waste. Each function and level has their own sub-part of the overall plan.
Hope it helps!
Marc 11th November 2001, 10:45 PM Originally posted by Jon Shaver
The way I interpret it, you don't need to have o & t at each function/level.What does 'O & T' stand for?
Marc 11th November 2001, 11:52 PM Originally posted by db
I agree with Randy, we use a matrix and mathematical formula as well. That is how we determine if the aspect is “significant”. We also include “business need” as part of the formula.Would you consider sharing the formula (or preferably an example of your spreadsheet as an attachment in this thread) you use?
The attached is where I'm starting from. This is for a very small company, by the way.
Randy 12th November 2001, 08:46 AM Marc,
I'll check with my present client to see if they'll let me show you what they use.
As for your list, it looks OK. Stepping out of my 14K Auditor shoes and putting on my EHS Compliance Guru ones I'll make some comment.
You may want to consider any identified Aspect that has some regulatory issue attached to it as Significant. You don't need to, but it is pretty common.
You may also address the storm water Aspect as a "Non-source point" potential pollution issue. It looks to me like this is some type of automotive maintenance or manufacturing organization.
Energy (especially) electricity is overlooked by many. Attaching significance to electricity is a good idea. There is lots of waste in all sectors on this one. Setting O&T's for energy usage can result in significant cash savings (usage of profit which has to be made up from increased sales).
I harp on the financial side of 14K more than I do the saving the environment stuff. ISO 14001 is a business management system with "Business" being the key word. Preventing pollution gives everyone a nice "warm fuzzy", saving money by reducing cost brings out smiles and is more readily understandable by the boys at the top.
I'll see what I can get for you today.:bigwave:
Marc 12th November 2001, 09:20 AM The company is a small trucking company. Maybe 35 or 40 drivers. Everything is leased - tractors and trailers. They do oil changes and some minor service but all of that is 'caught'. Tires are taken by the lease company when they wear out. Oil and filters and antifreeze is contracted to a waste disposal company. Garage floor sweepings are contracted. Batteries are exchanged. They even have a contract for furnace filters in their offices to be changed and the used filters taken away by the maintenance contract provider.
About all they do is show up at one place, get trailer loaded, take to next place and unload.
I'd still like to know what 'O & T' stands for.
Randy 12th November 2001, 12:07 PM "O" = Objectives (what you want or intend to do) & "T" = Targets (how much you will do it).
Targets should be, but are not required to be, quantifiable. Something you can chart or graph. If you don't or can't measure it, you won't or can't manage it -- so to speak.
Look at 4.4.3 also in Appendix "A" A.3.3:)
One area that is frequently ignored is Appendix "A". It has tons of useful info on 14K. I also recommend ISO 14004:1996 as a reference document and absolute essential when doing implementation.
:bigwave:
Marc 12th November 2001, 12:16 PM Ah! Ok - that makes sense. Thanks!
Yeah - I have both documents.
energy 12th November 2001, 02:22 PM I'm assuming you client is in OHIO, so this may not pertain to your situation. Probably does, because most state regulation are driven by the Fed DEP.
Here's my long winded 2 cents:
Washing the trucks…You have to capture that runoff and dispose of it. In this state, Connecticut, businesses with certain SIC Codes (mostly all) must have all wastes associated with industrial activity categorized and disposed of in accordance with regulations. You already know that. We even have to have our rainwater discharge monitored. It’s called a Stomwater Discharge Permit. You cannot wash vehicles on the premises without proving there is no harm to the receiving water body.
1. A moderately expensive study of the facility and grounds.
2. A plan for all runoff water from rainfall activity. That means where you store your plowed snowfall, your vehicles, equipment, etc. Anything that can catch rainwater and contribute to pollution of the waterways. (That means the sewers) Every storm water drain must be identified and sampled for a prescribed list of potential pollutants. Then you do an annual sampling of all drains that are not common to each other. They are called outfalls. The Testing Lab puts in a little fish species called Daphnia Pulex. The mortality rate after 24 hours should not be <100% and after 48 hours, not less than <50%. If so, you must put a plan in place to reduce the “fishkill”. All this to protect the waters of the State. Your clients are better taking the trucks to a car wash than having to “Legally” flush that detergent with oil and grease down a drain. All the car washes in this state are required to have discharge permits, so they are “authorized”. Even Municipalities are not exempt. In my town the DEP cited the Street Department for washing trucks without the proper permit. The town ignored it. The DEP came back and shut them down until they figured a way to do it legally. Heavy fines were levied. They installed an underground tank that is pumped out periodically and disposed of.
As for the other facility stuff. All ours goes to an incinerator. If you tell the trash hauler what is going into their dumpsters, and they agree, dump it all. It should be in writing. It’s being burned with tons of other stuff. Going to a landfill is a whole different story.
This area of management is worse than a Quality Mgt System. Rather than unhappy customers, as we know them, the Regulatory Agencies’ CAR’s are far more serious and usually cost you more than money. We all see the companies in the news getting bagged for environmental violations. There is a stigma that goes with “Pollution” violators.:smokin:
Sam 12th November 2001, 05:53 PM Marc, A basic spreadsheet that I use for identifying and rating aspects.
:bigwave:
Marc 12th November 2001, 07:35 PM Thanks, Sam! :thedeal:
energy 12th November 2001, 09:31 PM Do you have an O? & T? for rain water runoff from the building, the trucks, the drive ways and parking lots? Maybe copper, zinc from the building roof, gutters? Roof exhaust stains? Oil and grease from the truck fleet leaks? With 40 trucks, no leaks? Employees cars and their drippings? Salted and sanded snow? Loading dock spill potentials? Ostrich feathers?:p :smokin:
Unregistered 24th November 2001, 12:13 PM Environmental Aspects
This is probably too long winded for this forum and not timely but here goes…
I have worked with two types of aspect identification procedures (those that try to numerically rank an aspect and those that use a yes/no (thumbs up/ thumbs down) significance determination. I prefer the thumbs up/ thumbs down approach, as I believe in simplicity. I am unsure about the added value of a numeric evaluation and arbitrary significance cutoff value. I believe that a numeric system imparts the appearance of objectivity that is not deserved.
As an ISO 14001 auditor I have observed significance procedures that used a FMEA type approach that I think missed the mark. This approach has a tendency to elevate only emergency type environmental aspects to significance.
I think the ISO 14001 standard expects an organization to identify, as significant, those aspects that they control (already have or should have operational controls) or can influence (improve performance). The best way I have found to do this is as follows:
1. Identify the relevant functions of the organization (department, manufacturing processes lines etc.) and prepare process flow diagrams listing the input (raw materials) and outputs (air emission, wastewater, other wastes) of each process.
2. In a table/matrix format list all the aspects of the process that you can possibly think of. Just list them. Don’t think about significance yet.
3. The table/matrix should have columns (like a spreadsheet) for each of the criteria you will evaluate the aspect for to determine significance. I like the following criteria (Regulatory Requirement, Unplanned Release, Cost/Economic Consideration, Other Interested Parties, and Significant Environmental Load). If you want I will elaborate on each of these criteria in another post.
4. Look at each of the aspects on the list and determine if it meets any of the significance criteria. Put an x in the criteria column if the aspect meets one of the criteria. If an aspect gets an x in any column it is significant. Those that do not get an x in a column are not significant.
I have found this approach to be simple, fast and effective in identifying those aspects of an organization that should be on its environmental radar screen. A key to making this aspect identification procedure work is to involve the right people in the process. If the quality department tries to do it in a vacuum it will fail. Involve representatives from the department (relevant function) when developing the process flow diagrams, aspect listing and significance determination. They know the process and will bring much valuable information to the procedure. Also, include an environmental professional on the team when you do this. They understand environmental aspects, regulations etc. and must be part of the aspect identification team.
The aspect identification work is critical to implementation of an effective EMS. If you don’t get this part right the rest of the EMS will suffer. You will be feeding the system the wrong environmental stuff. The result … garbage in…garbage out. Hire a competent consultant to help you with aspect identification. It should take them no more than a couple of day’s onsite to coach you through the process. The result will be well worth the investment.
Randy 25th November 2001, 05:01 PM Or......you can write each aspect on a chicken bone, toss all the bones into the air,, and the ones that land face up you can call your significant ones.:biglaugh:
Prove me wrong....;)
All that is required is a method and that the method be followed.
Oh yeah, you don't even have to do anything with the ones that you determine to be significant. The choice is yours.
:bigwave:
kalehner 26th November 2001, 10:55 AM Why would you want to do the chicken bone thing and then do nothing about the significant aspects? The reason we do this work is to try to improve our environmental performance, not just pass an audit. Also, I believe that a registrar could safely make a finding that the organization was not meeting its commitment to continual improvement and/or its commitment to prevention of pollution if the organization had identified significant aspects and then chose to do nothing about them.
Randy 26th November 2001, 12:39 PM 4.3.1 States ".....The organization shall ensure that the aspects related to these significant impacts are considered in setting its environmental objectives."
"Shall consider" does not mean that it is mandatory to use them in setting objectives. It means to look at them and if you want use them fine, if not that's fine too. They just need to be taken into account.
The real reason behind doing this work is to manage our business in a more profitable manner by taking into consideration our environmental performance and improving upon it. By doing so our emphasis is placed on placing environmental considerations at the design and front end of process's where it is less expensive than at the waste end, ensuring that our business is as environmentally consious as possible by integrating protection of the environment into the full scope of what we do, and continuously striving to improve upon our activities.
This will tend to make us more profitable, and give everyone a nice warm fuzzy by protecting stupid owls, turtles, knatcatchers and creepy crawly's.
As far as I'm concerned, continual improvement is system wide and not just related to aspects, O&T's.
Re-acquaint yourself with the phrase 4.3.1 "....over which it can be expected to have an influence.."
Toodles:bigwave:
db 26th November 2001, 05:29 PM Marc asked:
__________________________________________
Would you consider sharing the formula (or preferably an example of your spreadsheet as an attachment in this thread) you use?
__________________________________________
Sorry about taking so long to respond. I really can’t give provide the example for propriety reasons, but reading the guest’s comments (please register, we need your thinking) is pretty close to what we do. The key is to get the aspects down in writing so you can analyze it. I also looked at both Marc and Sam’s attachments and they both appear to be workable.
I’ve known others to base aspects off process maps. We all know that they are required by ISO 9000 (Oh sorry, wrong topic and wrong soapbox). :frust:
Dave B (the other Dave)
Randy 26th November 2001, 07:26 PM Here is an excerpt of an Aspect/Impact evaluation tool used by an organization I have been assisting. Explanatory info is in a table at the bottom.
Marc 26th November 2001, 07:42 PM Thanks!
kalehner 26th November 2001, 08:28 PM Here is a link to a site where you can download a procedure that covers 4.3.1, 4.3.3 and 4.3.4 and all the supporting forms.
http://envcompsys.com - Link was: /products/aspect_download.htm
Marc 26th November 2001, 09:19 PM Originally posted by kalehner
Here is a link to a site where you can download a procedure that covers 4.3.1, 4.3.3 and 4.3.4 and all the supporting forms.
kalehner didn't identify himself, so be aware this is his/her web site (as opposed to 'a' web site as stated) and there are conditions attached. They require the following info:
Your Name:
Company:
PO Box / Suite:
Street:
City:State:Zip
Telephone:Fax:
Email Address:
And it specifically states:
You must accurately fill out this form to have authorization to use the procedure for your company. Any reuse of the procedure for companies other than that listed in this form is not authorized.
This is to say they are not free per se, but rather an exchange for your company information. And you can't download it and post it here to share with everyone. This reply is in keeping with our theme here that affiliations must be stated.
energy 26th November 2001, 09:22 PM Originally posted by Randy
Or......you can write each aspect on a chicken bone, toss all the bones into the air,, and the ones that land face up you can call your significant ones.:biglaugh:
Dem bones dem bones dem dry bones....Is that some kind of roostertail voodoo?:rolleyes: Because this is, like six sigma, a topic I could care less about, I need to learn to more. I may be missing something. As an outsider, there appears to be some younger sea lions trying to take the harem from the Bull. My money's on the reigning Bull Shi...! Go for it Jarhead.:agree:
There may come a time when Management hears about this stuff and it becomes the fad of the month. I really am learning a lot of stuff not to worry about!:eek: :smokin:
Randy 27th November 2001, 08:47 AM I use the chicken bone thing as an illustration when I teach and assist organizations on 14K implementation.
Too many times folks are told that the only way to do Significant Aspect determination is to follow some pre-concieved rules and formulas and all that crap.
I tell folks all they have to do is have a procedure (of their choosing not some stumble butt auditors...remember I'm an EMS-LA myself) and follow that procedure. They can use charts, or formulas, lengthy complex spreadsheets, chicken bones or a blindfolded chimp with a dartboard, it's the organizations business on how they do it. They do need to 'consider' regulatory issues and all that other hoopola too, but there is no need to complicate this stuff.
I find it quite disheartening when "Professionals" fail to accept that 14K only requires that the 'minimums' be met, and they try to over complicate a relative simple document.
:bigwave:
kalehner 27th November 2001, 09:05 AM I believe that almost all EMS auditors regularly auditing for Registrars would consider the chicken bones approach and no action on any significant aspects a showstopper.
Randy 27th November 2001, 09:14 AM I'm an EMS Auditor and I do some work for Registrars, and as long as an organization does what the standard requires and they state they will do according to their procedures and policy where can I find them wrong?
As an auditor your job is to determine conformance to the standard in question, and not to impose your own mindset on the auditee.
Do they confrom to the standard? Yes No
Are they complying with their policy? Yes No
Are they complying with their procedures? Yes No
What else is there pardner?:confused:
kalehner 27th November 2001, 09:58 AM Randy, I guess you and I just disagree on this. To me no action on significant aspects would probably cause me to find that there is no evidence of commitment to prevention of pollution or continual improvement (a major nonconformance to 4.2) especially if the organization had what I would consider, as an environmental professional, many significant aspects.
This discussion highlights some of the problems with the standard and the registration system. The standard is vague and registrars are applying a wide range of interpretations of it during audits. The registration game is becoming more competitive and there is a chance that registration decisions could be influenced by a need to retain customers rather than a reasonable interpretation of the standard.
This could lead interest groups to rightfully characterizing an ISO 14001 registration as simply green wash rather than objective evidence of an organizations commitment to continual improvement, regulatory compliance and prevention of pollution. I believe as EMS professionals we need to be diligent and try to prevent the proliferation of that sentiment. If we fail it is likely that an ISO 14001 will become meaningless.
Randy 27th November 2001, 12:02 PM I guess this is a subject that seperates the men from the boys (or ladies from the girls as the case may be).
Where is it written or implied that significant aspects must be of the negative/potential polluting kind? The term is neutral. What if the only significant aspects identified by an organization were of the positive type...i.e recycling program, energy conservation program, hazardous waste management program, etc..? What if the organization determines that they are under control, being properly managed and in a state of continual improvement from the get go? What does the organization do now? Does the organization not have the right to determine how it conducts its business?
Have you ever heard of the word "initiative"? What would be wrong with dis-regarding the above significant aspects in lieu of something else. What would be wrong with let's say..An aspect that was identified (non-significant using whatever blackmagic procedure that was in place) was the vehicle parking areas for potential non-point source pollution. What would be wrong with looking at it or at any other aspect that may provide the opportunity to comply, prevent and improve?
You need to step back along with many others, take a breath of fresh air, and get away from this tripe that significant aspects are and must only be negative in nature and they 'must' be assigned O&T's. I say Bullfritters.:p
kalehner 27th November 2001, 12:56 PM I fully agree that significant aspects can be positive, negative or both. I still think if you call something like energy use significant you need to be doing something about them even if they are listed as positive aspects. My bologna detector starts twitching when an organizations claims they have already done everything they possibly can to improve their energy usage performance and see no need to establish an objective and target for this significant aspect. How can an auditor obtain objective evidence of an organizations commitment to continual improvement if the organization claims that it has already done everything it possibly could to improve its performance?
Randy 27th November 2001, 01:49 PM Please show me where an organization "has" to do anything other than "consider".:confused:
JodiB 10th December 2001, 06:36 PM YES!! YES!! YES!!
Kevin, I'm in love!!!
Randy 10th December 2001, 06:53 PM Nobody likes Randy:(
energy 10th December 2001, 07:12 PM Maybe I'm missing something here! Is there a cryptic message here for "singles" who need a synthetic environmental friendly lamp oil rub down under energy saving lights while perusing environmental articles! Holy Schmoley, Glockle Moley:p Im asuming that I missed something, but none of the posts I've read on this topic has lead to me to having an "terrestial event" such as I just gained access to. Keep it real, Environmental Gurus:eek: This isn't a "one upsmanship" contest. What you see is just your perception, and that doesn't make it so. I learned that.:( :smokin:
Edited to remove some things that make me feel bad!
JodiB 10th December 2001, 07:14 PM But I have to admit I go for that strong, "let's abide by the intent of the standard" kind of man ! I'm not so keen on the "loophole larry's" ( no offense intended toward the regular kind of Larry's!)
I can tell you know your stuff Randy. But I just don't like for games to be played with the words of the standard that end up with the intent of the standard and the strength of the standard being watered down.
energy 10th December 2001, 07:49 PM Originally posted by Randy
Nobody likes Randy:( I told you it wouldn't be easy:biglaugh: Time to re-trench, break out the heavy hardware and prepare to repel boarders!:vfunny:
Just remember, the numbers of the opposition don't change the battle. Be like "The real Carl". Sooner or later, the message gets through. Purists live in a dream world that you can't fathom. Just keep on truckin!! Like me, you've been around too long, Old Man:ko: :bonk: :smokin:
mdobovsek 9th January 2002, 02:29 PM I´d like to comment that we add two more significance criteria:
-If the aspect is related to an item of the company Environmental Policy (ISO req. to specifically mention the very significant aspects in your polycy: ex. energy use in aluminium plant) to give a frame of reference to it
-If the aspect is related to an O&T already set: one may not reach the target because of an new aspect not correctly controled (no matter if it would be not significant for itself alone).
Best regards
Marc 10th January 2002, 12:38 PM Originally posted by Sam
Randy,
Being new in this arena, I have chosen to interpret that para. the same as you. But, I'm not sure, I've already had someone ask me about toner cartridges and how we control disposal. In that case all of our departments have copiers and printers. That could be a case for O&T from each department.
I'm going through a pre-assessment audit on 09/27 so I will know then if I'm correct.Were you correct or not?
Sam 10th January 2002, 03:19 PM Marc, Essentially, yes I was correct in my assumption for our application. As stated by Randy earlier we are only required to have O & T for those aspects that are classified as significant.
As stated by our auditor "the key word in the standard is "relevant". If each department has an aspect classified as significant that would be relevant, therefore an O & T would be required from each department."
Are there significant impacts in human resources, finance or he executive areas? Only the person doing the research within there facility can answer that question.
Note, Having spent a little more time reading the standard ISO-14001, 1996) I find it interesting that the term " significant impact" is not defined"
Marc 10th January 2002, 03:32 PM Thanks for the feedback. I'm back from LA and hot on the track of gettting all this stuff together for a client and I'm interpreting it the same way.
This is a good thread. Lots of good information. Some simple stuff, some complex stuff. And the files folks attached - hey - they're a great help.
> Originally posted by Randy:
> Nobody likes Randy :(
Ummmm, sure we do! :D It's energy that I'm worried about. :thedeal:
energy 10th January 2002, 04:18 PM Originally posted by Marc
> Nobody likes Randy :(
Ummmm, sure we do! :D It's energy that I'm worried about. :thedeal: Has somebody (s) been badmouthing me? Let me guess!:biglaugh: :ko: :smokin:
Marc 10th January 2002, 04:34 PM I guess I should have said:
Between Al and energy alone we have humour and tragedy. Throw in some 'quality', road kill recipes, calibration and such and - voila! The Cove Forums! Reminds me of that sign "You Gotta Be Nuts To Work Here" :bonk:
Naw You didn't do nuttin'. You're just easy to pick on. I never had a little brother to pick on, but had two older brothers who had few qualms about picking on me. So - I'm picking on you and Al to make up for not having had a little brother to pick on. I DID have a younger sister - by 6 years - but if I picked on her my big brothers would quite well take care of me so I had to leave her alone (yes - I found out the 'hard' way - don't pick on the baby sister). :thedeal:
kalehner 10th January 2002, 07:27 PM My understanding of 4.3.3 is that you do not even need to have objectives and targets for all significant aspects. Some of your significant aspects will need only operational controls. An example would be something like storm water. You decide that storm water is significant because it is regulated for your facility i.e. you need a permit. The permit says you will have a Storm Water Pollution Prevention Plan (SWPPP). The SWPPP says you will perform and document periodic inspections of the facility for evidence of storm water contamination.
The SWPPP is an operational control that is auditable. There is no need to establish an objective and target for the significant aspect storm water.
kalehner 10th January 2002, 10:08 PM Mdobovsek!
Great comment! If the policy specifies environmental aspects to be considered the significance criteria need to reflect this priority.
I am not sure I understand your second comment about not reaching a target because of a new aspect. Could you elaborate?
mdobovsek 11th January 2002, 06:38 AM Dear Kalehner!
Let me explain with an example:
We have an O&T related to minimize use of resources, specifically the use of water (we are not a heavy energy/resource user as a pharm industry...)
The target is to messaure the water use related to sections/equipments in plant.
We already installed 10 instruments. Monitoring is on the road
(6 month ago)
Now, we have a new project with new equipments.
We performed analysys of the future aspects of the project; one of this was water consumtion of new equipments.
After analysis, the quantity of water wasn´t significant by itself.
But, the significance is, this water use need to be mesaured ----> for monitoring purpose related to the O&T set.
Consecuence: instalation or verification that the equipment is on a line that have an instrument: we need to mesaure AND control ALL water use.
Det Norske Veritas (our registrar) is very sensible to O&T ( i agree with them). They think:
-we asses your environmental system-
-this system must adress your significant aspects
-you choose wich one include in an O&T
-you choose the Target
-if you do not get the target your system is not functioning as needed (of course if you have a very good reason they may overcome this, but many Target not fullfilled would kill your certification)
This is why we include the relationship between Aspects and O&T on the road; no mater if the aspect itself an alone is not significant.
I hope it clarified sth for you!
Best regards
:)
Marc 25th January 2002, 02:35 AM Makes sense to me. As does kalehner's post. :thedeal:
db 10th April 2002, 01:25 PM This is an update to an older thread, but it is valuable information. We often ask if regulated aspects need to be considered significant. This question was asked to the U.S. ISO 14000 Technical Advisory Group ("TAG"), which is the American National Standards Institute's ("ANSI") sanctioned body to develop and advance the official U.S. position in the International Organization for Standardization's ("ISO") Technical Committee 207. They delegated to U.S. SubTAG 1 the authority to represent it in Subcommittee 1 of TC 207. Here is the question and their response.
--------
99-03.A3
Question
When an organization is identifying its environmental aspects pursuant to Section 4.3.1, must it identify the environmental aspects of other organizations?
Answer
No. Section 4.3.1 requires that the organization “establish and maintain (a) procedure(s) to identify the environmental aspects of its activities, products or services that it can control and over which it can be expected to have an influence, in order to determine those which have or can have significant impacts on the environment.” This requirement applies to the environmental aspects of the organization implementing the EMS, not the environmental aspects of other organizations. Further, the requirement applies to those of its activities, products and services over which it has influence and control: both elements must be present.
-------
Notice: This is the "US" SubTag.
db 10th April 2002, 05:13 PM I posted the wrong question. Best two our of three?
--------------------------------------------------------------------------------------------------------------
99-03.A2
Question
Must a regulated environmental aspect automatically be considered a significant environmental aspect?
Answer
No. Section 3.3 states that “[a] significant environmental aspect is an environmental aspect that has or can have a significant environmental impact.” ISO 14001 does not establish the criteria for determining significance.
----------------------------------------------------------------------------------------------------
Randy 10th April 2002, 05:48 PM Where is my bag of chicken bones?;)
Lucinda will probably choke, hemmorage and have a case of appoplexy over this one db.:biglaugh:
JodiB 10th April 2002, 06:17 PM Originally posted by Randy
Where is my bag of chicken bones?;)
Lucinda will probably choke, hemmorage and have a case of appoplexy over this one db.:biglaugh:
Keep dreaming Randy! Of course they would give that response. It is a black and white answer that is to the letter exactly correct. The type of answer one would give in trial testimony. State the fact, give no opinion. They can really do nothing but that. Did the questioner expect something different??? Could you imagine the whole uproar and flack if they actually spoke outside the text of the standard? Oh my, gives a girl the vapors!
I don't dispute it. My comments relate to certification in particular and general practice ..well, in general. Certification in particular will look at the effectiveness and application of the sig test - and those permitted activities should be included. General practice in general says that your permitted activities can have some pretty serious consequences if not treatly "significantly".
I use alot of words. I would hope that somewhere in them I am communicating clearly:) Apparently not. The exact words of the standard are not in question. Never have been.
Marc 2nd January 2004, 10:51 AM Blast from the Past!
Randy 4th January 2004, 12:35 AM You absolutely would not believe the laughs I get in the EMS courses I teach when I discuss the "Chicken Bone" method or determining significance :biglaugh:
What's really funny is when it starts sinking in and folks obtain just a little insight into what they really need to do to meet the unique needs of each of their respective organizations when it comes to determining what is sigificant to "them".
|
|