Policy & Aspects, Objectives, Targets - Listing your aspects right in the policy

[isogirl - 2004]

Policy & Aspects, Objectives, Targets

I have a question for you folks with EMS experience. I recently attended an EMS Auditor's course. The instructor emphasized several times that the environmental policy should be ever-changing. This could be accomplished by actually listing your aspects right in the policy. As aspects change, your policy changes. This will ensure that your policy is in alignment with your aspects, objectives, and targets.

We did not write our policy this way. Ours is more of a general, all-encompassing statement which includes commitment to pollution prevention, continual improvement, etc. In this manner, I think it will remain in alignment with As, Os, & Ts.

We've already had our desk audit & on-site review. Final registration audit is in 2 weeks. The auditor seemed pleased with our policy. Does an ever-changing policy sound right to you?

 

[db]

I have a question for you folks with EMS experience. I recently attended an EMS Auditor's course. The instructor emphasized several times that the environmental policy should be ever-changing. This could be accomplished by actually listing your aspects right in the policy. As aspects change, your policy changes. This will ensure that your policy is in alignment with your aspects, objectives, and targets.

We did not write our policy this way. Ours is more of a general, all-encompassing statement which includes commitment to pollution prevention, continual improvement, etc. In this manner, I think it will remain in alignment with As, Os, & Ts.

We've already had our desk audit & on-site review. Final registration audit is in 2 weeks. The auditor seemed pleased with our policy. Does an ever-changing policy sound right to you?

The Environmental Policy should be dynamic to the extent that it changes, as your circumstances change. What I recommend is to look at the policy during Management Review (which is required by 4.6), and go from there.

I think that placing your aspects, objectives and targets in your policy would make it far more complicated than it needs to be and could create confusion and detract from what the policy is really trying to say.

BTW, I was up in Marlette, last month. Not quite Yale, but still in the Thumb! (I grew up in Almont)

 

[Claes Gefvenberg]

The auditor seemed pleased with our policy. Does an ever-changing policy sound right to you?

Not really... That is, unless circumstances are ever-changing. I'm in total agreement with db here (as usual, I might add). The policy should be scrutinized and changed as necessary, not for the sheer sake of change.

/Claes

 

[Randy]

Ever changing? Hmmmmmmmmmmm! List aspects in policy? Hmmmm Hmmmmmmmm!!

Never quite heard it put that way before, so I know I didn't train you.

What are you going the everly change? How many different ways can you say the you are committed to comply with applicable laws, prevent pollution and continually improve?

As for listing your aspects...are we talking all 432 of them (or whatever you have)?

I'm not going to dispute (at least not too much) one of my apparent peers, but don't bust you buns taking that advice.

Your policy should be subject to review and revision as all other system documents are to make sure that is stays "appropriate" (you determine "appropriate".

Your time would be better spent ensuring that your employees understand how they have an effect on the fulfilling of the policy and how the policy effects them in their work.

 

[RoxaneB]

What *they* said!

In agreement with what the group has said so far. If you have a policy that works for and is in alignment with the rest of your system and meets the requirements, I don't see a problem. Why make it complicated? Why make it so complex that no one understands it?

And the yearly review of it sounds like a plan to me. That's what we do here.

 

[isogirl - 2004]

Thanks to everyone for your replies. I thought I was on the right track until I the instructor (nope, Randy, it wasn't you) came out with his comments, then I became unsure. Seemed to me to be a bit of extra work putting aspects on my aspect ID list and in the policy. (Even though we have a lot less than 432!)

Seeing that all of you are in agreement with my original thoughts has given me that warm, fuzzy feeling again.

Hey, db, fellow thumb-ite!

 

[Randy Stewart]

While we are on the subject maybe you can help with this issue . . .
We are a very low impact manufacturer, our significant aspects include used lamps and battery disposal. We have controls in place, review them annually, etc. etc. We have become stagnant, if we want to take on the next level or group of aspects we will be dealing with grinding dust, hi-lo emission etc.
What do you do to keep the interest going? If it wasn't for our parent company requiring the cert we would drop it altogether.

 

[CINDY]

Randy,

Grinding Dust is out of your control other than proper disposal and WI for non-routine tasks (provided you have a collection system), and what do you expect from hi-lo emissions? You can not change the output of emissions without purchasing new equipment. You already have permitted drivers, training requirements, cylinder storage requirements, maintenance etc.

Turn it into friendly competition or useful targets.

Question: Your attached sheet has a lot of aspects on it. What did your Auditor say about having so many? Our's told us we had too many. We listed 23 and only had 8 that we monitored because they were in our direct control.

Cindy

 

[Randy Stewart]

Nothing negative. The first auditor we had out wanted us to dig deeper, he thought we were overlooking a BIG one. It wasn't the case.
The person that did the Compliance Audit was impressed with the detail and he only noted very minor issues. The SARA III issue we don't meet the storage capacity requirements.
What you see is one of 3 facilities and it represents our biggest possible impact. Here are the observation and issues from the Compliance audit.

 

[CINDY]

Randy,

Looks like you came through very well. We just had our Certification Audit last week. We had 3 Majors and 10 Minors. It was a first visit for the "Environmental Expert" he was very large corporate minded and not small business, low environmental impact minded.

He also did not believe we maintained our facility as clean as the days of his visit. I hate paying someone to call us a liar.

We got hit for Spill procedures, Environmental Policy, SWPPP, Waste Management Procedures and training, EMS aspect communications, Subcontractor Procedures, Job Descriptions do not include enough EMS, Regulatory Compliance Procedures.

The regulatory compliance procedures he want us to monitor are just in case there are changes and we apply to them.

Cindy