posted 16 July 2001 02:48 PM              

The questions raised to me focus around the following situations: When (for example) on the occasion that an operator fails to initial a checklist, which would put us out of compliance, that we should at that point establish a “New” objective and target to address this. If, during an environmental audit, we discover that we are in violation of a particular regulation, should we generate an objective and target to address the violation?

When does the Objective and Target process give way to the Corrective and Preventive action process?

Many Thanks!!

posted 09 August 2001 11:26 PM               

The O&T relationship to regulations directly relate to their not being in conflict with the law. O&T, when established have to fall within mandated limits (you may be more stringent in your Targets than the law allows but not less), i.e., if you are required by law to reduce your VOC emissions by 200lbs a year, you may set a Target for a 300lb reduction, but not 150lbs.

I hope this helps.

[This message has been edited by Randy (edited 09 August 2001).]

posted 16 August 2001 03:08 PM              

Let me put this in the following scenario…
We test our back-up generator weekly. This test must be conducted on days, classified by the DEP as, “low-ozone” days. Failure to test on “low-ozone” days can, potentially, be grounds to place our site into a different classification with the DEP and change our air-regulation status.
If the EE in charge of conducting that test fails to contact the DEP to determine that the test day was OK and tests the generator on a “high-ozone” day…does this issue need an objective and target assigned to it or is this an area handled by corrective/preventive actions.
In other words, if we are in compliance with our regulation…have verifiable programs in place to maintain compliance (but this particular regulatory requirement does not have an associated O&T with it) and, because of EE negligence, fall out of legal compliance…what do we do? Do we, at that time, establish an objective and target to address the issue…or should this become a corrective/preventive action.

Another angle to consider would be (for example) violations found during an outside air audit. Let’s say we failed to include an emissions source. Once we receive a written report from the auditor, historically we fix the violation accordingly. If this failure to report said emissions source places us in violation of our legal requirement…should this be a new O&T instead of a corrective action?

many thanks,

posted 16 August 2001 03:42 PM               

I agree that you can have any type of O&T you want, but your Target should be something you can see and not just get a warm fuzzy over. Remember, "If you can't measure it, you can't manage it"

If you want to establish an O&T for every regulatory requirement you have, knock yourself out. The standard only requires that regulatory and other requirements be taken into consideration, not that they be acted upon when determining SA's.

As an auditor, I cannot tell you that you identified your SA's using an incorrect procedure, and consequently established inappropriate O&T's. I cannot tell you that your targets are not adequate and your Objectives are flawed. All I can do as an auditor is to ask some questions:
Is there a procedure to identify SA's? Yes No
Have SA's been identified? Yes No
Have O&T's been established for those SA's? Yes No
Have procedures been implemented to control O&T's? Yes No
Are O&T's consistant with the environmental policy? Yes No

Both cases you give are better suited to be addressed for C/P Action and not as O&T issues. IMMHO

posted 17 August 2001 09:54 AM              

I agree entirely with what you’ve said. The members in our Implementation team were split on this with some believing that every violation, of the nature previously explained, warranted establishing an O&T to address it…others felt that it was a C/P Action process issue.

Thanks again for your insight and clarification.