Hi all,

I'd like to hear your opinions on this one:

A company in the neighbourhood got into trouble during the ISO 14001 certification audit, when it was discovered that they had not tested their emergency preparedness routines. (4.4.7. and yes, the nature of their process certainly warrants such procedures). But they got off the hook...

They had recently had a real life emergency and claimed that the procedures had been tested that way. I don't know whether they had reviewed the emergency or not at the time of the audit.

Anyway they got away with it. They now hold a certificate.

/Claes

They got lucky. A real life emergency does is not a substitute for periodic testing. Primarily because it does not involve other people in the process. :)

We have a process that evaluates how effective our emergency response procedures are, with corrective actions or improvements noted. This process is used to evaluate both actual and mock situations.

I agree, the company got lucky. The procedure states that they must 'periodically test' (which would imply a mock situation). They may have passed on the basis that they had a drill schedule, and also if they evaluated the effectiveness of the particular real-life response (I don't know whether or not they did). If they did have a testing plan in place but hadn't yet got around to it, and they also evaluated the effectiveness of the actual response, I can see how the auditor would buy this.

It depends on what their procedure states. If they requie a test every 6 months and exceeded that time limit it doesn't matter whether the actual emergency happened or not, they failed to conform to their requirement.

On the other hand if they stipulate that a test must be conducted, but don't give a specific time period (it must be at least annually or as required by regulatory agencies) an the actual emergency happened, the system was in fact tested under actual conditions, and the requirement has been satisified.

I am curious as to whether or not they did any follow up, reviewed what went right an what didn't and decided on corrective actions for shortcomings.

Of course one can argue that since their entire EMS is brand new, they had not had the time for any drills yet. The question in that case would be if they had planned one? Anyway, I agree with Sam & Dean that they got lucky. My reason for starting this thread is that I can foresee this happening a lot in the future.

I am curious as to whether or not they did any follow up, reviewed what went right an what didn't and decided on corrective actions for shortcomings.
So am I, but I'm afraid I don't have that information...

Claes,

I started a thread earlier this year with respect to your concern - namely, how mature does a system have to be in order to be certified to ISO-14001?

Based on the responses I received, the answer was 'not very'. Basically, if you have documented procedures in place that meet the requirements of the standard, you can set up your audit and claim immaturity of the system as the reason why you can't show progress on anything (targets, drills, regulatory issues, etc.). The difficult part will be the 2nd, 3rd, and 4th audit. This is where companies must show continual improvement and complete records that they are doing EVERYTHING they say they are.

We are starting our system next week (by starting I mean we have ID's all sig. aspects, set our objectives and targets, all procedures are 'live' in our controlled system and we are working on our EMP's). We are set to have our certification audit in September. Basically, I can meet the requirements of the standard for this audit without having any drills, and without meeting any of our targets, as long as I have plans to meet all of these by the end of the year. I don't know if it's right or not, but we need to have the certification by the end of the year and the bottom line is, we better show results for our surveillance audit in March.

Personally, I think that this mainly stems from the fact that most companies are doing ISO-14001 because the Big 3 say so, not because they want to prevent pollution and improve the environment. JMO.

Pretty perceptive of you Dean:vfunny:

Make sure that you have performed some type of internal audit and can show some corrective / preventive action by the time the registrar comes knocking.

And if you're the MR...never, never, never answer a question with "I don't know." Remember you are addressing issues, developing information, so on and so forth

:bigwave:

Hi Dean,

We have reached the same stage as you have, with the certification audit planned for late May. (Good luck btw :) )

The difficult part will be the 2nd, 3rd, and 4th audit. This is where companies must show continual improvement and complete records that they are doing EVERYTHING they say they are.
Aye, there's the rub. You can get the certificate before you are ready to back your words up with action.

/Claes

The reason we have to periodically test ER procedures is to make sure if a "real" emergency occurs, we have the capability to effectively deal with it.

If we say that a "real" emergency is not a test, we are only playing word games. A real emergency will definitely test our procedures. In fact, it is the best test. During drills and tests, we are not dealing with the stress of an actual emergency. During an actual emergency, we are also testing our ability to react under pressure. “Real” emergencies are the BEST test.

With the little information Claes provided, I do not see how “they got away with it”. There is nothing to “get away with”. They have a process and the process worked (an assumption – if it did not work, a “test” should have shown the same failure)

The important thing will be how they analyzed their response to the emergency and how they used lessons learned; not only how they dealt with the emergency, but also what went wrong to allow it to happen.

I think that if the company did have a drill / testing schedule, then you are right, Dave, there was nothing to 'get away with' and they did meet the requirements (as long as they evaluated the effectiveness of the response). The fear is that they were relying on real life emergencies to test their system. I don't think any of us would want to count on live emergency situations to see how our system works.

As for getting our certificate before we achieve anything, well, I hope that is why we are all here, to make sure our respective companies actually achieve what we set out to do and make improvements to our own environments. That's the challenge of any 'system' I guess (quality or env): to make progress and achieve positive results, even if management is only concerned with the certificate on the wall.

I think that if the company did have a drill / testing schedule, then you are right, Dave, there was nothing to 'get away with' and they did meet the requirements (as long as they evaluated the effectiveness of the response). The fear is that they were relying on real life emergencies to test their system. I don't think any of us would want to count on live emergency situations to see how our system works.
Amen to that....

Yep, real life *is* the best drill. If they had a drill scheduled, cancelled it after the real emergency and then went on to evaluate it and implemented the actions decided on that basis... then I think all is well... As I said I don't have that information, but it's certainly a topic worth discussion, because this won't be the last time this happens.

/Claes

The use of "real" emergencies in lieu of “test” emergencies can be a bit tricky. After reading Dean’s response:

The fear is that they were relying on real life emergencies to test their system. I don't think any of us would want to count on live emergency situations to see how our system works.

I can see where he is going, and I agree. My comments were more from the standpoint that if a test was scheduled for Tuesday, and we had an emergency on Monday, then we have met the requirements for Tuesday's test. I must make this clear... at NO TIME would I suggest using real emergencies as the only method! But if a real emergency does occur, I think you can count it as a "test".

As far as registration before you can demonstrate the EMS works, may it never be! But Alas...

Agreed, Dave, and hopefully in that situation we always pass the test!!

A few questions regarding emergency preparedness and response procedures...not sure if it belongs in this thread, but will post it here anyway.
1. Are emergency preparedness procedures only required for significant aspects?
1a. For example, if we have drums of oil on the loading dock as an aspect, but have determined them insignificant because our current control measures eliminate the possiblity of any environmental impact, do we need an emergency response procedure?
2. What if we do have emergency procedures in place that do not apply to significant aspects, s hould those be included within our EMS?
:confused:

My answers:

1. Emergency procedures are required for any potential emergencies, not sig. aspects. There is a relation there, as an emergency (i.e. a spill) could create a significant aspect, but the procedures should be focusing on the emergency itself, not whether or not an aspect is involved.

1a. On your shipping dock, you may have control measures which reduce the potential of an emergency, but there is still some potential for a spill into the environment, so you should have procedures in place. The potential may be very low, but is still there. And I would think that, even though your drum storage area is not deemed significant as is, a spill would probably create a significant aspect.

2. Other emergency procedures (such as injury response, machine entrapment, etc.) may not be a part of your EMS, but it would be useful to include them into this program, if only for the fact that it formalizes the procedures and brings them under document control.

Hope this helps.
Dean

A few questions regarding emergency preparedness and response procedures...not sure if it belongs in this thread, but will post it here anyway.
1. Are emergency preparedness procedures only required for significant aspects?
1a. For example, if we have drums of oil on the loading dock as an aspect, but have determined them insignificant because our current control measures eliminate the possiblity of any environmental impact, do we need an emergency response procedure?
2. What if we do have emergency procedures in place that do not apply to significant aspects, s hould those be included within our EMS?
:confused:

Excellent questions! Although the standard revolves around your “significant” aspects, I think you would not have an effective EMS, if you only included accidents and emergencies that relate to your significant. I think the reason that the standard does not specify accidents and emergency situation that do not involve significant aspects it this. If you have an accident, say, you spill your cup of coffee. A several questions arise:

1) What is the impact of the spill?
2) Would this fall into the category of an “emergency”?
3) Do need to respond to the spill?
4) How should you respond?

Any accident or emergency situation that would result in a “crisis”, should deal with a “significant” aspect. Now, by crisis, I do not mean that you have to get a change of clothes.

As far as your drums of oil, should something run into them, and rupture a few, would that create a “significant” aspect? The level of control shouldn’t dictate whether they are significant. Their potential impact should.

As far as emergency plans that are not associated with significant aspects, I would encourage you to include them. If they are important enough to have a plan, then they should be important enough to audit and ensure they are capable.

-----added----------

Wow! Dean. You posted, as I was writing, and we kinda ran along parallel lines. Man, has your credibility just taken a hit! :bigwave:

Good, quick answers.
I understand that the potential for an impact requires consideration in significance and emergency preparedness (which are totally unrelated),
but now have a follow-up question.


The level of control shouldn’t dictate whether they are significant. Their potential impact should.

Our current significance rating procedure incorporates control measures into the process. My thoughts are "if there are control measures in place to avert the potential for impact and these measures are 'fail-safe,' then is the aspect truly significant?

Is this a correct/acceptable procedure?

Our current significance rating procedure incorporates control measures into the process. My thoughts are "if there are control measures in place to avert the potential for impact and these measures are 'fail-safe,' then is the aspect truly significant?

Is this a correct/acceptable procedure?

My quick answer is no. The fact that you dealt with the aspect doesn't change its potential severity. If you think of an FMEA (provided you know what an FMEA is), we can make sure the failure does not occur, and we can increase the ability to detect it before it occurs, but should it occur, we probably can't do a lot about the severity. Significance is like that. I can do everything possible to contain the oil that is in the drum, but what if it gets out? What is the impact.

Now, before you go nuts. Just because you now call the oil significant, does not mean you have to do ANYTHING different! You have the controls in place, and you might be able to leave it at that, provided you adhere to the controls. Audits would confirm this.

My take anyway. Dean..anything to add?

To be honest, this conflicts with my understanding of how significance determination works...

I understand your line of reasoning concerning the potential impact - what if it does get out? - but the potential for this happening is so miniscule...(we have not only operation controls, but curbing and slopes to eliminate the impact to the environment). I'm not sure I can succumb to the thought that it is significant because it is there.

On a parallel line (and kind of off subject) is a prisoner in a maximum security prison, chained to his bed, guarded by dogs, electrical currents, and rifles and significant threat to society just because he is there?

To continue my original thought,
our significance determination process takes into consideration more than just potential impact. We consider
1. the concern of interested parties,
2. Regulatory Risk,
3. Severity,
4. Frequency, and
5. Control.
What do you think of this?

On a parallel line (and kind of off subject) is a prisoner in a maximum security prison, chained to his bed, guarded by dogs, electrical currents, and rifles and significant threat to society just because he is there?


A quick answer is he was. That is why he is there. If I were to make a list of all known significant threats to society, I would put his name on the list. I would also annotate that he is currently in custody. Agencies do not have to spend any resources looking for this guy.

To continue my original thought,
our significance determination process takes into consideration more than just potential impact. We consider
1. the concern of interested parties,
2. Regulatory Risk,
3. Severity,
4. Frequency, and
5. Control.
What do you think of this?

We use similar things. Although "control" isn't one of them, we do look at the probability of release.

Now, if I were auditing you, I doubt that I would write a nonconformance on the way you determine your significant aspects (based on the 1996 edition). I might ask a few questions about any emergency plans you have concerning the oil storage. I would also ask about the emergency plans that are not part of your EMS. But even then, I'm not certain I have sufficient evidence for any nonconformances. Perhaps an observation or two.

Thanks db.
I think this was a very valuable discussion from my perspective...it should change the way we evaluate our aspects as we are currently evaluating them.
Gus

Late spring we received a minor N/C for not testing the emergency response plan - which was true.

Our corrective action plan was to conduct a test in the summer (with a deadline) as the majority of activities are outdoor seasonally based. The auditor accepted this corrective action plan.

Our test was to conduct several unannounced spot inspection for forest fire fighting equipment and spill kits in our vehicles and quiz the staff on our EMS procedures for fire fighting and dealing with a spill. About 10% of our staff and vehicles were inspected and quizzed

It sounds like we are likely going to be written up during our external surveillance audit (it will be over later this week)

The auditor is concern that our test was not with our highest risk people, who are those who work for us under contract and actually handle fuel and are most likely to come across a forest fire.

I agree that we did not conduct a test with the contractors. – However, we did do a test of the emergency response procedure. Our staff knowledge was good and we discovered one vehicle had some deficiencies in emergency equipment.

Excuse the vent… …

My emergency response question is: does the standard differentiate between a drill and test?

Our auditor is hinting he likes mock simulations rather than a knowledge testing and equipment checks.

...Wilf

Our test was to conduct several unannounced spot inspection for forest fire fighting equipment and spill kits in our vehicles and quiz the staff on our EMS procedures for fire fighting and dealing with a spill. About 10% of our staff and vehicles were inspected and quizzed.


I'm not too certain this meets the requirements, even if you did 100%. Perhaps it is the way you worded it, or perhaps the way I read it, but it sounds more like you auditing rather than testing. I would think a test might be along the lines of you do an unannounced burn simulation to see how the group(s) respond. The important thing is to see if your emergency response system works, not to see if they have the equipment.

Good point.

I would have to agree that asking someone if they know how to use a shovel isn’t the same as using a shovel. It is quite possible that some individuals would not know that creating a mineral guard to prevent fire spread is usally a better method than covering a fire with dirt as the roots can smoulder for a long time.
:)

I'm not an expert in fighting forest fires, but I have worked a bit with emergency response. Another factor to consider is response time of each step in the process. How much time does it take from the event to initial notification? How much time from initial notification to initial response? How much time from initial response to arrival? Typically, the more time each step takes, the greater the impact.

Odd question, how does one minimize the impact of a fire?

Odd question, how does one minimize the impact of a fire?

Get rid of the fuel source?

Change the path?

Put it out?


BTW...If your auditor has concerns tell him to show his butt up when a fire is going on to see if the procedures work.

Get rid of the fuel source?

Change the path?

Put it out?

Okay, but that might limit size, but what about the severity (thinking FMEA here)?


BTW...If your auditor has concerns tell him to show his butt up when a fire is going on to see if the procedures work.

I think this is more of a test of your auditor. There are a few (you and I, I think) that would not hesitate to jump in and grab a shovel. I do wonder how many would run...run far and run fast. :lmao:

[QUOTE=db]Okay, but that might limit size, but what about the severity (thinking FMEA here)?

QUOTE]

That would go with limiting the access to fuel. Severity could also be limited by altering the path from high value areas like residential or improved locals.

Of course it would boil down to how severity is measured.

This is a great link for those of you who want to 'test' your plan without actually shutting down operations and going outside for a drill:

http://www.fema.gov/library/biz1.shtm

Excellent Post, little__cee!! :agree1:

...that was an excellent link. Thank you.

/Claes

In the interest of understanding how a process or enviroments behave and or will behave real time. 3D event simulation is a key to success. We have made leaps and bounds with organizations with simulation and awareness to opportunities and defficiencies.

I would say that in the event of understanding where and when a model behavoir may pose issues it can be updated and tested real time.

If interested have a look at the web site www.flexsim.com you can download the software for a look at the power of simulation.

I also understand that the TS reqiurements will have a component or element of simulation.

Best Regards

Dave brajkovich
dave@flexsim.ca

I found a new link today that I bookmarked as a safety favorite:

http://www.ready.gov/business/index.html

This is very comprehensive and has some great information.

Hello,

I have a question related to "testing emergency procedures in real life." I am about 1 year into the process of developing an EMS for a municipal Fire Department. Through the process of identifying and ranking various environmental emergencies that our staff could potentially cause (4.4.7), the emergency that ranks the highest are releases stemming from accidents involving Fire Department vehicles or boats (i.e. an accident involving a fire truck where the entire diesel tank is emptied into the river, or a similar spill involving a rescue boat).

I have developed an emergency response procedure for this type of emergency that I will be soon training staff on. However, this procedure does not vary greatly from other procedures that staff follow when responding to external (i.e. public) emergencies like car accidents, industrial releases, etc. The only real difference is the need for staff to report large spills to regulatory authorities…when we respond to external releases, it is up to the generator to make this report.

My question is, since our staff respond to external/public emergencies of this type on a daily basis, and also practice this response through ongoing training exercises, do I also have to get them to participate in drills to practice their response to internal releases? Since emergency response is their business, it seems a bit ridiculous to get staff to practice such a drill...sort of like getting a fire station to hold their own fire drill. I'm hoping that records of our daily response to external releases and training records showing that staff are well trained to respond to releases will be sufficient to show that we have tested our own internal release response procedure.

Any thoughts on this topic would be most appreciated. Thanks!

Just identify that because of the requirements you must meet emergency response training (drills) are to be a part of on-going operations. Just be sure that after every training exercise or real deal a review takes place and required improvement occurs with appropriate documentation.

Your business is emergency response...Trust me, if I was your auditor you wouldn't have to draw a picture.