Discussion: Significant Aspects (Clause 4.3.1), Operational Controls (Clause 4.4.6)

[kalehner]

Objectives and Targets

I am interested in opinions from contributors with the following 3 questions:

1. Do all significant aspect (4.3.1) need associated operational controls (4.4.6).

2. If an organization has identified an aspect as significant such as electricity use, and intends to improve their performance for that significant aspect, can the objective for that aspect be to perform a study to identify a feasible objective and target?

3. Does ISO 14001 require that all significant aspects for which an organization intends to improve its performance have documented objectives and targets for each or does the standard allow the organization to commit to a process that will lead to the setting of well conceived objectives and targets based on the implementation of that process.

Discussion:

I am an EMS-LA regularly performing ISO 14001 registration assessment for RAB accredited registrars and providing ISO 14001 consulting and training services (see www.envcompsys.com for more info). In a recent Readiness review/ Stage 1 assessment for one of my clients I was surprised that an auditor I believe to be highly competent made the following finding: “4.4.6 Operational Control – The facility has not identified operational controls for all identified significant aspects.”

While coaching my client with aspect identification and significance determination I instructed that they had to recognize a need to act on any aspect that was found to be significant. This action could either an associated operational control (like a work instruction or training) or a recognition that some action needed to be taken to improve the performance for that aspect (Environmental Management Program) or in some cases both an operational control and an EMP would be appropriate.

I do not believe that each significant aspect needs to have an operational control. Electricity is a good example. In the early stages of implementation of an EMS the organization may not know enough about its electricity use to define an operational control. After further study an operational control may become apparent but to I do not believe a registrar should compel an organization to associate operational controls with all significant aspects.

With regard to the objective and targets questions, I believe an organization should only establish objective and targets based on knowledge of what is feasible not guesswork or just pulling objective and targets out of thin air to satisfy an auditor or registrar. That is why I advocate for the identification of all significant aspect that have potential for improvement early in the implementation process but resisting the temptation to guess at objectives and targets. Rather I advise that the organization select a few of these kinds of significant aspects and follow a six sigma type define, measure analyze, improve, control (DMAIC) type process to systematically pursue improvement for the significant aspect. As progress is made on these significant aspects and additional resources become available, top management can choose to “activate” other improvement type significant aspects. This approach avoids the problems of prematurely establishing unreasonable objective and targets and requiring an organization to do everything at once.
I like to think of improvement type aspects as you would a potential six sigma project. The organization has identified the improvement opportunity and may choose to put the project in the “six sigma hopper”. When resources become available the organization can pick a project from the hopper and run it through the DMAIC process. As long as the organization can produce objective evidence that it is actually perusing some improvements projects and intends to or actually “activates” new improvement projects I believe that the requirements of ISO 14001 and the required policy commitment have been met. Unfortunately it seems that most of the auditor and registrar community is stuck on the notion that at the get-go all improvement type aspects need to have document, objectives and targets and I don’t believe that is required by the standard.

Your thoughts appreciated. K.

 

[Randy]

Pretty good subject Kevin, let's see what we can dig up...here's what I think:

1) No.....only those SA's that without an appropriate control can cause you to go out of conformance with your policy (compliance, pollution, improvement) or that can effect the achievement of O&T's have to meet 4.4.6.

2) No....look at 4.3.4 & 4.5.1....4.3.4 an EMP has to be in place for each O&T that gives a specific means (how it will be achieved) and time frame to perform it, and 4.5.1 says "The recording of information to track performance.....and conformance with the organization's objectives and targets" You gotta have something to show that you are on track.

3) No....S/A's only have to be considered when establishing O&T's. Organizations can set O&T's based upon what they reasonably believe they can do taking into consideration those things stipulated in 4.3.3

As for the electricity thing....unless the organization can show real improvement in environmental performance I don't care how much money they save, I won't buy off on it. Saving money don't save no environment. (Nice English isn't it?)

 

[db]

As for the electricity thing....unless the organization can show real improvement in environmental performance I don't care how much money they save, I won't buy off on it. Saving money don't save no environment.

While saving money does not save the environment, saving electricity does. The less electricity we use, the less natural resources are used to produce electricity. The problem is there is no clear, defined correlation between saving electricity and pollution prevention (at the organizational level). But the same can be said of most EPs. It would be hard to show "real improvement in environmental performance" with many EPs.

And to be blunt (but not trying to pick a fight), if you were my auditor, I wouldn't care less if you "buy off on it". If I call electricity usage significant, and/or if I have an EP for electricity, it is my EMS, and that EP is just as valid as any other.

 

[Randy]

You're wrong there db. Kilowatt hours can be directly related to barrels of oil, tons of coal or cubic feet of gas, they can also be directly related to tons of ash & cubic feet or tons of emissions. Those things relate to real environmental performance indicators.

I am not going to buy off on money savings alone with regard to O&T's. During the courses I instruct whether they are Lead Auditor, Implementation or Internal Auditor courses I tell eveyone that money is not an "Environmental Performance Indicator".

 

[db]

You're wrong there db. Kilowatt hours can be directly related to barrels of oil, tons of coal or cubic feet of gas, they can also be directly related to tons of ash & cubic feet or tons of emissions. Those things relate to real environmental performance indicators.

That is the point I was trying to make Randy.

I am not going to buy off on money savings alone with regard to O&T's. During the courses I instruct whether they are Lead Auditor, Implementation or Internal Auditor courses I tell eveyone that money is not an "Environmental Performance Indicator".

I would fully agree with the "money savings alone" thing. I do stress the positive financial benefits of a good EMS, but $$$$$ should never be the focus.

 

[Craig H.]

You're wrong there db. Kilowatt hours can be directly related to barrels of oil, tons of coal or cubic feet of gas, they can also be directly related to tons of ash & cubic feet or tons of emissions. Those things relate to real environmental performance indicators.

I am not going to buy off on money savings alone with regard to O&T's. During the courses I instruct whether they are Lead Auditor, Implementation or Internal Auditor courses I tell eveyone that money is not an "Environmental Performance Indicator".

OK, Randy, but a question:

Would you accept a reduction in KWH used as a measure of increased efficiency/decreased pollution? Would it have to be related back to tons/units produced?

Just curious.

Craig

 

[db]

OK, Randy, but a question:

Would you accept a reduction in KWH used as a measure of increased efficiency/decreased pollution? Would it have to be related back to tons/units produced?

Just curious.

Craig

I know you asked Randy, but I was eavesdropping, and thought I would but in. Pardon my intrusion. I would say yes to your first question, and would say you would have to for your second question. If you did not relate it back to production somehow, you could not be sure any progress, or lack of it, was the result of the program. If your output doubles, but your electricity only goes up by 10%, then you might have something to say, but what if your output goes down and your electrical usage stays the same. What does that tell you? For those reasons, I always recommend to tie all measurable aspects to production.

My two cents (even though you didn't ask for it )

 

[Craig H.]

I know you asked Randy, but I was eavesdropping, and thought I would but in. Pardon my intrusion. I would say yes to your first question, and would say you would have to for your second question. If you did not relate it back to production somehow, you could not be sure any progress, or lack of it, was the result of the program. If your output doubles, but your electricity only goes up by 10%, then you might have something to say, but what if your output goes down and your electrical usage stays the same. What does that tell you? For those reasons, I always recommend to tie all measurable aspects to production.

My two cents (even though you didn't ask for it )

Thanks, Dave. Even though I am not involved with EMS, I am still interested in it, and wondered if that approach made any sense to those more experienced. I am glad to see that it does.

It would seem to me that this approach would be a simple way to guage effectiveness for some companies, and the numbers should already be available, so it would just be a matter of "plug and chug".

Thanks again!

Craig

 

[Randy]

OK, Randy, but a question:

Would you accept a reduction in KWH used as a measure of increased efficiency/decreased pollution? Would it have to be related back to tons/units produced?

Just curious.

Craig

Kind of in line with db's line of thinking. Clause 4.3.4 specifies that "EMP's" need to be flexable to account for change (EMP's are required for each O&T...they may be combined if applicable)

The purpose of an EMS is to systematically manage environmental performance with O&T's being a primary mechanism by which to manage improvement. Improvement (environmental performance type) should focus on real environmental "stuff"....I have yet to be shown where $'s (by themselves) saved or spent have any influence on the environment. There needs to be a relationship between $'s and actual things that impact (influence) the environment.

I misunderstood you earlier there db