Significant environmental aspects for rubber printer roller production process

[Randy]

You know you're right about the quote...lack of attention to detail on my part...Dr R. contributed part of it

Anyway to continue....The determination of significance doesn't need to have anything to do with the understanding of environmental chemistry, waste streams or the man in the moon.

Significance determination is totally based upon criteria established by the organization which it deems to be important to them and developing a methodology of its choosing that will essentially differentiate those aspects of less environmental importance from those of a greater importance with importance being decided by the organization. The importance or significance does not have to align with any science, legal or any other requirements in but can be soley based on nothing more than organizational cultural values in many ways similar to the process of establishing O&T's.

Signifance determination of aspects in an individual organizational activity that can vary across the entire spectrum...What is significant to one may or may not be significant to another. I'll use an illustration to help explain significance.....

In the Southern part of the US (Arkansas, Alabama, Georgia, etc)...the open display of a shotgun or rifle in a gunrack located in the real window of a pickup truck or the open wearing of a holstered pistol in Arizona is not identified as an activity worthy of note..nobody really cares (it's not significant).....now perform the same activity in NYC, Chicago or London, the event will be one of great significance especially to the one displaying the firearm. Significance like beauty is in the eye of the beholder....So what we may identify as significant may or may not be to our friend and the opposite holds true.

Our friend, as well as anybody else performing the task of signifance determination has to identify himself those factors that of import to them such as controllability, legal requirements, cost potential for harm, views of the public or any other value they choose and then develop a method to weigh one aspect against another.

Now if you can show the specific shall that makes the above incorrect I'll kiss your naked fanny in the middle or Terminal A @ DFW.

 

[Helmut Jilling]

I think the right answer is somewhere between Randy and Paul's answer

I think the right answer is somewhere between Randy and Paul's answer.

Randy, I agree with your explanation up to a degree. It is left to the organization to determine significance. But it cannot be read to imply any old arbitrary assignment would be acceptable (and I don't that was your point). There has to be thought and a logical basis to the conclusion, or I might write it up as not effective.

I agree with Paul to a degree, that some understanding of SO and SO2 would be needed, but a basic user level would be adequate. You don't need the services of a chemist, etc.

The shalls in the standard are basic but pretty clear. The aspects already exist in the organization. They are the activities and materials used. The significance of the impacts have to be determined in a realistic manner, (though it certainly could vary between Arizona and NYC, or LA). Legal requirements will vary from country to country, but they must be determined as well. And the needs of interested parties need to be considered. None of these could be construed as arbitrary.

 

[Randy]

I agree with Paul to a degree, that some understanding of SO and SO2 would be needed, but a basic user level would be adequate. You don't need the services of a chemist, etc.

Thanks for the comments, but I'm gonna disagree about the "science" aspect of your argument.

ISO 14001 was developed in such a fashion that any type of organization, doing any type of activity, any place on the earth could meet its requirements. The abiguity and abstractness of significance determination was for a specific purpose and that purpose was to not require, demand or extort organiztions to do anything other identify through their means those aspects they deam to be of greater importance than any other. The understanding of SO, SO2, NOX, E=MC2 or anything else is actually irrelevant if they don't want to go down that trail. They can have as many crazy things they want and identify their trash and electricity as the most significant if they so choose. To tell someone they need to be a chemical engineer or scientist and apply those mathmatics involved to adequately identify significant aspects is a falsehood and definitely misleading for a novice an the inexperienced..or anyone else for that matter. It is intended to be a simple process for an important reason...so anybody regardless of literacy, education and scientific background could do it.

 

[Helmut Jilling]

Thanks for the comments, but I'm gonna disagree about the "science" aspect of your argument.

ISO 14001 was developed in such a fashion that any type of organization, doing any type of activity, any place on the earth could meet its requirements. The abiguity and abstractness of significance determination was for a specific purpose and that purpose was to not require, demand or extort organiztions to do anything other identify through their means those aspects they deam to be of greater importance than any other. The understanding of SO, SO2, NOX, E=MC2 or anything else is actually irrelevant if they don't want to go down that trail. They can have as many crazy things they want and identify their trash and electricity as the most significant if they so choose. To tell someone they need to be a chemical engineer or scientist and apply those mathmatics involved to adequately identify significant aspects is a falsehood and definitely misleading for a novice an the inexperienced..or anyone else for that matter. It is intended to be a simple process for an important reason...so anybody regardless of literacy, education and scientific background could do it.

Randy, you may be changing my comments. I agreed with everything you explained, except I cautioned the selection cannot be arbitraay. I even included the shalls that were involved.

I most definitely DID NOT say "To tell someone they need to be a chemical engineer or scientist and apply those mathmatics involved to adequately identify significant aspects is a falsehood and definitely misleading..."

I fully agree they do not have to be chemists or experts. But they have to have a reasonable "user's level of knowledge" and would be expected to know Sulfuric acid cannot be poured down a drain. That would not comply with the legal regulations in most parts of the world.

I don't think we are disagreeing in principles. I am not a chemist by any stretch. Every organization I audit has had an adeqaute and effective understanding of the materials they use. If they had any questions, they consulted with their vendors, or other knowledgeable persons.

My only point was it cannot be arbitrary, or inappropriate. That would never pass a witness audit. If you don't agree with that last statement, I would be surprised, but we would then have to choose to disagree.

Sincerely, Hjilling

 

[Paul Simpson]

Round and round in circles .....

The determination of significance doesn't need to have anything to do with the understanding of environmental chemistry, waste streams or the man in the moon.

We disagree.

• In order to understand significance you have to understand impact
• In order to understand impact you have to understand what is in your waste
• In order to understand what is in your waste you have to understand your processes
• In this case in order to understand your processes you have to understand the chemistry

I'll leave the man in the moon to you.

Significance determination is totally based upon criteria established by the organization which it deems to be important to them and developing a methodology of its choosing that will essentially differentiate those aspects of less environmental importance from those of a greater importance with importance being decided by the organization. The importance or significance does not have to align with any science, legal or any other requirements in but can be soley based on nothing more than organizational cultural values in many ways similar to the process of establishing O&T's.

Wrong again. If an organization has a polluting process and wants certification because they are economical with paper clips then I'll send them to you. If they want to implement a management system that assesses its aspects, evaluates the significance of their impacts and puts in place a management system that makes a difference to the environment then I will be happy to carry on talking to them about certification. The base line is compliance with legislation with improvement on top.

If the company doesn't understand its processes then it cannot know if it is complying with legislation

Signifance determination of aspects in an individual organizational activity that can vary across the entire spectrum...What is significant to one may or may not be significant to another. I'll use an illustration to help explain significance.....

In the Southern part of the US (Arkansas, Alabama, Georgia, etc)...the open display of a shotgun or rifle in a gunrack located in the real window of a pickup truck or the open wearing of a holstered pistol in Arizona is not identified as an activity worthy of note..nobody really cares (it's not significant).....now perform the same activity in NYC, Chicago or London, the event will be one of great significance especially to the one displaying the firearm. Significance like beauty is in the eye of the beholder....So what we may identify as significant may or may not be to our friend and the opposite holds true.

Not an area of expertise of mine, I confess, so I can't comment on the legislation in the States behind the analogy. Now in the UK you can't walk around with a pistol because it is illegal - which kind of supports my argument. Legislation makes the wearing of the gun significant - as an individual I may choose to determine this as not significant but I am wrong - and may live to be told so.

Our friend, as well as anybody else performing the task of signifance determination has to identify himself those factors that of import to them such as controllability, legal requirements, cost potential for harm, views of the public or any other value they choose and then develop a method to weigh one aspect against another.

Any auditor worth their salt will also assess the significance evaluation process and determine if it is a genuine attempt to identify environmental impact or so much window dressing. In the case we are discussing (remember that? ) if the company doesn't even know what is going up the chimney the significance evaluation process doesn't amount to much.

Now if you can show the specific shall that makes the above incorrect I'll kiss your naked fanny in the middle or Terminal A @ DFW.

Thank you for this (second) offer. Again I am going to have to decline.

ISO 14001 was developed in such a fashion that any type of organization, doing any type of activity, any place on the earth could meet its requirements. The abiguity and abstractness of significance determination was for a specific purpose and that purpose was to not require, demand or extort organiztions to do anything other identify through their means those aspects they deam to be of greater importance than any other. :

It was precisely because some people and, more importantly, some certification bodies are treating ISO 14001 as a paperwork exercise and not related to environmental significance that the 2004 revision tried to make more clear the link between scope / aspects / legislation and improvement (and drew out the legislative compliance as a stand alone clause)

The understanding of SO, SO2, NOX, E=MC2 or anything else is actually irrelevant if they don't want to go down that trail. They can have as many crazy things they want and identify their trash and electricity as the most significant if they so choose. To tell someone they need to be a chemical engineer or scientist and apply those mathmatics involved to adequately identify significant aspects is a falsehood and definitely misleading for a novice an the inexperienced..or anyone else for that matter. It is intended to be a simple process for an important reason...so anybody regardless of literacy, education and scientific background could do it.

Bull***t. This is dangerous stuff.....

In most countries in the world (I can speak directly for the UK, China, Romania, France, Belgium and the Czech Republic with some knowledge of other countries) there are limits on what organizations can put in the air, water and into the ground as pollutants. These are directly regulated by the nation state or local regulatory bodies. They issue permits to specify maximum permitted levels of NOx, SOx, Fluorocarbons, CODs, BODs, VOCs and any other acronym you care to mention (I would elaborate but my fingers are getting tired). If they catch you breaching those limits they are likely to fine you.

While I agree it is not intended to be elitist. Registration to the standard is meant to be awarded to organizations that understand where they sit in the environment and play their part in maintaining that environment and improving it.

I tried once to explain the reasoning behind significance evaluation on another thread and it was ignored.
http://elsmar.com/Forums/showpost.php?p=124396&postcount=13

I stand by the post and stand for organizations that play their part in pollution prevention and environmental improvement. I oppose organizations that have ISO 14001 certification as window dressing - and anyone who supports that.

 

[Sidney Vianna]

Taking sides

I wholeheartedly agree with Paul. According to Randy's comment, an organization could blatantly disregard scientific data and "align" their significance determination based on cultural issues. So, if it would cost US$10 million to install a scrubber to minimize air pollution, but senior management makes a decision NOT to invest the $10M and self award them the $10M as year end bonus, that means that they could "manipulate" the significance determination criteria any way they want to justify not having to install the scrubber...That is laughable. An ISO 14001 certificate should mean something. As it relates to Environmental Performance. I have already mentioned 3 other times in this Forum that the IAF guide to ISO Guide 66 states that it is a responsibility of the EMS 3rd party audit team to ensure that the criteria established to determine significance must be SOUND. Further, due to external pressure, the Accreditation Bodies are trying to make CB's accountable. Read, for example, ANAB Heads up # 61, which states that outputs matter. For EMS and QMS. It does not address specifically the issue of significance determination, but the underlying message is that the certified systems must deliver on the INTENT of the Standard. Who determines what the intent is? The IAF Guide to ISO Guide 66 would be a pretty good start.

 

[Craig H.]

AM I the only one who thinks we might have a few ships passing each other in the night? Although most, if not all, of what I know about the subject came from this site, I think maybe I can align the various views here. At the risk of appearing totally whacked, here goes. Let's start with this quote from Paul:

In most countries in the world (I can speak directly for the UK, China, Romania, France, Belgium and the Czech Republic with some knowledge of other countries) there are limits on what organizations can put in the air, water and into the ground as pollutants. These are directly regulated by the nation state or local regulatory bodies. They issue permits to specify maximum permitted levels of NOx, SOx, Fluorocarbons, CODs, BODs, VOCs and any other acronym you care to mention (I would elaborate but my fingers are getting tired). If they catch you breaching those limits they are likely to fine you.

I stand by the post and stand for organizations that play their part in pollution prevention and environmental improvement. I oppose organizations that have ISO 14001 certification as window dressing - and anyone who supports that.

OK, now, Randy has stated that the companies are free to determine what is significant. It is a cultural thing. But lets say right now that he is, technically speaking, correct. So who is right?

How many corporate cultures would willingly expose themselves to the slings and arrows (not to mention fines and lawsuits) that accompanies the wrath of the environmental authorities? I know that sometimes business decisions have been made, so maybe a better question would be how many 14001 companies have been caught making environmentally questionable "business decisions"? Is there evidence that there is an effect?

Therefore, I would like to offer the possibility that in practice both positions are correct.

Although I may have just created an aspect that will lead to an impact. That of a hostile posting environment. TAKE COVER!!!

 

[Randy]

I haven't deviated from anything provided below.

I've copied the material from documents paid for by my corporation (DSEQ, Inc) for my private use and under agreement I may use it as long as do not print and sell it or offer it for sale.

Excerpted from ISO 14001:2004, A.3.1

In some locations cultural heritage can be an important element of the surroundings in which an organization operates, and therefore should be taken into account in the understanding of its environmental impacts.
Since an organization might have many environmental aspects and associated impacts, it should establish criteria and a method to determine those that it considers significant. There is no single method for determining significant environmental aspects. However, the method used should provide consistent results and include the establishment and application of evaluation criteria, such as those related to environmental matters, legal issues and the concerns of internal and external interested parties.
When developing information relating to its significant environmental aspects, the organization should consider the need to retain the information for historical purposes as well as how to use it in designing and implementing
its environmental management system.
The process of identification and evaluation of environmental aspects should take into account the location of activities, cost and time to undertake the analysis, and the availability of reliable data. The identification of environmental aspects does not require a detailed life-cycle assessment. Information already developed for regulatory or other purposes may be used in this process.
This process of identifying and evaluating environmental aspects is not intended to change or increase an organization's legal obligations.

From ISO 14004:2004
4.3.1.5 Determining significant environmental aspects
Significance is a relative concept; it cannot be defined in absolute terms. What is significant for one organization may not be significant for another. Evaluating significance involves applying both technical analysis and judgement by the organization. The use of criteria should help an organization to establish which environmental aspects and associated impacts it considers significant. Establishing and applying such criteria should provide consistency and reproducibility in the assessment of significance.
When establishing criteria for significance, an organization should consider the following:
a) environmental criteria (such as scale, severity and duration of the impact, or type, size and frequency of an environmental aspect;
b) applicable legal requirements (such as emission and discharge limits in permits or regulations, etc.);
c) the concerns of internal and external interested parties (such as those related to organizational values, public image, noise, odour or visual degradation).
Significance criteria can be applied either to an organization's environmental aspects or to their associated impacts. Environmental criteria can apply to both environmental aspects and environmental impacts, but in most situations they apply to environmental impacts. When applying criteria, an organization can set levels (or values) of significance associated with each criterion, for example based on a combination of likelihood (probability/frequency) of an occurrence and its consequences (severity/intensity). Some type of scale or ranking can be helpful in assigning significance, for example quantitatively in terms of a numeric value, or qualitatively in terms of levels such as high, medium, low or negligible.
An organization may choose to evaluate the significance of an environmental aspect and associated impacts, and may find it useful to combine results from the criteria. It should decide which environmental aspects are significant, e.g. by using a threshold value.
To facilitate planning, an organization should maintain appropriate information on the environmental aspects identified and those considered significant. The organization should use this information to understand the need for and to determine operational controls. Information on identified impacts should be included as appropriate.
It should be reviewed and updated periodically, and when circumstances change to ensure it is up to date. For these purposes, it can be helpful to maintain them in a list, register, database or other form.
NOTE The determination of significant environmental aspects does not require an environmental impact assessment.

 

[Sidney Vianna]

When you say that

The understanding of SO, SO2, NOX, E=MC2 or anything else is actually irrelevant if they don't want to go down that trail. They can have as many crazy things they want and identify their trash and electricity as the most significant if they so choose. ..so anybody regardless of literacy, education and scientific background could do it.

you are basically inferring that they can disregard toxic waste, pollutants etc... and develop a significance determination criteria that would NOT include obvious HIGH impact aspects of their operation and artificially control less significant ones. For example, a nuclear processing facility could disregard their toxic waste as a significant aspect and consider printer cartridges/toner as a significant one. To me, this just does not make sense. That is why the IAF Guide to ISO Guide 66 requires the CB auditors to test the significance determination criteria for soundness. If a CB auditor is not up to challenge the organization's significance determination criteria, s/he is failing to follow the IAF rules, therefore contravening the rules of accreditation.

 

[Helmut Jilling]

Randy, thanks for posting the excerpts. I am well aware of the content of the sections you posted and agree with them fully. In fact, I happily embrace the thoughtful approach ISO has brought to this difficult subject of environmental performance. Without that, the program would fail.

I would suggest the excerpts perfectly agree with what I have been trying to say.

Yes, it is left to the organization to determine significance, but in a "thoughtful manner ...with consideration of technical issues."

It does not have to be high level chemistry, but can't be oblivious, either. It has to consider financial, technical and regulatory issues. It cannot be arbitrary.

It also cannot ignore the comments that Paul and Sidney made from the standard, and from Guide 66. These statements all have to be taken into consideration.

It cannot be arbitrary. It has to be a thoughtful and legitimate selection, or it serves no benefit to the environment. Ths would seem to be a perfectly reasonable and consistent, and value-added interpretation. I might add, none of my clients have had any issues with this, and readily followed this approach.

Best regards.