ISO 14001 Environmental Action Plans

[Luke Hannant]

Action Plans

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???

 

[Dean P.]

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.

 

[Randy]

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.

 

[Luke Hannant]

Dean,

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

!!!!!!!

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
!

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 )!!

 

[Randy]

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.

 

[Dean P.]

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.

 

[Randy]

Correctamundo Dean!!

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

 

[Luke Hannant]

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.



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:

 

[Dean P.]

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.

 

[Randy]

Listen to Dean, Luke.

He is giving you good solid stuff.

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