I am slowly working though this EMS me-larkely, and have come up with the following question (it is mostly common sense, but I just wanted to check).

To what level of detail must action plans be published inorder to achieve accreditation???

Here is an example, to help clarify my thoughts.

---------------------------- example --------------------------------------

Objective : To reduce water usage

Target # 1: To reduce water abstracted from the river by 10%, by April 30th 2003.

Action 1 - To reduce the water consumption by the
Pulper by 5% by January 30th 2003.

Action 2 - To reduce the water consumption by X
process unit by Y% by April 30th 2003 (in
order to achieve the target # 1).

Target # 2: To reduce town water usage by 10%, by April 30th 2004.

Action 1 - To reduce the water consumption by X
process unit by Y% by April 30th 2003 (in
order to achieve target # 2).

---------------------------------------------------------------------------------

Still with me? :) , nice one. So as I undertand that for EVERY significant impact, where there is no current control I need to either asign an objective and traget, or assign an action to achieve an existing objetive and target. Right????

So taking the example above and assuming I have another 20 or so significant impacts relating to water usage (hence each requires an action). Do I have to detail all 20 actions that are to be completed for each objective in order to acheive accreditation, OR can I just state the overall Objectives and Targets???

:smokin:

Luke,

Remember you do not have to have a control, objective, or target for all of your significant aspects. You actually don't have to set targets on any of your sig. aspects, you only need to 'consider' them. (If your significant aspect results in a legal compliance issue, then you should have some type of control in place to show compliance.)

As for your action plans, you only need to document what you are going to do to meet your target. For example, we set a target to reduce our solid waste going to landfill by 10%. The following solid waste was considered significant at our facility: cardboard waste, paper, plastic parts, wooden pallets, oily gloves & rags, etc. Our action plan has been set to remove cardboard from the solid waste stream. Basically, we are not setting action plans on all of the solid waste components, just the cardboard, and by focusing on the cardboard we will achieve our target of 10% reduction.

Also, remember that the Objective and Target is WHAT you want to achieve, the Environmental Programs state WHO, WHERE, WHEN, and WHAT you are going to do to achieve the targets. The specific details on how you are going to perform you EMP's is handled through Operational Control, in the form of procedures and work instructions.

Hope this helps.

Listen to Dean there Luke (of course Lucinda will hemorage over this). Check back through the Threads and you will see how we beat the poor Significant Aspect horse to death a few times.

What you have provided as an example is fine. ;)

Dean,

Remember you do not have to have a control, objective, or target for all of your significant aspects !!!!!!!

:bonk: :bonk: Well if that's true than I have been completely missing the boat, as it was under my understanding that all significant impacts have to be controlled in someway or another either now or in the future, provided it is practical and econmic.

Can you give me a pointer on where I can find this clause in the stanadard, as this will considerably change my workload
:D !

So, i guess this is bringing every thing around full circle, but if we are not required to control every significant impact, how do we decide which ones to control??

Many thanks for your help, I hope my tone comes accross right! I am mostly surprised that I have been barking up the wrong tree for so long, (maybe i should have read the standard in the first place :bonk: )!!

The organization shall ensure that the aspects related to these significant impacts are considered in setting its environmental objectives.

This is part of 4.3.1. You're only required to take significant aspects into consideration, it is not mandatory that you use them.

You control those that YOU feel that YOU can.

Check out my "Chicken Bone" theory.

That's part of what makes IS0-14001 a manageable system. You decide what you are going to control, and you show evidence that you are doing it.

Thankfully, it does not mandate us to control our significant aspects. If we were required to do so, it would mean ~$3 million investment for our company - this is where the 'shall consider...significant aspects, technological requirements, financial requirements' comes into play. Just make sure you set a reasonable, definable target that will improve your environment (in some way), and set an action plan to meet that target. Whatever you do is your decision, not someone else's.

Correctamundo Dean!!:bigwave:

There are some (as can be located here in the Cove) that think otherwise though.

Right, i'm just slightly confused.

I can accept that as far as the standard goes, we are required to control our significant impacts within our resources.

Which would practically mean limiting the significant impacts generated by the assessment, to a number that I have the resources to control (by setting a score threshold - well a limbo bar basically). O.K, that makes sense. On a scale of 100, u could start off with say all Impacts above 90, then as resources became available drop to 80, and so on.....

You guys are saying, that we can stop the bar at any point we want.

So how does that work with continuning accrediation???

So inother words once all legislative issues have been addressed there is no requirement to do anything else, but continually improve our performance, which is completely up to how little or how much the company wants to provide as resources!!!!

...actually just to repeat myself so i can be crystal clear, provided we meet all legislative requirements, then the only thing that needs to happen to remain accrediated would be for the the company to continually improves its environmental performance, DEPENDING on how much resource the company is willing to commit!!!!

....wow, it takes my breath away, basically ISO 14001 is just a standard that says a company meets all its legislative requirements, and at its ABSOLUTE discretion also continually improves its environmental performance.

----------------------- CAn I ask One last Question -----------

So in the case where we are not complying with legislation, is it possiable to become accreditated, provided there is a plan to deal with the issue (such as an unauthorized discharge to the river) as an objective and target????

OR

Should ALL situations where there are non-compliances with legislation be dealt with prior to acceditation.

:smokin: :ko: :smokin:

Once again many thanks, I have a meeting with the MD is a few days, where I am going to have to push for the minimum work required (i.e. engineering work, Oil Bunding, etc.) to get the standard (as they are just not providing the resources!!), which is why i want to be absolutely certain for what is explicity required as a minimum...

Stick with me guys, I will get there in the end!!!!!!

:thedeal:

Last things first - you can achieve accreditation to ISO-14001 if you are out of compliance with the law, provided you have an action plan implemented to regain that compliance.

Even though the standard allows you to set your own targets for improvement, the intent of the standard (IMO) wants you to improve the environment as best you can. The theory is that you identify all of your significant aspects, and set targets to minimize the impact of whichever ones you choose. Assuming you hit your target, this impact should then drop off the radar screen, and you start working on the next ones. The standard is managable in that it allows you to skid some of your significant aspects if they are too costly or technically advanced for you to put anything in place.

Auditors can also usually pick up on a company that is doing the bare minimum. It is true that you can meet the intent of the standard by meeting your legal requirements and setting minimal targets for improvement, but if a company is lacking in this area, it is probably not putting the resources in place in other parts of the standard (document control, operations, management review), and this will get picked up by 4.4.1 ("...management shall provide resources essential to the implementation and control of the system..."). Believe me, I make this statement based on previous experience!!!!

Bottom line, you can get away with setting minimal targets for improvement, and meeting your legal requirements. And if you do this, you are still doing better than 90% of the companies out there. In reality though, we should want to do everything we can to improve the environment, so we should be pushing management on a daily basis to set high goals for the organization (reachable, but high). This will be the only way to realize the true value of an EMS, socially and financially.

Listen to Dean, Luke.;)

He is giving you good solid stuff.

Dean, you sound like a good teaming partner to me
:bigwave: Where have you been hiding?

Just sitting back in the shadows, Randy, absorbing all of the Cove's knowledge.

Actually, I implemented an EMS at my last place of employment, and due to lack of management committment, it failed miserably (my job at the time was also Tech Service to our customers in the rubber industry, so that had to take priority for me). I recently started my current job, which is to develop and implement an EMS (and certify to ISO-14001), and also get a handle on our 'other' environmental issues. Being an automotive component painting facility, you can imagine the issues we have!! We should be certified by the fall, then I'll see where the road takes me...

Anyway, I really enjoy the EMS side of business and have done everything I can to learn about systems and practices for enviromental management and improvement (I think it might be my niche in life). I also enjoy debating / discussing the interpretations of legislation, standards, practices, etc., and this Cove has given me plenty of discussion and debate in the short 5 months I've been involved with it.

I also like the fact that this is a team, that everyone is trying to help each other, none of the typical "that's not my job" issues that arise in the workplace.

Thanks Dean,

you read through my long winded ramblings and provided me with what I needed to hear.

I am personally very, very driven to improve the environment we all share, i was just strugling with this EMS, which just seemed to be getter harder and harder to implement.

Now with your excellent advice, I have decided to tackle the legislative issues first, followed by a few significant impacts (as obs and T's) once the system is fully implemented, and up and running, I will work on doing some real work on top management side to really push the environmental performance envelope.

Many thanks to the BOTH of you for such quick and informative replies... Till my next question then!!

Luke

:bigwave:

Hi, i agreed with the opinions stated in this thread but i hope to clarify something.

I hope to clarify on "what we should do for a significant aspect?"

My understanidng on this is:
(a) consider those significant aspects in your O&T but not neccessary to set a O&T for them

(b) control ALL the identified significant environmental aspects - having operational control on those significant environmental aspects within our resources


Remember you do not have to have a control, objective, or target for all of your significant aspects.


The Clauses 4.4.6 Operational Control stated that :
"The organization shall identify those operations and activities that are associated with the identified significant environmental aspects in line with its policy, objectives and targets. The organization shall plan these activities, including maintenance, in order to ensure that they are carried out under specified conditions by:

(a) establishing and maintaining documented procedures to cover situations where their absence could lead to deviations from the environmental policy and the objectives and targets;

(b) stipulating operating criteria in the procedures;

(c) establishing and maintaning procedures related to the identifiable significant environmental aspects of goods and services used by the organization and communicating relevant procedures and requirements to suppliers and contractors.

My question is :

Put aside the "significance criteria" that we have set for identify the significant aspects. What should we do on the significant aspects? Don't we required to control all the significant aspects whether by existing control practices or establish a new procedure?
:bonk:

As i thought that we have taking into consider the "business needs" or "company priorities" in the process we identify the "significant aspects". In this case, the "significant aspect" will stand for two meanings for me:

(a) an aspect which has or can have a significant impact
(b) an aspect which the company can control and over which it can be expected to have an influence

Or, probably i should say that (can i say that?):

"we should control "ALL" the significant aspects within the resources available - although it may not possible to invest some expensive equipment/ machine for control purpose, but atleast we should do something to reduce the "human error" or others which would help in reducing the severity or possibility of occurrence."

Are we in the same thought?

Hopefully i didn't confuse any of you and thanks for any reply.

:rolleyes:

Hi June,

They key here is that you must have controls in place for those significant aspects that are in line with your O's and T's, and your policy. There will (may) be some significant aspects that are not associated with either an objective or your policy. Basically, there are three situations where you have to control a significant aspect (or any aspect for that matter):
1. If you have set an objective and target against it
2. If you have stated in your environmental policy that you will control it
3. If it could result in a legal compliance issue.

As 4.4.6 states, you must have controls / procedures in place where the absense of them could result in a non-compliance with O's and T's or your policy (and obviously legal requirements).

When identifying your significant aspects, this should be as objective as possible, in other words, your financial or business situation should have no bearing on whether or not an aspect is significant. The business factor only comes into play when you look to set your targets. For example, say a company is generating a large amount of hazardous waste, waste that could be minimized through the investment of new equipment. The impact of that waste on the environment is significant, regardless of your financial situation. If you say that you can't afford the equipment, therefore the aspect is not significant, your not looking at the impact objectively. Significance is always determined by facts (severity, frequency of occurance, current controls or detections in place). It's common for companies to say "we can't afford to control it, so we're not going to make it significant". This is what I did my first time through this process in 1997.

If you can put controls / procedures in place for all of your significant aspects, then you are way ahead of the game. Just remember that when evaluating significance, you should not consider business goals or situations, only the impact on the environment.

Again, long winded, but I hope I answered the question.

O.k it finally all makes sense, we are required to IDENTIFY all our significant impacts, and control THOSE which would affect any of the 3 points mentioned in the last post.

Any other significant impacts we are NOT required to control (especially if not practical) if we do not want to, although inorder to satisfy the registar (i.e Randy), and continually improve our environmental peformance we must control SOME of them, as resources allow.

The significant impacts that we have assigned NO control whatsoever, will eventually be dealt with as the ones above drop of the radar screen, and resorces become available. For the purposes of the Registar, it WOULD be sufficent to say that these will evntually be dealt with, although no detailed action plans are required at this stage.

Have I hit the Nail on the Head???????????????????

I think I have, but will need your final comment to confirm. If so, I am very happy I have finally seen through the trees, many, many thanks :D :D :D

The nail has been firmly struck, Luke.

It's funny (now) how I learned so much about this part of the EMS. We had a system in place a few years ago, and as I said, lack of resources allowed it to fall to pieces. But, we decided to go ahead and schedule our surveillance audit anyway, thinking we could talk our way around certain weaknesses. We knew that our Aspects and Impacts / Objectives and Targets portion was really weak, but what the heck, let's go for it.

Turns out, our auditor sat on the Technical Council that developed the ISO-14001 standard! Needless to say, he knew his stuff and there was no way we could ever talk around our weaknesses. We ended up with 22 non-conformances - 11 of them majors!!!! He didn't even make it out of the boardroom and into the plant.

In the end, he recognized that our bosses didn't support the system (which was confirmed through a conversation he had with them), so he spent the last 1 1/2 days of the audit teaching me how the system is to work, how the elements flow into one another, and how the majority of the focus (if anything) should be on the planning portion of the system. As bad as the audit was, it was a great learning experience for me and has allowed me to fully implement a system at my current place of employment in a little over 4 months (600 employees). Continual improvement for me is learning from my mistakes and ensuring they don't happen again, and hopefull sharing this with you so you don't end up down the same road as I was. Best of luck.

Yes. I agree.

After reading back the "Chicken Bone Thread" (sorry for miss up some of the important posts), the Clauses 4.3.1, 4.4.6 and A.3.1, yes, i think i've misunderstanding the definition of "significant aspects". As i was consider the "company needs" during determining the significance, so the list of "significant aspects" identified would be those aspects that our company can or wish to control. In this case, all the significant aspects identified will have to be controlled in certain degree as i have consider the "company ability" in significance criteria.

But, if the "significant aspect" is stand for those aspects would generate significant impacts. Then, yes, i agree that not all of the significant aspects should be controlled. Only those significant aspect in line with the policy and O&T are required to have "operational control".

:bigwave:
Hopefully i was on the rigt track..... Randy, dun be angry, i still your supporter!!!

I have appointed an external consultant to conduct an in-house internal auditor course on next week. I just received the training notes and i found that the lecturer would have same opinions with us. Let me check it out.

And, many many thanks to Dean P and Randy!!!

:)

I dont really see what the fuss is about IMPACTS v. ASPECTS.

I am under the understanding that it is ONLY the Significant impacts that require control, as discussed throughout the post.

A significant Aspect is defined as an aspect which has one or more significant impacts (well, so I think anyway). Since it is the impacts that result in a change in the environment, then only they require controlling. Which indirectly results in the control of the related Significant Aspect.

Unless I am a bit of the track, once impacts have been identified, the Aspect bit, has fullfilled its purpose and falls by the wayside. err right?????????????????????????????????? :smokin: :ko: :smokin:

Hi Luke,

My thought about IMPACT and ASPECT is different from you which in reverse order.

An "aspect" is more like the source where the impact from. For example, engine operation is the aspect, and the potential impacts generated from the aspect would be air pollution, noise pollution etc. So, once we control the "aspect" which is the source of the impacts, then we could reduce or control the "impacts" indirectly.

It's just like "prevent better than cure".

It would be pointless to control the impacts on air or water or noise by trying to put some chemicals to neutralise the air or water components or build noise absorbent to reduce the noise impacts to surrounding, in fact you could actually reduce all these impacts by controling the source - "aspects".

Any opinion?

:bigwave:

Just to share with you, Luke.

There is no clear distinction between "aspect" and "impact", as sometime an "aspect" could also happened as an "impact" too.

This is the feedback i get from a consultant and the companies implemented EMS when i attended the "Identifying Environmental Aspects" course. And they also told me that they were always face the same problem when trying to diffrentiate the "aspect" and "impact".

In order to avoid confusion, i try to limit the scope of impacts to those "change in environment":
- air pollution
- water pollution
- noise pollution
- Ozone depletion
- Global warming
- Land contamination
- Health & safety hazard
- depletion of natural resources
- biological impact etc.

And for the "aspect", i try to make it be more "large" enough to enable me to have a control and small enough to carry out the significance evaluation.

This is only my opinion. Be hearing from others.

:)

I think this section of ISO-14001 is one that is going to be debated until they revise the standard!

I see aspects as the cause, and the impact as the effect. A single aspect can have more than one impact on the environment (eg. a spill of hydrochloric acid can cause land contamination, air pollution, water pollution, etc.). You need to evaluate the individual impacts to determine which ones are significant, then back track and the cause of that significant impact becomes the significant aspect. This is what you want to control, the cause of your impact. Using the HCl spill, if we have a containment unit around the acid tank, then land contamination and water pollution would not be a significant impact, however the air pollution and liquid waste would be significant. Therefore, we would classify a potential HCl spill as significant for air pollution and liquid waste, but not for land or water pollution. And in order to control the air pollution and liquid waste, we will focus on the cause / source, which is to do everything we can to prevent or limit a spill.

Hi Dean,

Just curious to know that are you using the mentioned methodology to identify the significant aspects for your current company?

Because i did try the same things before. To identify all the impacts generated by an aspect, evaluate all the impacts and then score the aspect. However, i found that this is a time-consuming process and i also face some difficuties to identify all the potential impacts as we are not actually the environmental experts. (but, i actually wish to do that way if time and resources available) After that, i decide to use another simple method to evaluate and identify the significant aspects.

Refer to the your example, what is the conclusion for the "HCl spill"? Is "HCl spill" significant or insignificant?

As for my method, my way is (not excatly same):

Aspect: XXX

Impacts:
AAA - score 9 /10 - significant
BBB - score 5/ 10 - not significant
CCC - score 1/ 10 - not significant

Conclusion: Aspect is significant as one of the impacts is significant.

Record: I'll list down all the potential impacts caused by the XXX aspect so that i'll consider all of them when establishing the relevant operational controls.

Hi June,

This is exactly how we determined the significant aspects here. Identifying your aspects and evaluating them for significance is by far the most time consuming part of the process. For us (a plant of 600 employees), it took a team of 12 individuals two months to complete the process, with each of them working at it for an average of 10 hours per week (and me working 45 hours per week).

In our example, we evaluated the HCL spill four times, each independant from the other. Our ranking system for significance is a multiplication of: Severity of the impact (1 - 10), Probability of occurance (1 - 10), and Current Controls in place (1 - 10). Our results were as follows:
HCL spill - air pollution - 81
HCl spill - land contamination - 8
HCL spill - liquid waste - 12

Based on our system, an HCl spill creating air pollution is a significant aspect, while the other are not , due to the fact that we have a concrete containment unit around the bulk tank. Since any spill would be contained, it would eliminate our spills to the land and our liquid waste, however it would create air emissions (the tank is outside), so this becomes a significant aspect.

Our control measures (if we choose this one) would then focus on minimizing the effects of air pollution as a result of the HCl spill, probably building an enclosure or adding some sort of ventilation unit.

Like I said, this is the most time consuming part of the entire process, and you have to look at everything in great detail to ensure you have captured all actual ('DOES IT CAUSE air pol, land pol, water pol, waste?) and potential effects ('COULD IT CAUSE air pol, land pol, water pol, waste?). And don't worry, no matter how hard you try, the auditor will always find something that you missed, every single time!!! And it's usually something that's been staring you in the face!

Wow~ it's great!!! I believe that this should be a perfect method for identifying the significant aspects and i wish to have one too.

I do not sure whether will "it" also work for me as my company is a construction company where the significance of an aspect may vary significantly from one project to another project. Therefore, i treat each individual project as a small "organization" and they have to identify their own significant aspects associated to their project activities.

In my case, i could only generate a "generic" list of significant aspects which could be the reference for project use but they still have to come out with their own significant aspect list.

So, to use your method may not so practical to my company. ??? :rolleyes:

We developed a database (Microsoft ACCESS) to manage all of our aspects. Once we assign the individual rankings, it automatically flags it as signifianct if the result is above our 'significance cut-off' level (which we determined ourselves). You could easily use a version of this for your situation. Even though each work site would have different circumstances, I'm sure you would have the same general aspects / impacts at each site (waste generation, certain air emissions, noise, etc.). You would then only need to go through and re-assign the rankings on the common aspects, and do a thorough review to ensure you have captured any new ones.

Also, this isn't the only way to do it, and you may have a system that is just as easy to use and allows you to ID everything and evaluate for significance. It just made sense for our facility.

To Dean & Jun...

YES!!!!!:bigwave:

Hi Dean P.,

We developed a database (Microsoft ACCESS) to manage all of our aspects. Once we assign the individual rankings, it automatically flags it as signifianct if the result is above our 'significance cut-off' level (which we determined ourselves). You could easily use a version of this for your situation.

I've discussed with my working committee to manage the aspects & impacts register in Microsoft Access database. Do you mind to share with me on what are the Tables & the contents of each individual table that you have created for your company use?

Many many thanks.:bigwave:

Hi June,

I'm not as knowledgable in the MS-ACCESS database as I should be, but I can tell you what our different fields are called and give you an idea on how our database is organized.

First, once we have ID'd all of our aspects, we populate the following fields:
ASPECT: (what the aspect is)
ASPECT CATEGORY: (aspects can usually be grouped together)
ASPECT ID#: (is assigned automatically)
IMPACT: (the result of the aspect)
PROCESS: (location of the aspect / impact)
OPERATING SCENARIO: (is this aspect under normal operating conditions, emergency, start-up/shut-down, or maintenance?)
EVALUATOR: (who is entering and evaluating this into the db)
DATE: (date that it is entered)

Once these have been populated, then we evaluate each individual aspect for the following:

1. Legislative Requirements - if there is a legal requirement attached to the aspect, then we click 'YES', and this automatically flags this as a Compliance Aspect (purple bar across the top of the page). This allows us to track the aspects that have a legislative requirement and ensure we maintain compliance.

2. Risk Evaluation - we rank each aspect for three criteria: Severity of the Impact (1 - 10), Frequency of Occurance (1 - 10), and Current Controls in place to Minimize the Impact (1 - 10). The database then multiplies these three numbers to give us a Risk Rating. We selected 125 as our trigger, so if an aspect rates over 125, it is flagged as a significant aspect (red bar across the top of the page). (Note, in our case we also chose any Severity factor greater than 7 to be automatically significant, just to bring them to our attention).

This is the basics of our database. We also have some features that allows us to link our Objectives and Targets, EMP's, and specific work instructions / procedures to the individual aspects. This is our way of showing the auditor the link between all of these. We can also run reports to sort our compliance aspects and / or our significant aspects from the others, and also sort each of these by process, category, or risk rating (basically using different sorting funtions and queries).

Again, I apologise for not having specifics of the database, but if someone on your team knows and understands ACCESS, then they should be able to develop something similar to this to meet your needs. I really hope this helps you, June, and please let me know if you have any questions.

Good luck,
Dean

Thank you very much, Dean. P.

I'm still trying on that. :)