Well, I'm just thinking of questions right now - so my post is a bit pre-mature I guess. I'm pulling together the 9K2K upgrade project but with one client I have to integrate 14001. This is a Ford Q1 requirement (this QOS thing is almost silly). The company is only about 35 souls all told.
I figure I'll put the Q manual together by adding any extra clauses as I did in http://Elsmar.com/pdf_files/ - Look for QS-Req.pdf (a matrix which became the Q manual index in a project quite a while ago). That was a QS-ISO-VDA6 matrix but the principle should be the same. I'm looking at ISO 9001:2000 Annex A Table A.1 right now.
I still have a few questions of them. I know they lease all their equipment (tractors and trailers) and the only thing I know of that they do is minor repairs - such as burned out light bulbs and minor wiring problems on trailers. I don't believe they do any oil changes or such - I think that's part of the lease agreement as are tires and all the other 'major' things one might consider in a turcking company. If they do oil changes - that will be an EPA issue.They don't package anything. I think they have a fork lift they service - so that'll be an issue with oil disposal. Possibly tires. But I know they rarely use the lift because almost all of their business is taking a trailer to a company, getting loaded and going to another company to unload. That said, the fork lift issue should be small. I have to meet with the 'garage manager' next week as he does all the EPA stuff - so I'll get a lot clarified then.
Office is small. Paper intensive so I guess recycling could be an issue.
I guess the first step is an inventory which I'll keep as a record of assessment of what may or may not be 'applicable'. I'll go office to garage.
I remember that list as 1 I provided as example of ASPECTS. Remember that an ENVIRONMENTAL ASPECT is any element of an organization's activities, products, or services that can interact with the environment (like the exhaust from the trucks). All you need to do is develop a procedure for identifying ASPECTS and then follow it. There is no right or wrong way here.
Here is some info.......(not all are required to be documented...but.....)
ISO 14001 required procedures are:
Identification of environmental aspects and significant impacts (4.3.1).
Identification of, and access to, other requirements (4.3.2).
Identification of training needs (4.4.2).
Document control (4.4.5).
Creation and modification of documents (4.4.5).
Communication of procedures and requirements to suppliers and contractors (4.4.6 c).
Identification of potential emergencies and accidents, and the response to them (4.4.7).
Monitoring and measuring of key characteristics of operations and activities (4.5.1).
Calibrating equipment (4.5.1).
Evaluating compliance with relevant environmental legislation and regulations (4.5.1).
Preventing non-conformances or taking corrective action should any occur (4.5.2).
Identifying, maintaining and disposing of environmental records (4.5.3).
Performing EMS audits (4.5.4).
In addition to procedures, there are requirements to establish and maintain records and directive documents, such as a company's environmental policy, operational control plans and operating criteria.
Luke, not to steal Marc's thunder, but there are really only two basic questions that must be asked.
1. Is oil usage (either through maintenance, or loss) an aspect? Most of us agree that it probably is. I often describe aspects as those things you store, move, use, spill or dispose of. Oil fits all categories.
2. Is oil usage a “significant” aspect? This question can only be answered by you. Take into consideration things such as disposal methods/costs, usage rates, leaks and losses, storage and movement. Depending on the size of your organization, it could very well be significant.
As a side note, commercial carriers tend to have a rather extensive paper system. Paper disposal/recycling might also be significant.
Yeah - motor oil is an aspect. But - it's not a controllable aspect. You can't reduce the use without affecting preventive maintenance. There is the aspect of drippings from tractors, but most tractors today are built pretty solidly and, like newer Harley-Davidson motor bikes, don't significantly drip fluids. We did inspect the lot for drippings and found very, very few and all were < 3" dia. with most about 1". Not many total, but honestly I didn't count them but they were 'rare'.
For bigger companies, I think 40 CFR 279 Used oil generator (Container Storage and labeling, Waste evaluation, Shipping) applies.
Oil is controllable to some extent. There are now small relatively inexpensive recycling units that organizations can place in facilities. Antifreeze can also be recycled onsite. There are machines that crush filters to remove the fluids also.
If I were consulting to a company that performs a lot of maintenance I would recommend exploring onsite recycling to help reduce usage and disposal. The initial investment would be recaptured in time.
Marc, I believe that Randy and I (if I might place words in his mouth) were refering to handling waste oil from servicing the trucks. We might not be able to control the amount of waste generated without endangering our fleet. We can however make intelligent choices on what to do with the waste generated.
As far as leaks. The control would be to ensure leakage was rare and small. If an oil cooler is blowing oil, then the impact would of course change dramatically. I think tires would be rather significant. In many places storm water runoff might even be regulated. Check with the state to find out. Michigan has some pretty exact regulations on how storm water runoff is to be handled. I’m can’t say about other states.