Has anyone done an implementation in a small to medium transportation (limited to trucks on hi-way) company? Particularly a combined ISO 9001 + ISO 14001 implementation.

Kinda, sorta, to a certain degree. The program I had at ITT had to address maintenance and operation of about 4,000 military vehicles.

What kind of questions do you have Marc? I'll give it a shot.;)

Well, I'm just thinking of questions right now - so my post is a bit pre-mature I guess. I'm pulling together the 9K2K upgrade project but with one client I have to integrate 14001. This is a Ford Q1 requirement (this QOS thing is almost silly). The company is only about 35 souls all told.

I figure I'll put the Q manual together by adding any extra clauses as I did in http://Elsmar.com/pdf_files/ - Look for QS-Req.pdf (a matrix which became the Q manual index in a project quite a while ago). That was a QS-ISO-VDA6 matrix but the principle should be the same. I'm looking at ISO 9001:2000 Annex A Table A.1 right now.

I still have a few questions of them. I know they lease all their equipment (tractors and trailers) and the only thing I know of that they do is minor repairs - such as burned out light bulbs and minor wiring problems on trailers. I don't believe they do any oil changes or such - I think that's part of the lease agreement as are tires and all the other 'major' things one might consider in a turcking company. If they do oil changes - that will be an EPA issue.They don't package anything. I think they have a fork lift they service - so that'll be an issue with oil disposal. Possibly tires. But I know they rarely use the lift because almost all of their business is taking a trailer to a company, getting loaded and going to another company to unload. That said, the fork lift issue should be small. I have to meet with the 'garage manager' next week as he does all the EPA stuff - so I'll get a lot clarified then.

Office is small. Paper intensive so I guess recycling could be an issue.

I guess the first step is an inventory which I'll keep as a record of assessment of what may or may not be 'applicable'. I'll go office to garage.

This list is from another thread:

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

Just fishing for thoughts at this point. So far it doesn't look like a monster...

I remember that list as 1 I provided as example of ASPECTS. Remember that an ENVIRONMENTAL ASPECT is any element of an organization's activities, products, or services that can interact with the environment (like the exhaust from the trucks). All you need to do is develop a procedure for identifying ASPECTS and then follow it. There is no right or wrong way here.

Here is some info.......(not all are required to be documented...but.....)

ISO 14001 required procedures are:

Identification of environmental aspects and significant impacts (4.3.1).

Identification of, and access to, other requirements (4.3.2).

Identification of training needs (4.4.2).

Communication (4.4.3).

Document control (4.4.5).

Creation and modification of documents (4.4.5).

Communication of procedures and requirements to suppliers and contractors (4.4.6 c).

Identification of potential emergencies and accidents, and the response to them (4.4.7).

Monitoring and measuring of key characteristics of operations and activities (4.5.1).

Calibrating equipment (4.5.1).

Evaluating compliance with relevant environmental legislation and regulations (4.5.1).

Preventing non-conformances or taking corrective action should any occur (4.5.2).

Identifying, maintaining and disposing of environmental records (4.5.3).

Performing EMS audits (4.5.4).

In addition to procedures, there are requirements to establish and maintain records and directive documents, such as a company's environmental policy, operational control plans and operating criteria.


Later:bigwave:

This was asked in another thread, but what is your definition of a 'Directive'?

Marc,

Just curious, how did you pitch the use of oil in the vehicles, with respect to significance???

I figure oil is a non-renewable resource, so over a certain usage (per year), it should justify some sort of significance.

Just wondering what you did/thought about it.
;)

Luke, not to steal Marc's thunder, but there are really only two basic questions that must be asked.

1. Is oil usage (either through maintenance, or loss) an aspect? Most of us agree that it probably is. I often describe aspects as those things you store, move, use, spill or dispose of. Oil fits all categories.
2. Is oil usage a “significant” aspect? This question can only be answered by you. Take into consideration things such as disposal methods/costs, usage rates, leaks and losses, storage and movement. Depending on the size of your organization, it could very well be significant.

As a side note, commercial carriers tend to have a rather extensive paper system. Paper disposal/recycling might also be significant.

Hope that helps

Yeah - motor oil is an aspect. But - it's not a controllable aspect. You can't reduce the use without affecting preventive maintenance. There is the aspect of drippings from tractors, but most tractors today are built pretty solidly and, like newer Harley-Davidson motor bikes, don't significantly drip fluids. We did inspect the lot for drippings and found very, very few and all were < 3" dia. with most about 1". Not many total, but honestly I didn't count them but they were 'rare'.

For bigger companies, I think 40 CFR 279 Used oil generator (Container Storage and labeling, Waste evaluation, Shipping) applies.

Don't forget: Batteries Antifreeze Hydraulic fluid Used oil filters Used air filters Tires Tractor / trailor wash runoff water Floor sweepings (garage, if there is one)And what db said.

Oil is controllable to some extent. There are now small relatively inexpensive recycling units that organizations can place in facilities. Antifreeze can also be recycled onsite. There are machines that crush filters to remove the fluids also.

If I were consulting to a company that performs a lot of maintenance I would recommend exploring onsite recycling to help reduce usage and disposal. The initial investment would be recaptured in time.

Marc, I believe that Randy and I (if I might place words in his mouth) were refering to handling waste oil from servicing the trucks. We might not be able to control the amount of waste generated without endangering our fleet. We can however make intelligent choices on what to do with the waste generated.

As far as leaks. The control would be to ensure leakage was rare and small. If an oil cooler is blowing oil, then the impact would of course change dramatically. I think tires would be rather significant. In many places storm water runoff might even be regulated. Check with the state to find out. Michigan has some pretty exact regulations on how storm water runoff is to be handled. I’m can’t say about other states.

Storm water runoff is called "Non Source Point" and is controlled by Fed and State regs.

> Oil is controllable to some extent. There are now small
> relatively inexpensive recycling units that organizations
> can place in facilities. Antifreeze can also be recycled
> onsite. There are machines that crush filters to remove
> the fluids also.

I would look closely at onsite distillers with a doubtful eye unless I was working with a very large company. In part because you may 'cleanse' old oil but there are still particulates which you would have to dispose of including heavy metals. All my clients have just paid to have a recycler haul motor oil and antifreeze away. Oil filters they drain (no need to crush) and the residue is acceptable by the regular trash hauler (yes - we double checked).

> Marc, I believe that Randy and I (if I might place words
> in his mouth) were refering to handling waste oil from
> servicing the trucks. We might not be able to control the
> amount of waste generated without endangering our fleet.
> We can however make intelligent choices on what to do with
> the waste generated.

That's what I'm referring to - used motor oil. As far as having a choice about what to do with it, you don't have much choice. You can recycle it yourself or you can have a recycler pick it up. You can't pour it on roads any more to keep the dust down and you aren't allowed to burn it as was once common. What other choice do you have?

> As far as leaks. The control would be to ensure leakage
> was rare and small.

Yup.

> If an oil cooler is blowing oil, then
> the impact would of course change dramatically.

Well, yes. But this would be a rare, catastrophic event which puts us into the hazardous spill mode.

> I think tires would be rather significant.

Yes - tires are in my list. What I have found is - at least my transportation clients so far - all lease tires. So when they get a new tire the company takes the old one. In addition, while tires are an aspect, can you think of a way to control tire wear (other than preventive maintenance like wheel alignment and balance)? Batteries are also leased/exchange.

> In many places storm
> water runoff might even be regulated. Check with the state
> to find out. Michigan has some pretty exact regulations on
> how storm water runoff is to be handled. I'm can't say
> about other states.

In part that's why I listed truck wash water. The same applies to rain (storm) water runoff. There is also the possibility of flooding and runoff water from that (see how well you've taught me?). With my client we evaluated the property surface aqnd determined the slopes and where water runs. Then we verified that the city checks so that we don't - and they do.

Yup - we're on the same wave length. Gee, this is fun! :thedeal:

I understand your concern there Marc, but there are systems that clean down to a couple of microns achieving results acceptable for passing spectrographic oil analysis. This is one way Uncle Sam is using to reduce consumption and conserve resources on some installations.

I don't doubt that there are such systems. The clients I have are simply not big enough for the economics to make sense. They simply pay a recycler to pick it up.

I'm sure for companies like Fed Ex, UPS, Ryder, U-Haul and such it probably would make economic sense. They will still have to do something with the distillate.

I'm assuming we're looking at a distillation to bring over the oils leaving the contaminates as opposed to a centrifuge (particulates removed leaving many dissolved chemicals) or a 'chemical washing' type of recycling. well - motor oil, anyway. I'd think anti-freeze would be easier to 'cleanse' than motor oil in part due to the blow-by motor oil gets.

Maybe I should be asking, since you apparently know about them - How do they work and what's the cost per gallon (post process)? Any idea?

Either way, however, you're looking at a purely economic issue. The aspect and/or significance does not change because either way you're recycling.

I've got some figures buried somewhere. This is a project I worked on a couple of years ago in support of a logistics contract. I'll try to dig the stuff back up.

Antifreeze is a bit easier to clean. The recycling of it changes some EPCRA reporting requirements and disposal costs. The effluent materials still have to be managed, but the oil that is removed is in itself recyclable.

Paying a recycler is paying for the same material twice. This is not good business. The recycler is reaping a benefit (making money on both ends of the transaction) so they should be paying for the raw material, even if it only pennies per whatever. The same goes for pallet disposal and other materials.

As I say, I understand and agree. The question is whether it's economically feasible which will be a function of company size and their processes. Many smaller companies, for example, hire owner-operators and thus do few oil changes. So maybe they do maybe 200 gallons a month (a few tractors a month) - sometimes less. For that company buying equipment to recycle oil and/or anti-freeze is probably not going to be economically feasible.

Yes - a recycler charges, but I don't know the prices so you may be paying 'twice' but probably not twice as much. Part of that cost is off-loading the liability issues involved in both transportation and the recycling process(es) as well as lawful disposal of the 'residue' (contaminates) from the recycling process.

To me this is not unusual. Any time you sub-contract a part of your process it costs (theoretically) more than if you do it in house. But as the auto industry long ago found, often sub-contracting processes is cheaper than doing it in house. That could lead us to talk about core functions of the business and such.

How many tractors was the contract you were working on? Long distance or mostly local routes? Own their own or hire owner-operators?

It wouldn't really apply in this case I guess. We had over 4,000 vehicles in one location and our oil usage was 60K - 100K gallons a year. Antifreeze was close to the same. Extremely hard usage in the desert.

Marc,
One thing you may want to look at is combining the recycler. We found that the company that picked up the waste oil also would pick up the batteries, etc. it proved to be a significant cost savings. We purchased an oil recycler and found the viscosity to be an issue. We can't reuse it and haven't identified a market for it.

You may already have something like this, but if it helps you're welcome to it.

Yeah. The 14001 clients I have in transportation are small. I'll have to check on the combination of anti-freeze and oil, but as I remember those are picked up by the same recycler.

The other stuff is really out of their control. They lease batteries so the company they lease them from exchange a good one for a 'bad' one (thus assuming responsibility for recycling the batteries in accordance with federal and state law). The same for the tires. Tractors are almost all owner-operator deals.

Neither client is like Randy's case of having 4000 tractors. Very big difference. But that's one of the interesting parts of the project. That is also why it is hard to come up with targets and objectives - so far we haven't come up with any (which we have discussed with the registrar).

Maybe you have to look in instead of out. How much are hey involved in using recycled material like office consumables?

Take another look at how much energy they use. Do they have areas that may be lighted too much or when it's not necessary?

Do they lease their vehicles? Maybe they could specify that vehicles must meet certain emission standards.

What about their suppliers? Maybe they could say that by such -and-such date they will only use X% suppliers that don't have an EMS. They don't need to demand that their suppliers implement systems, but they can attempt to influence their doing so.

Step out of the box for a while and try to view the operation from a different perspective. It may allow some additional creativity.

Yeah - We've done all that. Thing is they've been proactive long before the 14001 thing came up. Energy (electric and gas) audits and the works. 'Special' low energy bulbs and fixtures everywhere. Even low water commodes were installed a couple of years ago.

> Do they lease their vehicles? Maybe they could specify
> that vehicles must meet certain emission standards.

Not feasible with owner-operators, but they do specify tractors less than 6 years old unless they go through an 'extended' inspection.

> What about their suppliers? Maybe they could say that by
> such -and-such date they will only use X% suppliers that
> don't have an EMS. They don't need to demand that their
> suppliers implement systems, but they can attempt to
> influence their doing so.

A small (32 people plus drivers) trucking company is not going to tell Firestone (their tire lessor) about starting up an EMS program. Or Interstate Battery. The problem, Randy, is your paradigm keeps you with big companies in your expectations. Little companies simply do not have the control bigger ones have. Its a bit like telling Kelloggs to implement an EMS or you won't buy their breakfast cereal(s). You have to get one heck of a movement going for something like that to work. And I doubt any individual is going to go out and buy their own corn flake making equipment (ref: recycling equipment in-house) in an attempt to reduce long term costs and/or to reduce environmental harm.

> Step out of the box for a while and try to view the
> operation from a different perspective.

Your turn! :D

To paraphrase the Terminator "I'll be back...after I think on it":frust:

What about in the office portion? Paper, toner, ink, etc. It sounds like they would have it covered but have they looked at air emissions while in an enclosed area (loading dock, service bay)?

:confused:

Originally posted by Randy Stewart
What about in the office portion? Paper, toner, ink, etc. It sounds like they would have it covered but have they looked at air emissions while in an enclosed area (loading dock, service bay)?Simpler than that. They pick up a trailer at location A and transport it to location B. No inbetween storage or anything. Yup - office checked. Paper heavy as often happens in transportation businesses. Toner, ribbons, etc.

Marc

Check out www.greenseal.com and then go to Product Recommendations. Aslo check out Product Standards and Certification and scroll to the bottom of the page for Green Seal Environmental Standards.

You may find something of interest

The audit is over. 0 nonconformances. They accepted no T&Os based upon our evidence (minutes from several meetings, etc.) of attempting to set one or more and failing - and they couldn't recommend any. So - that's another ISO9K upgrade and 14001 registration finished. Whew. I think I hate the darn things as much as, if not worse than, my clients. I've never had a client go down in flames, but I always get 'stage fright'.

Congrads there Marc:bigwave:

Congratulations Mark!

No O&T's? I just can't see how there can be an environmental management system when there is nothing being managed. I guess I don't understand. Maybe it's enough that you have a structure in place in case you do ever find something that needs managing? Or a structure for looking for something to manage? Or just simply managing existing things but not trying to continually improve? Oh wait ...but you do have to improve ...or at least try. And I guess I don't understand a true demonstration of trying without there being O&T's set. Perhaps trying to try (which is what your meeting minutes show...) but not actually trying. If you get my drift.

Well, you passed so there is more to it than that I reckon.

BTW, does the registrar allow you to attend the certification audits? And do you? Kind of curious about the level of participation that they allow...

I've never quite undertsood why a consultant would not be allowed at the registration audit by the Registrar. Would the consultants vapors make everyone tarnish or something?

The audit is to determine the conformance of the system to the standard and not the level of participation of consultants. IMMHO of course.

Lucinda said:

BTW, does the registrar allow you to attend the certification audits? And do you? Kind of curious about the level of participation that they allow...

No O&T's? I just can't see how there can be an environmental management system when there is nothing being managed. I guess I don't understand.
I always attend audits unless I feel the company really doesn't need me there which has happened a couple of times. I explained it was their call - that I didn't feel they needed me but I would be happy to attend but, of course, I would have to charge.

During the audit I just can't answer questions for them directly. I can talk to them 'on the side' (like a sidebar in a trial). But - that said - with small companies I simply have them put me on their organizational chart as a part-time project manager. Then I can talk as well.

As far as no O&Ts, the issue is this: You reach a point where the operation is so simple that you have to 'discover' ways to 'improve'. This is also somewhat true in ISO. In this instance the company has a continuing on-time delivery agerage of 98%. While one might sit there and say "Hey - there's always room for improvement somewhere", in many smaller companies this becomes so much rhetoric. It sounds nice but if you're in the situation is is just words.

Your failure to understand is related to your paradigm that no company is ever optimized. Continuous improvement is often in small steps which, ISO or not, would have happened anyway. An example is a client I had which was small - 14 people. No new hires in over 10 years. All they do is bulk mixing - same thing for over 40 years. Simple chemicals No desire to increase business - everyone is there at 7 AM and leaves at 3.30 PM as they have for about 40 years. They're like one big family. The nice thing is they all lead low stress lives, enjoy what they're doing and have plenty of time for family life (no weekend work or over time). The place is like a dream from the 1950's. When I first went in they had one computer - it was only for labeling (a customer requirement for laser printed labels). Now they have about 10 computers. Continuous improvement but unrelated to ISO. They were just slow to come on board electronically in part because they really don't need computers for much.

But back to 14001, you have to experience a small, stable, long established company and you may (as we did) end up looking to the point of - well, we sell 30 cans of pop a day but drivers take almost all of them with them in their truck - so recycling cans is a non-issue. You know, you can always keep suggesting things but you reach a point of it being rediculous. Does one go so far as to post signs asking employees to try to only use the bathroom once a day thereby conserving water and paper?

I saw the same thing in the old ISO 9001 - statistical techniques. I had a number of clients who were so small that they did not see a need for statistical techniques. I argued with them when we went thru implementation that auditors would have trouble with no ST's identified - which was in fact the case. But the bottom line is they really don't have a need for one. that's not to say that you couldn't - as an outsider - keep saying "What about...?" until you're blue in the face but it doesn't change the fact that they didn't see any as of any value. I had to agree that in their case there wasn't anything they really could do with ST's - as did te auditor after the discussion.

The auditor at that registration audit also didn't like (read didn't believe) that the company had not had a customer complaint in nearly 7 years. Truth was they hadn't and they could prove it.

I've worked with a lot of companies of various sizes and such and there's always a different challange. The auditor (well, auditors) didn't like the idea of no O&Ts but we when through out thinking during the Stage 1 audit and they couldn't show us where you HAVE to have O&Ts - and we could show we went to the "Only 1 toilet trip a day to conserve water and paper" level in evaluating the company. So - what were they to do? It is, however, a part of management review to the operations manager's 'search' for O&Ts.

Check idealism at the door when you enter reality.

My feelings and sentiments exactly Marc.;)

I can hear the arteries of the "Purists" out there splitting open right now.

During the audit I just can't answer questions for them directly. I can talk to them 'on the side' (like a sidebar in a trial). But - that said - with small companies I simply have them put me on their organizational chart as a part-time project manager. Then I can talk as well.
Yep.....been there and done that too:p

I think there are a whole bunch of folks that don't accept the standard as a guide or template for an EMS. As long as the basic requirements are met you can call the elements of your system what you want, and pretty much do with it as you wish.

A quick review of the RAB's EMS equivalent standards (of which I am guilty of submitting one) will show this.

Again..great job:bigwave:

My thanks for the help from folks (including you) in the forums here. It was invaluable to me.

Oh it's not like I don't believe that a company can reach the point you describe. It's just that I don't see how there can be a system in place to manage something that is nonexistent. And then get a certification that says you have it. But it really doesn't do anything. Not because you don't want it to do anything, but because there isn't anything to do - as you describe.

If a company has to be certified, then what else can they do? But it still looks strange to me.

Sigh.

Yes, we had the same policy on our audits relating to consultants being there. They could be there but couldn't answer for the company. The company's rep had to know his own system well enough that he didn't need the consultant to tell him the answers. I recall a company who tried to use the "but our consultant is our EMS rep. We don't have a fulltime EMS rep. Here, look at our org chart" and it didn't fly as well as it did for you. It was fine if they wanted that to be the case, but they still needed fulltime employees to be able to respond. After all, who was going to know what to do when the rep was off somewhere else? So the consultant still couldn't answer the questions. I was just curious if other registrars had the same policy.

Lucinda said:

Oh it's not like I don't believe that a company can reach the point you describe. It's just that I don't see how there can be a system in place to manage something that is nonexistent. And then get a certification that says you have it. But it really doesn't do anything. Not because you don't want it to do anything, but because there isn't anything to do - as you describe.

If a company has to be certified, then what else can they do? But it still looks strange to me.

Sigh.
You have to look at it as a system to monitor for the future. It is open so that should something be identified it can and will be appropriately dealt with. There may be nothing to control now but that does not mean there never will be.

Yes, we had the same policy on our audits relating to consultants being there. They could be there but couldn't answer for the company. The company's rep had to know his own system well enough that he didn't need the consultant to tell him the answers. I recall a company who tried to use the "but our consultant is our EMS rep. We don't have a fulltime EMS rep. Here, look at our org chart" and it didn't fly as well as it did for you. It was fine if they wanted that to be the case, but they still needed fulltime employees to be able to respond. After all, who was going to know what to do when the rep was off somewhere else? So the consultant still couldn't answer the questions. I was just curious if other registrars had the same policy.
The problem is you state:
but they still needed fulltime employees to be able to respond.
I challange you to show me anywhere in any of the requirements where the words 'Full Time Employee' or anything near that is even used. You may come up with something like "Well, it's implied.." but that doesn't get it.

You may not like it because it doesn't fit your paradigm, but you can fulfill any requirement with part time personnel - even responding to corrective actions or whatever. I've held many contract jobs where I was responsible for FMEAs, PPAPs, was part of the design team, interfaced with customers and supliers, etc., etc. and I was definitely not fulltime.

After all, who was going to know what to do when the rep was off somewhere else?
Heck - people take vacations all the time. Who takes over for them? Does a full time management rep ever take a vacation? Yes? Who knows what to do when the full time management rep in your company takes a vacation? There are telephones, e-mail, pagers - hey - no one has to be 'out of touch' in today's world.

Here in the Lexington Ky. area Toyota Motor Manufacturing (TMMK) has the largest private responce team. They actually repond to all emercency issues as far as clean up for ISO14k. They would have information that you might be interested in 1-502-868-2000 ask for Enviromental department. :lick:
They are super efficent, all the checks and balances needed to develop or improve on a system.:bigwave:

To reply to a comment by Marc. We do not use Statistical techniques and have had no problem with 2 different auditors. I think most auditors look at your definition of Statistical techniques rather than push it on you.

gpainter said:

To reply to a comment by Marc. We do not use Statistical techniques and have had no problem with 2 different auditors. I think most auditors look at your definition of Statistical techniques rather than push it on you.

I believe that's quite a bit more true today, but go back 5 years or more and it was less so. One thing I consistently see is evolution of what is acceptable and what isn't. Ten years ago auditors were expected to have direct work experience in the field they're auditing. Now days it's hard to find an auditor with work experience in the field at all.

I also see auditors accepting much more than they ever did. Having been in this game for over 10 years, audits any more aren't half as difficult as they were. There is a lot more that is acceptable today than ever before.

As far as one's definition of statistical techniques - I guess you could say writing numbers in a column is a statistical technique. My statement came from where no statistical techniques were identified at all unrelated to the definition of what a statistical technique is (such as a simple line chart). I haven't had an auditor define statistical techniques - only grouch when the company identified none.