ISO 14001 - 4.5.1 Monitoring and measurement

[cheahga]

Quote ISO 14001 4.5.1:
"The organization shall establish and maintain a documented procedure for periodically evaluating conformance with relevant environmental legislation and regulations"

May I know what's the intent of this clause and how do you interpret this?

What's the main differences between this clause and 4.3.3 "When establishing and reviewing its objectives, an organization shall consider the legal and other requirements, its significant environmental aspects, its technological options and its financial, operational and business requirements, and the views of interested parties".

The reason I ask this question was that during our last re-assessment audit, our CB auditors throw a question to our EMR "how do you guys assess and evaluate your conformance towards environmental legislation or others requirement?"

Our answer to this was "we monitored all out effluents discharges, gaseous emission according to our local legislation through our monthly meeting!"

The feedback from our CB auditors was we do not have a proper documented procedure towards the claims although hard evidences of meeting minutes was shown.

Does this mean a procedure for tracking such conformances need to be formulated under element 4.5.1 monitoring and measurement?

Any good advice is welcome!!!

 

[Randy]

"The organization shall establish and maintain a documented procedure for periodically evaluating conformance with relevant environmental legislation and regulations"

This just requires that an organization develope and operate a compliance inspection program, the results of which should be reviewed and corrective action taken to address inconsistencies.

 

[D.Scott]

Randy is spot on - and yes, you need to write a procedure stating how you do it.

Dave

 

[JodiB]

Re: 4.5.1 Monitoring and measurement

cheahga said:

Quote ISO 14001 4.5.1:
"The organization shall establish and maintain a documented procedure for periodically evaluating conformance with relevant environmental legislation and regulations"

May I know what's the intent of this clause and how do you interpret this?

What's the main differences between this clause and 4.3.3 "When establishing and reviewing its objectives, an organization shall consider the legal and other requirements, its significant environmental aspects, its technological options and its financial, operational and business requirements, and the views of interested parties".

The main differences:
1) 4.5.1 requires you to document a procedure for evaluating your conformance with legislation and regulations. (keeping minutes of your meetings is the record of having done the evaluation, not the procedure itself that *might* state that you will have monthly meetings where you will evaluate your conformance)

2) 4.3.3 is where you are told the things to consider in setting your objectives (and related targets): what regulations may require you to do, what your company is financially able to do, what the community expects you to do to be a good neighbor, etc.

Your 4.5.1 procedure *may* include the method you use to ensure that you know what regulations / legislation applies to you (otherwise, how can you correctly monitor your performance against them?) With this proper legislative and regulatory information in hand, you will use this information to help form your objectives (4.3.3). Also, the results of the monthly meetings you are having (the records of having met your 4.5.1 procedure?), will loop back to demonstrate your performance against any objectives/targets (as established from 4.3.3).

There is a natural relationship between these clauses but they are two distinct activities.

 

[cheahga]

Hi Randy & Lucinda,

Thanks a lot for your constuctive ideas.

Will definitely take into consideration all the good points you guys have put in.

Thanks guys.

 

[Randy]

Being a girl, Lucinda has the ability to turn the simple into the complex and the mundane into the exciting.

 

[JodiB]

You're right Randy. My answer may sound a bit obtuse. I could have been more clear.

1. Write a procedure that says how you will find out what regulations apply to you . Also make sure that you have a way to find out when a new regulation is passed or an old one changes.

2. In the procedure, also explain how your company will go about reviewing the information about regulations. Also describe that you will gather information on your activities that are affected by the regulations and you will review that information to ensure that you know whether or not you are in compliance.

That is 4.5.1

1. When you set your objectives and targets, keep these regulations in mind. If you need to keep emissions within a limit or discharges, etc. then perhaps you will want to set objectives to deal with the processes or equipment in your facility that impact those.

That is 4.3.3

Better now?

 

[Randy]

Absolutely....Wanna Buffalo Chicken Wing? I know a good place to get some

 

[kalehner]

I think 4.5.1 says that the organization must document a procedure for performing periodic environmental compliance audits of the activities covered by the scope of its EMS. It can be as simple as “ Environmental compliance audits of our facility will be conducted every 2 years by a competent outside environmental professional”.

The standard does not say how these audits will be performed but I believe a competent environmental professional should perform them without direct management oversight by the facility being audited. Internal environmental managers auditing their own efforts are a conflict.

 

[Randy]

This element or clause directly ties in with 4.3.2 "Legal and other requirements". The whatever you want to call it has to at the minimum bounce off of what the law requires. Everything else can be called gravy.