We have a stubborn Quality Management Representative who is also oversseing the work we do. She read couple of Risk Evaluation and Management Books and she insists on putting in non-normal condition aspect for each environmental aspect we evaluated so far.

Now ISO 14001 states that an organization should also consider non-normal operating conditions in process of finding out significant environmental aspects. Would anyone give me an example of an environmental aspect showing nonnormal operating condition?

Let's say I have contaminated rags as aspect. What would be the non-normal condition of this aspect? How would I suppose to show an auditor that I took nonnormal conditions into consideration?

Any and every bit of help would be greatly appreciated...

We have a stubborn Quality Management Representative who is also oversseing the work we do. She read couple of Risk Evaluation and Management Books and she insists on putting in non-normal condition aspect for each environmental aspect we evaluated so far.


...

First, I guess the Quality management Rep has nothing to do with your Env. aspect except when she is also assigned as Env. management Rep...:bigwave:

Second, as per my experience, we evaluated ALL our processes and determined ALL the potential and probable aspects that could have potential impacts to the environment.Say for example, if we have oil-contaminated rags, the potential aspect would be it might be thrown in the sewage that can cause Water Pollution(impact) and since our Governemnt released a Republic Act on Throwing Oils (used or non-used oil), this aspect would now become significant. We now consider this as Non-normal conditions...or maybe you have another definition of Non-normal condition...:)

Dear Ugurkavi,

Under the normal conditions, the generated "oil contaminated rag" will be collected, handled, stored and disposed off in a way specified in your procedure (which has been perhaps established (4.4.6) to reduce/eliminate the environmental impact due the generation of contaminated rag). An abnormal (non-normal, as you say) situation is that which deviates from the established procedure - that is the rag is not collected, stored, handled or disposed off in a way as prescribed. These deviations from the procedure can cause environmental impacts. For example, if the procedure requires that the contaminated rags have to be stored in closed containers in sun/rain protected rooms with impervious floors, before sending them for disposal and if you find that they are collected in open containers and stored in the open on soil, there can be impacts on (pollution of) soil, water and air. BS 7750 (precursor for ISO-14001) did warrant evaluation of environmental effects under normal, abnormal, accident, shut-down and start-up conditions and in principle that applies to ISO-14001 (section 4.3.1) too.

By the way, an abnormal situation may not always be linked to the procedure as mentioned above (that depends on how much of analysis had been carried out before the procedure was established); for example, a tap is supposed to let out a liquid only when it is open - that is normal. An abnormal situation is when the tap leaks and lets out the liquid, however small the quantity is. In a good procedure, the abnormal situation is taken care of by providing a secondary containment, which can at least hold 1.5 times the capacity of the primary container. In normal circumstances one will have the liquid container placed in a secondary containment. An abnormal situation will arise if the secondary containment is not effective (e.g. the effective volume has been reduced by keeping some other containers too in the same secondary containment); the impact is obvious.

In my opinion, your Quality MR is right in pointing out this to you - that will improve the effectiveness of your environmental management system; but in my opinion this should have been done anyway as a requirement for assessing environmental aspects.

With best regards,

Ramakrishnan

Anyone can guess what normal situations are.
Abnormal or non-normal conditions are conditions like when there is a fire, flood, sudden evacuation, strike, etc.......
You have to consider the impacts of those conditions on your situation.
Like f.i. what can happen when there is a full production going on and people have to be evacuated. In some situations this can have a serious environmental impact if not handled well. You have to forsee this in your risk analysis.

Best regards,

Antoine

Thank you all for your valuable input. It cleared a lot of fog in my mind. We are still in the process of identifying and evaluating environmental aspects and their impacts and we will definitely put more attention in detail. :thanks: