Legal and Other Requirements Relating to Objectives and Targets

[Andy Cheung]

Legal and other Requirements

For the ISO14001:1996 clause 4.2.3, I am not sure whether or not our organization has met these requirements. We have the procedures to identify that :

a) quarterly we go to environmental protection bureau to collect / update the environmental regulations and ongoing changes.

b) all EMS regulations are reviewed and combined to a list with revise date which is communicated to all employees thought computer on-line system.

c) the most important regulations are also summarized and classified by departments in the list so that the relevant department could find the requirements easily.

d) those obsolete regulations are removed from the system.

Are these good enough ? Because of resource constraint, I notice that we cannot verify all the EMS regulations (more than 100 and each has so many requirements) that are applied to our organization activities. Can anyone of you advise some feasible method to verify this key point ?

 

[jashaver]

You seem to be doing what is needed to conform to the part of 4.3.3 that requires procedures to identify relevant legal reqts. What about "other requirements" (like industry codes)? No mention of these or how you track them.
While you don't mention it, regulatory reqts are also an improtant part of 4.2 (policy), 4.3.3 (obj & targets) & 4.5.1 (monitoring & measurement). Nonconformance in these areas is often more serious.

 

[Jon Shaver]

To verify applicability of legal reqts - there are lots of companies who will do that for you, often on a retainer that is much less costly than doing it yourself.

[This message has been edited by Jon Shaver (edited 04 September 2000).]

 

[mcj]

"Legal and Other Requirements"...Other Requirements

For some reason or other, we seem to be having a dilemma with regards to handling “Other Requirements.” Does anyone have any suggestions? Should we generate a list (as a controlled document) that spells out all “other” requirements that we follow as a company that are not adhered to because of regulatory necessity?
Would it suffice to include in such a list issues such as: contract conditions, land use restrictions (I think most of these are legally required), and customer requirements…
Does having a white paper recycling bin in every office and our practice of recycling toner cartridges constitute “other requirements”?
Does anyone maintain a list like this that they update and review regularly? Does anyone use any of his or her quality program requirements to satisfy this issue?

Didn’t mean to fling out a bunch of questions…but any response would be greatly appreciated.

Kind Regards,

 

[goose]

A couple of other requiremnts come to mind:

1.Corporate environmental requirements (not necessarily regulated by law)

2.Due to proximity of plant to residental areas, certain concessions may be made to neighbors reference environment.

 

[tomvehoski]

You may want to check with your state, or other regional government. In Michigan, the state DEQ publishes a complete handbook which covers all environmental requirements for both the state and federal governments.

Tom

 

[mcj]

Thanks to Tom and goose for your help!

mcj

 

[mcj]

I've managed to run into a bit of a standstill regarding this requirement.
"Ensure that legal and other requirements are considered in setting environmental objectives and targets"
I interpret this in two ways. First, in every case where our organization does not comply with legal and regulatory requirements there should be a related objective and target. Second, where regulations are not followed with a corresponding objective, that we must be able to verify that there are programs, in existence, designed to maintain compliance.

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!!

mcj

 

[rrramirez]

See 4.5.1 Last Paragraph, may be help a bit.

 

[Randy]

The establishment of Objectives and Targets have to do with managing your Significant Aspects and not with failing to use a checklist correctly.

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).]

[This message has been edited by Randy (edited 10 August 2001).]